Certification Maze

The events of the last few years, including the export of monitors and other cathode ray tube devices in violation of U.S. Environmental Protection Agency regulations as well as the dumping of toxic materials from electronics in developing countries around the globe, has lead to the growth of third-party certification programs geared specifically toward electronics recyclers. These certification programs developed by the Institute of Scrap Recycling Industries Inc. (ISRI), Washington, D.C.; a stakeholder group convened by the U.S. EPA;  and the Basel Action Network (BAN), Seattle,  all seek to provide clients of electronics recycling firms with assurances that the companies handling their devices are meeting a certain level of performance when it comes to environmental, health and safety practices. These certifications also seek to assure organizations that their electronic devices will be properly safeguarded until the information they contain can be properly destroyed, as do certifications offered by the National Association for Information Destruction, Phoenix. (See sidebar, “Information Protection,” page 92.)

In light of recent developments in the area of third-party certifications for electronics recyclers, it can be difficult to keep track of what these programs entail, which is why Recycling Today is offering this certification primer and quick reference chart, available at our Web site, www.RecyclingToday.com.

We hope these resources will act as a reference tool for electronics recyclers and their clients, who may be wondering which program represents the best option for their businesses.

RESPONSIBLE RECYCLING

While the U.S. EPA’s Responsible Recycling Practices for Electronics Recyclers (R2) is the newest certification available to electronics recyclers, these practices have been in development since 2001. The American National Standards Institute-American Society of Quality National Accreditation Board (ANSI-ASQ ANAB) announced July 27, 2009, that it would start accrediting companies to certify recyclers of electronic equipment under the R2 practices. However, the development of the practices began when the EPA facilitated a group of stakeholders consisting of representatives from state governments, electronics manufacturers, recyclers, trade associations and non-governmental organizations who first began meeting in 2001 as the National Electronic Product Stewardship Initiative (NEPSI).

According to a press release issued by ANAB, “A Committee of Experts that includes representatives of the EPA, states, electronics manufacturers, electronics refurbishers and recyclers and certification bodies developed ANAB’s R2 accreditation requirements.”

Although the EPA facilitated the development of these standards, Thea McManus, associate director of the Resource Conservation and Sustainability division of the EPA, says the agency does not own the standard. “As a federal agency, the EPA cannot endorse any particular standard,” she adds, “but we are encouraged by recyclers’ desire to get certified to any particular standard.” All R2 audits are performed by certification bodies who have been ANAB approved rather than by the EPA itself.

R2 requires recyclers to develop and use environmental, health and safety management systems (EHSMS). Additionally, R2 states: “An R2 electronics recycler shall obtain a certification from an Accredited Certification Body stating that: (1) Its EHSMS conforms to the requirements of this provision, and (2) Its practices conform to the EHSMS and to the requirements of these R2 Practices.”

R2 also promotes reuse and recycling of end-of-life electronics, setting forth a hierarchy of management strategies that puts these approaches ahead of energy recovery or disposal.

Regarding export, the standard also states that “An R2 electronics recycler shall comply with all applicable environmental, health and safety legal requirements and shall only export equipment and components containing FMs (focus materials) to countries that legally accept them.” FMs include items containing mercury, lead and PCBs (polychlorinated biphenyls). R2 also stipulates that FMs should not be managed using energy recovery, incineration or land disposal. However, R2 allows that “if circumstances beyond the control of the R2 recycler disrupt its normal management of an FM, it may consider these technologies to the extent allowed under applicable law.”

According to McManus, the use of downstream vendors is a critical issue when it comes to electronics recycling. R2 requires a certified recycler to “maintain business records sufficient to demonstrate the material flow of equipment, components and materials that pass through its facility” for a period of at least three years. These documents include “commercial contracts, bills of lading and other commercially accepted documentation for all transfers of equipment, components and materials into and out of its facility, as well as for any brokering transactions.”

McManus says all downstream vendors used by an R2-certified company have to be in compliance with the R2 standards pertaining to FMs and export.

In the area of data security, R2 calls for an electronics recycler to “employ generally accepted data destruction procedures, including sanitizing, purging or destroying data on hard drives and other storage devices, unless otherwise requested in writing by the customer. The R2 electronics recycler shall adhere to the data sanitization, purging or destruction practices described in the NIST (National Institute of Standards and Technology) Guidelines for Media Sanitization: Special Publication 800-88 or another current generally accepted standard or be certified by a generally accepted certification program.”

The R2 standard does not take a position on the use of prison labor. “Instead, we have developed practices that are harnessing all important components of worker safety,” McManus says. She adds, “That being said, there is a federal law that encourages the federal government to use the services of federal prison industries. The federal government may be more restricted when it wants to get rid of its computers than someone else.”

The complete list of R2 practices is available at www.decideagree.com/R2%20Document.pdf, and recyclers can access a checklist at www.decideagree.com/The%20R2%20Checklist.pdf.

R2/RIOS

ISRI is offering a joint certification for electronics recyclers that incorporates R2 certification with the organization’s RIOS, or Recycling Industry Operating Standard, certification. This certification is a successor to the certification formerly offered by the International Association of Electronics Recyclers (IAER), an association that ISRI completed the acquisition of in May 2009.

RIOS is a quality, environment, health and safety (QEH&S) management system standard designed for the recycling industry that includes continual improvement in QEH&S performance, according to David Wagger, ISRI RIOS program manager. “It helps recyclers manage processes and procedures and do better over time.” It was developed by ISRI staff and the organization’s members. The R2 practices, Wagger says, add specific downstream requirements for electronics recyclers.

