Ongoing improvement

Performance and management standards, such as e-Stewards and the Responsible Recycling (R2) Standard for Electronics Recyclers, are designed to help the organizations that implement them achieve continual improvement of their operations. Similarly, the standards themselves are reassessed regularly to ensure they are addressing the needs of the current market.

KEEPING CURRENT

Sarah Westervelt, policy director for e-Stewards, which was developed by the Basel Action Network (BAN), Seattle, says such standards typically are updated every three to five years. However, the e-Stewards Standard has an additional formal vehicle known as Sanctioned Interpretations for making clarifications to the standard on an ongoing basis. “We intentionally built this formal tool to allow the standard to evolve as needed when needed,” she says.

According to the e-Stewards website, www.e-stewards.org, “The e-Stewards Sanctioned Interpretations exist to provide a single focal point for all questions and changes related to the e-Stewards Standard between formal revisions of the standard. All organizations seeking certification must meet requirements of both the current e-Stewards Standard and the current e-Stewards Sanctioned Interpretations.”

Westervelt says the Sanctioned Interpretations allow the e-Stewards Standard to respond to the needs of the electronics recycling industry, noting issues surrounding cathode ray tube (CRT) glass markets as one example, on an ongoing basis. She says this approach helps to keep the e-Stewards Standard “relevant to recyclers and their customers. It has allowed us to evolve the standard as appropriate.”

Boulder, Colorado-based SERI, the R2 Standard housing body, also offers an interpretation process. According to the “SERI Manual of Policies and Procedures for R2 Standard Development,” dated Aug. 30, 2015, and available through www.seri.org, affected parties can submit a written request for a formal explanation of the meaning or intent of a specific provision of the R2 Standard to the Standard Management Team (SMT). The request will be presented to the R2 Consensus Body, which, with input from the Technical Advisory Committee (TAC), prepares a draft response. In the case that the draft includes a statement of interpretation, the SMT must submit it to the SERI board of directors for review and final approval.

Interpretations are released to R2 certified companies through SERI’s website and newsletter.

While these processes allow the housing bodies of these standards to provide clarification, sometimes a more thorough update is required. Both R2 and e-Stewards, which were introduced in 2009, released updated standards in 2013.

AREAS OF FOCUS

With the most recent version of their standards, SERI and BAN sought to strengthen requirements in various areas.

R2 Updates. With the introduction of R2:2013, Patty Osterberg, SERI director of education and outreach, says the rate of certification slowed slightly. She attributes this to the additional requirements of the revised standard, specifically the need for an environmental management system either in the form of ISO 14001, managed by the International Organization for Standardization, or RIOS (Recycling Industry Operating Standard), which was introduced in 2005 by the Institute of Scrap Recycling Industries (ISRI) and now is managed by the Global Recycling Standards Organization.

In the area of data security, R2:2013 requires recyclers to verify their data sanitization methods to ensure that this equipment is properly calibrated and working, Osterberg says.

According to the standard, “The R2:2013 electronics recycler shall adhere to the data sanitization, purging or destruction practices described in the FIST Guidelines for Media Sanitization: Special Publication 800-88 (rev. 1), or another current generally accepted standard, or be certified by a generally accepted certification program,” such as the National Association for Information Destruction (NAID) and the Asset Disposal & Information Security Alliance (ADISA) certification programs.

Reuse is an important area of focus for SERI, and R2:2013 reflects this, Osterberg says. “We are the oversight body for R2, but we also work to create a world where electronic products are repaired and recycled in a way that promotes worker health and safety,” she says.

This emphasis on reuse is “one of the great strengths” of the R2 Standard, Osterberg adds.

The R2:2013 has helped to ensure more robust testing and tracking of products destined for the reuse market, she says, adding that it also has improved legal compliance regarding imports and exports.

Under the R2 Standard, devices must be tested before they enter the reuse market, and recyclers must maintain records of these tests. “This gives buyers greater confidence in what they are buying and helps to minimize what in some cases was the sale of nonworking devices,” Osterberg says. “We want to prevent sales in the guise of reuse that can have damaging effects on the environment and people.”

