Responsible Recycling

Electronics are the fastest growing portion of the municipal solid waste stream. Unlike traditional curbside collected commodities, such as plastic, paper, aluminum and glass, which tend to be homogenous and benign in chemical makeup, electronics are complex. These multi-material products require proper management to avoid environmental, health and safety concerns.

The electronics recycling industry has received a black eye as a result of years of material mismanagement practiced by some unscrupulous recyclers. Today, responsible recyclers are seeking certification to demonstrate their adherence to best practices and to position themselves as industry leaders in environmental management.

Recognizing the need for an industry specific certification that addressed all of the operational and materials management concerns, the U.S. Environmental Protection Agency (EPA) convened a broad stakeholder group to develop what has come to be known as the Responsible Recycler Practices Standard, or the R2 Standard. Representatives from a broad range of stakeholders, including state and federal regulators, OEMS, recyclers and non-governmental organizations (NGOs), participated in the standard development. Toward the end of the process, NGOs disengaged from the group to develop an alternative standard. The remaining stakeholders continued the standard development process.

A little over one year after the first facility received certification in January 2010, 37 recycling facilities have been audited to the standard and many more are under contract with the ANSI- (American National Standards Institute-) accredited certifying bodies that audit to the R2 Standard.

R2 Solutions also has been established as a nonprofit organization to house the R2 Practices and will conduct educational and outreach services and provide administrative support for the multi-stakeholder R2 Governing Council.

Speaking to the importance of certification in the electronics recycling industry, Lynn Rubenstein, R2 Solutions board member and executive director of the Northeast Recycling Council (NERC), says, “The R2 Standard is an important tool for the e-recycling industry. Achieving certification not only distinguishes a recycler from [its] competitors but [also] demonstrates a commitment to the environment, human health and safety and a determination to do ‘the right thing.’” Rubenstein adds, “The electronics recycling industry has long cried out for a way to make it apparent which processors have the environmental management systems and standards in place. R2 does just that.”

R2 HIGHLIGHTS
R2-certified recyclers have been vetted on 55 points in 13 operational and EH&S (environmental, health and safety) areas. For the most part, the standard spells out much of what customers would expect in terms of meeting legal requirements; ensuring worker safety and environmental protection; establishing a reduce, re-use, recycle hierarchy for materials management; and establishing record-keeping requirements and a process for materials flow management. However, there are two areas in particular that were designed to set R2 apart from other e-recycling standards: the areas of data destruction and the global shipments of commodities.

Data security and destruction. In a recent IT Asset Disposition Trends Report, conducted by Converge, mid- to large-sized firms rank data security issues as one of their top concerns when considering IT asset disposal services. Mismanagement of information by a recycler can leave firms open to liability and a damaged reputation. The R2 Standard requires strict data protection practices, including requiring all R2 certified recyclers to:

• Sanitize, purge or destroy data on hard drives and other data storage devices according to practices described in the NIST (National Institute of Standards and Technology) Guidelines for Media Sanitation: Special Publication 800-88, or another current generally accepted standard, or be certified by a generally accepted certification program;
• Document information destruction procedures;
• Provide appropriate training, on a regular basis, for all employees involved in data destruction; and
• Have data destruction processes reviewed and validated by an independent third party periodically.

The standard also allows for customers to request hard drive destruction.

Materials exports. Developing countries can be home to both atrocious and “state-of-the-art” electronics recycling and refurbishing operations. In these countries, as well as internationally, there is a desire to shift electronics recycling and refurbishing away from the former and into the latter types of operations. This accomplishes environmental, health and safety goals while also promoting good jobs in areas of the world that are among those most in need of economic opportunity.

To ensure exported electronic scrap ends up at state-of-the-art facilities, three key criteria need to be met. First, shipments of exported electronic scrap must be sent and received in accordance with the laws of the exporting and importing countries. Illegal shipments all too often end up causing serious harm to health and the environment in the worst of recycling and refurbishing operations.
Second, all receiving facilities must be evaluated regularly to ensure they are employing best technologies and practices. In Asia and other parts of the world, there are many state-of-the-art electronics recycling and refurbishing facilities that rival those in the U.S. in terms of technology and materials management.

