Chasing the trail of transboundary e-scrap

The electronics industry is a global one, from component manufacturing through to the recovery and recycling of discarded electronics.  While much of this trade occurs legally, it continues to be very difficult to determine the quantity and nature of the millions of pounds of material recovered from electronic scrap and shipped to smelters, plastics recyclers and glass recyclers situated around the world.   

     The lack of specific data has been a primary challenge in offering measured regulatory oversight and informed international policy.  "There is a dearth of good, publicly available data," explains Josh Lepawsky, Assistant Professor at Memorial University and R2 Technical Advisory Committee member.  "However, what data do exist typically don't distinguish between different types of material.  And, by definition, trade data misses any illicit transboundary flows.  Good regulatory oversight needs good data."

     In an effort to better understand what information is needed in regards to transboundary movement of e-scrap and how that information can be obtained, a workshop is being organized under the umbrella of the Solving the E-waste Problem (StEP) Initiative by the Materials Systems Laboratory (MSL) at the Massachusetts Institute of Technology (MIT) and the National Center for Electronics Recycling (NCER) with financial support from the US EPA.  Invited attendees will discuss the transboundary flows of electronic scrap originating from the U.S., but with consideration of the movement of materials from other regions as well. 

     John Lingelbach, Acting Executive Director for R2 Solutions, will be participating in this workshop which will be held in June.  "We are excited to participate in an endeavor that seeks to bring a scientific and balanced look at the truly global nature of this industry.  Ensuring responsible management of scrap electronics material, whether that's occurring in the U.S. or overseas, is the central goal of the R2 Standard.  Improving access to better export information and transparency will further support this goal."

     The workshop will be an important opportunity to lay the groundwork for the project.  "This workshop will bring together some of the leading experts in the field," notes Jason Linnell, Executive Director of NCER.  "The workshop marks the beginning of this significant project that will lead to a sound characterization of the sources, destinations, and quantities of used electronics flows in order to inform strategic decision-making."

R2 Status Check 

When the R2 Standard was made available as the first certification specific to the electronics recycling industry, it quickly became the leading industry third-party certification program for electronics recyclers.  Since then, the R2 Standard has continued to gain momentum and presence in the marketplace.  To date, 76 facilities have been R2 certified in North America. 

     This month, AQA International became the fourth ANAB accredited Certififcation Body (CB), joining Orion Registrar, Perry Johnson Registrars and SGS.  These CBs are actively working with dozens of clients, auditing facilities throughout North America as well as facilities in Europe, Mexico and Asia.  R2 Solutions expects the number of certified facilities will exceed 100 by the end of the year, further expanding responsible recycling options for customers seeking these services.     

     Since September of 2010, R2 Solutions has been working hard to promote the merits of the R2 Standard.  The R2 message has literally reached thousands, with articles about the R2 Standard having been featured in a variety of industry news outlets, including:

• PowerSource Online (May 2011)
• Electronic Waste Journal (May 2011)
• NERC bulletin (April 2011)
• ITAK magazine (March and June 2011)
• Recycling Today (March 2011)
• Product Stewardship Institute Blog (December 2010)

Additionally, our monthly newsletter is distributed to over 3,000 key industry players keeping them abreast of important R2 news.  R2 Solutions looks forward to continuing to increase awareness of the standard, act as a resource for the growing number of R2 certified recyclers, and provide support for the ongoing development of the Standard.

Your input is requested as the TAC considers revisions to the R2 Standard

The R2 Standard is scheduled for updating every three years so that the Standard is kept current as technologies, management practices, and the materials processed change within the electronics recycling industry.  The first version of the standard was published in October 2008, and is slated for revisions over the next number of months.  The R2 Technical Advisory Committee (TAC) will soon begin the work of reviewing the standard. 

     The TAC is initiating this process by asking interested parties to provide initial suggestions about areas of the Standard that should be evaluated for potential revision.   R2 Solutions has created a web page that will allow you to submit this input electronically.  R2 Solutions and the TAC welcome feedback from all interested parties, particularly those who have first-hand experience implementing the practices of the R2 Standard, preparing firms for audits, or performing audits.   Please go to the web page to provide input.

Only ANAB accredited CBs can award R2 certification

Recyclers seeking R2 certification should be aware that there are only four (soon to be five) ANAB accredited certifying bodies (CBs) that can award R2 certification.  At least one non-ANAB accredited organization has emerged purporting to offer certification to R2.  The R2 Standard (Provision 1b) explicitly requires that R2 certification be conducted by an Accredited CB, which is defined as a CB that is "accredited under ISO/IEC Standard 17021:2006 to certify electronics recyclers to the R2 Standard."  In North America, this means ANAB accreditation.  When seeking certification, electronics recyclers should visit the R2 Solutions website to find an ANAB accredited CB and only enter into contract with one of these CBs. 