While SERI introduced spot audits of its certified recyclers in 2015, the organization says it plans to double the number of spot and desk audits it completes in 2016. Osterberg says, “We learned that going on site can be useful, but it can be just as useful to review other info, such as bills of lading.” She says combining site audits with documentation audits can help SERI “be more efficient and cover more ground.”

SERI also is working to extend responsible electronics recycling beyond the U.S. and Canada, having certified companies in India, the Pacific Rim and Europe. “R2 is truly a global standard,” Osterberg says.

However, she says SERI recognizes that for a number of companies, certification may not be an option because of the expense it entails, which is why the organization is working to produce videos on best practices in the industry to make available on YouTube. “We want to raise the bar for everyone,” Osterberg says.

E-Stewards Updates. The integration of ISO 14001 into the e-Stewards Standard has evolved since the standard was introduced in 2009, Westervelt says. While it was part of the e-Stewards Standard from the beginning, she says ISO 14001 has been better integrated in the most recent version. “It is easier for a recycler to operate a single management system using our standard.”

Data security also was addressed in e-Stewards Version 2.0.

“We dramatically increased data security requirements in Version 2.0,” Westervelt says. This was done at the request of certified recyclers to better meet the needs of their clients, she adds.

“It represents an absolute evolution from the earlier requirements while still giving flexibility in implementation,” Westervelt says of e-Stewards Version 2.0 data security requirements, adding that a recycler can identify the most rigorous standard that is most applicable in its area or region, with the National Institute of Standards and Technology (NIST) guidelines serving as a fallback.

E-Stewards Version 2.0 also requires certified companies to verify that 100 percent of the data on 100 percent of devices they process has been sanitized. “We were concerned that this might be over the top, but stakeholders felt very strongly about it,” she adds.

Recyclers must establish data breach response programs under e-Stewards Version 2.0, which also specifies the need for a documented chain of custody that stipulates when and where transfer of custody to the recycler begins and ends, secure logistics that maintain effective physical and electronic controls throughout transport and transfer and comparable security requirements for temporary storage locations.

Health and safety requirements were an additional area of focus in e-Stewards Version 2.0. Westervelt says the changes are “very detailed and in response to real concerns and releases that are happening even in the most sophisticated facilities.”

These standards were updated in consultation with NIOSH (National Institute for Occupational Safety and Health), an occupational physician and a certified industrial hygienist, she says.

E-Stewards Version 2.0 environmental, health and safety standards require certified recyclers that are performing disassembly, shredding and other forms of processing to conduct regular testing regarding employee exposure to hazardous materials using certified industrial hygienists. Westervelt acknowledges that testing of this nature is “not cheap,” and says many recyclers pursuing e-Stewards certification decide to limit their operations to avoid these additional monitoring and recordkeeping requirements.

Looking ahead to potential revisions to future versions of the e-Stewards Standard, Westervelt says she would like to see more explicit requirements for site closures and associated financial stipulations, such as requiring third-party custody of these financial instruments. She acknowledges, “This is challenging because there are not a lot of options out there.”

The R2 Standard has helped to ensure more robust testing and tracking of products destined for the reuse market, Osterberg says, adding that it also has improved legal compliance regarding imports and exports.

Westervelt says the program’s administrators are looking into potential options.

STATE OF THE INDUSTRY

Westervelt says the slowdown in China’s economy and the crash in commodities markets have led to a crisis for the recycling industry, and electronics recyclers have not been immune. Therefore, BAN is looking for ways to reduce certification costs for e-Stewards recyclers without reducing the program’s rigor.

“A huge financial burden has been placed on recyclers to handle hazardous e-waste,” Westervelt says, adding that she would like to see this burden placed more so on manufacturers and on consumers.

Osterberg also refers to the downturn in commodity prices and the effect it has had on electronics recyclers, causing many companies to prioritize offering asset disposition services and component reuse. “Recyclers that have diversified their business models are able to weather the economic ups and downs better,” she says.

The R2 and e-Stewards standards will be charged with balancing responsible recycling with market realities in their future updates.

The author is managing editor of Recycling Today and can be contacted via email at dtoto@gie.net.