Third, all equipment must be accurately characterized on the shipping manifest. Too often, e-scrap exports are characterized as “re-usable” to avoid the added scrutiny and legal requirements that apply to “waste.” This creates a loophole that can allow scrap to be inappropriately sent to a facility that is not capable of safely handling it.

R2 is designed to address each of these criteria. It prohibits the export of end-of-life electronic equipment containing toxic materials unless the shipment is legal under the laws of both the exporting and importing countries. It requires that the receiving facility conforms to key R2 requirements and employs technologies appropriate for the materials it processes. Furthermore, “re-usable” electronics equipment containing toxic materials is subject to these same requirements unless it has been tested and its key functions are working properly. Finally, all shipments must be accurately labeled.

Through these requirements, the stakeholders that developed R2 seek to achieve the goal of protecting vulnerable populations while supporting legal, safe, environmentally sustainable economic development in developing countries.

FUTURE OF R2
Now that R2 has been developed and the industry is embracing these stakeholder-defined best practices, what are the next steps for the standard?

R2 Solutions, a non-profit housing entity, has been established to provide education to recyclers and their clients about R2, ensure the integrity of the standard and support future development of the standard. Importantly, future development of the standard will be conducted through the a transparent and democratic process, just as it was developed.

Governing Council. R2 Solutions is in the process of forming the R2 Governing Council, which will take on the task of updating the standard at least every three years. The group will be balanced with representatives from each key stakeholder group, including large corporate customers, OEMs, electronics recyclers and refurbishers, regulators, NGOs, downstream vendors and experts on international trade. One of the biggest strengths of the standard is that it captures the input and concerns of all stakeholders involved in the chain of custody of scrap electronics as well as those involved in regulating the industry.

“Much like the U.S. Constitution, the R2 Standard was developed through an open and transparent process, therefore the standard is a consensus document,” notes Joe Clayton, director of sales for Synergy Recycling LLC, Madison, N.C. “As the Governing Council takes on the task of updating the R2 Standard, anyone will be able to submit recommended changes to the standard and voice opinions and ideas about those proposed changes.” He adds, “History has shown us that the most effective and relevant standards have been developed through similar, consensus-based processes. The success of these standards is in large part due to the fact that they most accurately capture the concerns of the industry brought forth by all stakeholder groups, without exclusion. Mechanisms for addressing those concerns are then drafted in the standard in the same fashion. The result is a truly comprehensive standard—that’s the real strength of R2.”

Quality Control Strategy. Recyclers seeking R2 certification are thoroughly vetted in 55 areas of concern during the auditing process. However, the question that every certification program is challenged with remains, “Once certification is achieved, is there assurance that conformity is maintained?” To assure continued confidence in the R2 Standard, R2 Solutions is exploring the possibility of developing a quality control strategy that will help to answer this question.

The quality control strategy will likely include a combination of internal and external control tools. This two-prong approach will include creating tools that will help recyclers to evaluate conformity internally as well as creating an infrastructure through which conformity can be periodically monitored by an independent party. R2 Solutions believes this strategy will be crucial to maintaining the integrity of the standard in the long term. Provision 13 of the R2 Standard likely will play a central role in the overall strategy as it requires R2-certified facilities to keep all relevant documentation in a single location.

SHAPING THE INDUSTRY
Now that the R2 Standard has been in operation for one year, the impact that it is having on the industry is evident. R2 Solutions is working hard to educate customers of electronics recycling services about the value of the R2 Standard, which is becoming a trusted brand for those seeking IT asset disposal (ITAD) services. Customers of R2 certified recyclers can have a new level of confidence in their service providers.

From a recycler’s standpoint, the R2 standard is improving industry practices. In terms of individual performance, we have seen some R2-certified recyclers choose more transparent downstream vendors. And collectively, the standard is raising the bar for the industry as a whole as the expectations of customers rise. Through the continued involvement of key stakeholders, the R2 Standard is positioned to have a positive and lasting impact on this important sector of the recycling industry.

Additional information about the R2 Standard, including a free copy of the standard for downloading, is available through the R2 website at www.r2solutions.org.

John Lingelbach is acting executive director of R2 Solutions, Hotchkiss, Colo., and can be contacted at Lingelbach@r2solutions.org. Kim Holmes is principal consultant of Oregon-based 4R Sustainability Inc. and contributes to a number of R2 Solutions’ projects. She can be contacted at kholmes@4rsustainability.com or at kholmes@r2solutions.org.