Conformity review:  Downstream Due Diligence (Part II) 

Conformity review is a monthly column highlighting important operational  

information concerning the R2 Standard

Last month's Conformity Review  was dedicated to downstream due diligence.  It spurred enough discussion to merit continuing review of the topic for another month.   In the April R2 Update, R2 Solutions described how to ideally demonstrate the necessary downstream due diligence.  This month we will expand on the discussion, go into more detail, and offer some clarifications.

     Provision 5 (e) and (f) of the R2 Standard make clear that each vendor in the Recycling Chain must conform to Provision 5 (e) (1)-(7).  And that the R2 recycler must confirm this.

From Provision 5 (underline added):

Selection and Ongoing Due Diligence of Downstream Vendors for FMs

(e)  For shipments of removed FMs, and shipments of equipment and components containing FMs, an R2 electronics recycler shall select downstream vendors that possess and conform to:

(1) The R2 recycler's FM Management Plan (developed in accordance with and including the requirements set forth in Sections (b) - (d) above),

(2)  A documented environmental, health, and safety management system,

(3)  A list of its environmental permits and copies of each,

(4)  This Section (e) of Provision 5, thereby establishing that each vendor in the Recycling Chain conforms to these subsections (1) - (7),

(5) Provision 6 (Reuse),

(6)  The exporting requirements of Provision 3 (a) (2), and

(7) Provision 7 (Tracking Throughput).

(f)  An R2 electronics recycler shall confirm, through audits or other similarly effective means that each downstream vendor in the Recycling Chain to which Section (e) applies continues to conform to the requirements of Section (e) for as long as it receives FMs directly or indirectly from the R2 recycler.

So how does an R2-certified recycler confirm that each downstream vendor in the Recycling Chain for its FMs possesses or conforms to each of Provision 5 (e) (1)-(7)?  What does an auditor need to see?  (Note, "each downstream vendor in the Recycling Chain" means each vendor all the way to Final Disposition of the materials, so in some instances we could be talking a 2^nd, 3^rd, or even more tiers of vendors.)

     First, for an R2 recycler to show that it is conforming to Provision 5 (e), it needs to obtain from its 1^st tier FM vendors documentation that will enable its R2 auditor to reasonably conclude that each 1^st tier vendor possesses or conforms to (1)-(7).  If you go through each of (1)-(7) above, this is reasonably straightforward.  

     One of the more difficult is (7), which simply states "Provision 7 (Tracking Throughput)".   Here, the R2 recycler needs to be able to provide its R2 auditor with something that will allow the auditor to reasonably conclude that each 1^st tier vendor, per Provision 7 (a) on tracking throughput, "maintains for at least three years commercial contracts, bills of lading, or 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." 

     Producing actual bills of ladings (BOLs) is the most straightforward approach in many instances, but not possible in all situations, so Provision 7 explicitly provides alternative approaches.  In addition, many auditors are looking for a complete flow chart of the downstream vendors for each FM.

     Second, for an R2 recycler to show that it is conforming to Provision 5 (e), it needs to provide its R2 auditor with evidence that will enable the auditor to reasonably conclude that each 2^nd , 3^rd, (and 4^th, etc.) tier downstream vendor for FMs possesses or conforms to Provision 5 (e) (1)-(7).  As with the 1^st tier vendors, this must be done "through audits or similarly effective means."  This is the most difficult requirement of the R2 Standard to meet.

     To date, one approach to addressing this requirement has been to include language in a contract, survey, or audit of each 1^st tier vendor asking them to verify that they request the same information regarding (1)-(7) of their downstream vendors, and that those downstream vendors ask the same of theirs, and so on.  Also, if a downstream vendor is R2 certified, this will likely be deemed sufficient evidence by the auditor that that vendor has performed the necessary downstream due diligence through to final disposition.   

     This can be difficult information and documentation to gather, particularly for small recyclers.  Perhaps it is an area that the R2 Technical Advisory Committee can consider as it review ways of clarifying and improving the R2 Standard.

**Note:  The newsletter is not official guidance, rather a tool that R2 Solutions is using to get recyclers and auditors  thinking carefully about the requirements of the R2 Standard.  All official guidance on interpretation of the Standard will come from the Technical Advisory Committee, and documents approved by the TAC such as the Guidance Document which is in development.