Today, SGS is the only accredited certification body able to certify recyclers to the R2 and RIOS standard, which is administered by ISRI Services Corp. ANAB is the accreditation body that accredits certification bodies, such as SGS.

R2/RIOS certification is audited on a facility basis and expires after three years. After achieving certification, electronics recyclers are subject to at least two surveillance audits following an initial two-stage audit and prior to recertification, Wagger says.

When it comes to the issue of worker safety, RIOS offers more comprehensive direction than R2, Wagger says, going beyond a plant’s own staff to include any visitors to the certified electronics recycling facility.

Additional information on ISRI’s R2/RIOS certification is available at www.isri.org/rios.

E-STEWARDS 

BAN introduced its e-Stewards Standard for Responsible Recycling and Reuse of Electronic Equipment in July 2009, written for internal use. ANAB is in the process of accrediting three certifying bodies—AQA International, Columbia, S.C.; Orion Registrar Inc., Arvada, Colo.; and QMI-SAI Global, Independence, Ohio—to certify to the standard. The first recycler certifications have been completed and will be announced April 15, according to Sarah Westervelt, BAN e-stewardship policy director.

The e-Stewards certification program is an accredited third-party-audited program with a detailed standard that replaces BAN’s former Electronic Recycler’s Pledge of True Stewardship, a program that involved a basic third-party desk and documentation audit, says Lauren Roman, business director of the BAN e-Stewards program. The standard is applicable to electronics recyclers, refurbishers, asset managers, processors and refiners. Collectors, brokers and transportation companies are not currently eligible for the certification.

The e-Stewards Standard requires ISO 14001 certification for environmental management systems (EMS), Roman says. The entire ISO 14001 standard is embedded in the e-Steward’s Standard, meaning that when a facility is audited to this standard, the ISO audit is performed concurrently, if not already completed.

“We believe that having a rigorous EMS is a crucial framework in which to insert industry-specific performance requirements,” Westervelt says. “The standard itself is based on the international set of definitions for hazardous waste in the Basel Convention.” She adds, “Having those definitions at the core of any standard is essential in order to determine legal exports.”

Westervelt says the e-Stewards program requires accountability concerning toxic materials, with the recycler knowing and controlling where the materials go throughout the disposition process. While R2 does not define hazardous materials based on the international trade definitions and allows recyclers to ship “focus materials” to developing countries as long as they have “a copy of a law or court ruling” that is believed to indicate the country’s legal imports, she says, e-Stewards forbids shipments of toxic materials from developed to developing countries for recycling or disposal.

Roman says this is a fundamental difference between the two standards. The  e-Stewards program requires recyclers to operate in accordance with the Ban Amendment to the Basel Convention on the Control of Transboundary Movements of Hazardous Wastes and their Disposal, Westervelt adds, “which means that developed countries may not send their hazardous waste to developing countries for any reason.”

The same requirements do not apply for clean, non-toxic commodities, such as copper, steel and aluminum, she adds. However, a certified e-Steward would not be able to ship shredded material that contains lead solder to developing countries for recycling.

Recyclers who are not using other certified e-Stewards for downstream processing will have to perform regular audits of their vendors and keep 12 months of shipping documentation on hand, Westervelt says. However, there are fewer due diligence requirements when using other certified e-Stewards as downstream processors.

The e-Stewards Standard was developed in cooperation with many of the companies who participated in BAN’s Pledge as well as with other recyclers and refurbishers, the California Department of Public Health (which provided technical input on health and safety), e-scrap auditors, NGOs, refurbishers via CompuMentor, mobile phone recyclers and certification experts. According to Westervelt, OEMs also have been invited to provide input on the standard.

Unlike the R2 and R2/RIOS certification programs, e-Stewards must certify all of their locations within 18 months after their first site is certified, Westervelt says. The certification follows a typical three-year cycle, and recyclers are subject to surveillance audits in year two and three following the initial two-stage audit, Roman says.

In the area of information security, the e-Stewards Standard requires recyclers to make their customers aware of data security concerns and to have clear agreements in place with their clients. If customers choose against data sanitation, certified recyclers must have signed waivers on file. Otherwise, recyclers must protect data against theft and loss and follow NIST guidelines for destruction and sanitation, plus additional requirements to address hard drive imperfections.

The e-Stewards Standard has detailed requirements for worker health and safety. Recyclers must conduct regular air sampling for specific toxins, and results must be in compliance with regulated exposure limits. E-Stewards also will be gathering actual exposure data for hazards not yet regulated, such as brominated flame retardants, which BAN will use to modify the standard as well as industry practices in the future, Westervelt adds.

Under e-Stewards, recyclers may not use prison labor to process hazardous materials, Westervelt says. “Using a disadvantaged incarcerated population that is not subject to unscheduled OSHA inspections to manage this hazardous waste stream can be comparable to sending the material to a developing country,” Westervelt says. “Doing so is not dealing with this hazardous waste stream in a way that fully incorporates costs and risk.”

Exports can be a contentious issue for electronics recyclers and their clients. Electronics can be exported for reuse or further refurbishment by e-Steward recyclers if all of the components and devices that contain hazardous materials are tested and verified to be fully functional prior to shipment. These devices must be packaged in a way that preserves their functionality as well, Westervelt says, and all personal data has to be eradicated.

More information on BAN’s e-Stewards certification program, including a free copy of the excerpted standard, can be found at www.e-stewards.org.