An Integrated Approach

The reputation of the recycling industry has been damaged by more than one fly-by-night operator collecting used electronics and dumping them in a developing nation.

For the industry’s largest customers, site visits were the best way to identify the responsible service providers. They had to see for themselves, because the industry didn’t have a certification that brought with it peace of mind.

That’s why the Institute of Scrap Recycling Industries Inc. (ISRI), Washington, D.C., spent the last three years developing the RIOS (Recycling Industry Operating Standard) and R2/RIOS certification programs. RIOS is a third-party certification of quality, environment and health and safety (QEHS) standards. R2/RIOS combines the RIOS program with the EPA’s Responsible Recycling (R2) standards for electronics recyclers. Both certifications are now available to recyclers.

BENEFITS OF CERTIFICATION

Operations that don't excel in QEHS are more likely to experience inefficiencies, problems, violations and accidents, potentially hurting the bottom line. In contrast, companies that strive for excellence in QEHS help to ensure profitability and future viability. Achieving certification can help to ensure a comprehensive QEHS management system and potentially benefits recycling companies in several ways.

First, a combined management system saves recyclers time and money by implementing all three standards at once instead of piecemeal over time. Certification boosts the company’s reputation because it shows the company is committed to QEHS management and to meeting its customers’ QEHS requirements.

Certification also can protect a company from potential environmental and health and safety effects and reduce risk of possible penalties and litigation because it ensures high levels of compliance.

The RIOS program is designed to improve monitoring of a company’s QEHS performance and to drive improvements to day-to-day operations. Other possible benefits include increased revenue, decreased costs, better emergency preparedness and improved relationships with regulators and the community.

For electronics recyclers, R2/RIOS is designed to assure end-of-life electronic equipment is handled responsibly. Certified companies can use “Certified Electronics Recycler” in their marketing to stand out from their competitors.

Many recycling companies realize the benefit of certification and have invested in ISO 9001, ISO 14001 and OHSAS 18001 for their facilities. RIOS is designed to be an alternative specifically for the recycling industry with the same bottom-line benefits but with fewer expenses than pursuing each of the other three individual certifications.

CERTIFICATION HISTORY

ISRI began developing RIOS in response to concerns about regulatory scrutiny and the public perception of the scrap industry.

After several years of development, the RIOS program came off the drawing board and was introduced last year. SGS Systems and Services Certification was the first certification body to receive R2 and RIOS accreditations from the ANSI-ASQ National Accreditation Board (ANAB). Ocala Recycling LLC in Ocala, Fla., became the first RIOS-certified facility in November 2009.

Meanwhile, the EPA, original equipment manufacturers and other stakeholders developed R2, which was released in October 2008. R2 is a voluntary set of general principles and specific practices for recyclers disassembling or reclaiming used electronic equipment.

ISRI developed R2/RIOS to integrate the R2 guidelines with a comprehensive management system. R2/RIOS is designed to be a complete blueprint for responsible electronics recycling because it combines environmental standards with a complete QEHS management system.

ISRI thinks of R2/RIOS as the highest standard for electronic reuse and recycling. R2 is supported by the EPA, major computer original equipment manufacturers, the Information Technology Industry Council and several state and local governments.

Electronics recycling company TechTurn, Austin, Texas, became the first R2/RIOS-certified facility in January 2010. Intechra’s Columbus, Ohio, facility and Creative Recycling facilities in Morrisville, N.C., and Tampa, Fla., were certified in February. 

Companies can accredit to R2 alone if the system is supported by an adequate environmental, health and safety management system. IMS Electronics Recycling in Poway, Calif., and Vancouver, Wash., were R2 certified in February.

CERTIFICATION REQUIREMENTS

Now that the gates are open and both programs are underway, companies are stepping up to the plate to get certified. RIOS certification entails six key requirements with which pursuing companies must comply:

1. General requirements—Describe the scope of RIOS, assign QEHS roles and responsibilities, provide adequate resources and facilities and ensure documents and records are managed and controlled;

2. Policy—Implement a QEHS policy committing to legal compliance, customer and product requirements, pollution and workplace injury prevention and continual improvement;

3. Planning—Identify the QEHS footprint, including environmental impacts and health and safety risks, determine legal, product and other relevant requirements and set goals for improvement;

4. Implementation—Determine competency and training requirements and ensure appropriate training, ensure adequate communication processes, implement operational controls and ensure emergency response to potential incidents and accidents;

5. Checking and corrective action—Monitor, measure and validate characteristics of operations, address and eliminate non-conformances, control non-conforming products and conduct internal audits; and

6. Management review—Conduct a RIOS review with recommendations for continual improvement at least annually.

To become R2/RIOS certified, companies must meet the above requirements as well as the following R2 practices:

1. Develop an environmental, health and safety management system (This is covered by RIOS.);

2. Have a hierarchy of responsible management—Document and implement a policy for managing used and end-of-life equipment based on a hierarchy of reuse, recovery and disposal or energy recovery (also applies to selection of downstream vendors);

3. Legal compliance—Plan for and ensure compliance to EHS legal requirements, including requirements regarding laws of importing countries receiving focus materials (FM);

4. On-site EHS—Use practices at facilities that protect worker health and safety and the environment;

5. R2 focus materials—Manage the FMs on site and throughout the recycling chain to protect worker health and safety, public health and the environment;

6. Reusable equipment—Refurbish as  needed, test and properly package equipment and components;

7. Tracking throughput—Maintain records to show the flow of equipment, components and materials that pass into and out of the facility;

8. Data destruction—Implement generally accepted information destruction procedures;

9. Storage—Store items and materials to appropriately manage EHS risk;

10. Facility security—Maintain security measures in all parts of the facility;

11. Insurance/financial responsibility—Possess adequate insurance and a plan and financial assurances for proper closure of facilities;

12. Transport—Transport equipment, components and materials using transporters that have regulatory authorizations; and

13. Recordkeeping—Retain documentation necessary to show conformity to these requirements.

THE AUDIT PROCESS

When a recycler has made the decision to become certified, the process begins by contacting the certifying body (CB). At this time, SGS is the only CB for RIOS and R2.

The certification audit process is based on registration and surveillance audits. The Stage 1 audit is an overall readiness review where SGS conducts an on-site document review and provides immediate feedback on the existing management system. In Stage 2, SGS audits to see that R2/RIOS has been effectively implemented and that the organization is conducting its day-to-day operations as planned.

Upon successful implementation, SGS will issue ANAB-accredited certificate(s) confirming that the organization conforms to the program requirements.

Yearly surveillance audits are conducted to ensure the organization is maintaining an effective management system.

Achieving certification is a sure sign your company has made the necessary investments and is committed to being a responsible recycler.