Electronics Recycling Supplement--Audit Prep 101

Currently, no distinct national accreditation system exists for the industry [though the International Association of Electronics Recyclers and the Institute of Scrap Recycling Industries Inc. offer industry-specific, third-party certifications]. At this time, many credible recyclers possess ISO (International Organization for Standardization) and OHSAS (Occupation Health and Safety Assessment Series) certifications to validate their practices.

KNOW THE REQUIREMENTS & EXPECTATIONS. One of the most common measures of environmental management is the ISO 14001 certification. Basic requirements include rating the significance of environmental aspects, developing a plan, documenting details and measuring the methods for determining the effectiveness of practices that satisfy the environmental management system.

The Occupational Health and Safety Assessment Series (OHSAS 18001) is a standardization system that gives a company structure in managing occupational health and safety risks. Requirements include developing policies, recognizing hazards, planning for potentially dangerous situations, setting goals and outlining and evaluating an action plan.

Thoroughly understanding the requirements of a standardization organization and following through with program details are keys to successfully passing an audit.

WHAT TO EXPECT. After an electronics recycling company has established compliance programs that are appropriate for its facility, the company can expect on-site visits from auditors. Each may represent a variety of specialties but will have the same purpose for visiting: ensuring that a company’s employees, subcontractors and, in many cases, vendors perform to the established standards and practices. Auditors, in general, will check for strict documentation on nonconformance of standards, how problems were corrected and what has been done to prevent future nonconformance in those areas.

One way to impress an auditor is through comprehensive documentation and records. Evidence of issues such as nonconformance or corrective and preventive action can be proven through documentation of program requirements and the company’s achievements and employee awareness of the certification standards and the ways in which the company complies.

During an audit, everyone from top management to temporary employees must be prepared for a variety of questions from the auditor. Typically, auditors want to speak in depth with top management and those with direct authority over aspects identified in the program.

Additionally, preparing and maintaining a set of audit books containing information relevant to the program will facilitate the process of hosting an auditor. Such books give the auditor a clear and concise picture of how a recycler develops and maintains its program and is an effective way to show a company’s mastery of the system.

GENERAL RECOMMENDATIONS. Surviving an external audit can be stressful, but by following some simple rules, the process can be manageable.

A company should get guaranteed commitment from upper management. Without the combination of management support and a designated person in charge of standardization, the project is unlikely to succeed.After support is achieved, a company must develop the plan’s framework, analyzing what needs to be done to comply with the chosen certification(s). A program should be implemented using the methods defined in the plan. This is a critical phase. If the program gets off to a weak start, it will be difficult to implement, and success could be compromised. A company should train, educate and encourage employees during the implementation phase, showing them improved or correct practices. Electronics recyclers should have a checklist or action record of their plans. When an action item is complete, it should be checked off; if there is a problem, it should be noted and fixed.A company should organize regularly scheduled meetings between the person or department responsible for standard enforcement and top management. This is a time to openly discuss problems and brainstorm continuous improvements. Electronics recyclers should be sure to keep a record of needed actions and methods for correction.A company should constantly evaluate the steps it has taken, modifying them as needed. Measuring and analyzing practices is paramount to compliance and the ability to successfully pass an external audit.