January 2012  

R2 Update
The latest information on the Responsible Recycling (R2) Standard 
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Welcome to the R2 Update!  This newsletter contains relevant industry information and news pertaining to R2 Solutions, and more importantly the R2 Standard, the leading certification program for the electronics recycling industry.
In This Issue
The TAC tackles management systems and exports
H.R. 2284 - "The Responsible Electronics Recycling Act"
Certified company spotlight: Taking R2 Certification International
Conformity Review: LCD Panels

 

 

The TAC tackles management systems and exports

 

The R2 Technical Advisory Committee (TAC) has a workgroup that is developing draft revisions to the R2 Standard. This past summer R2 Solutions collected input from the public regarding possible revisions. The workgroup is considering these as well as possible revisions that it has identified.

 

The TAC has developed a set of criteria with which to evaluate the current requirements of the Standard. This set of criteria includes:

  • Does the provision function as intended?
  • Do we want to raise the bar in this area?
  • Is the language prescriptive enough, i.e. detailed enough in what it is asking, and does it facilitate robust verification and auditing?
  • Does the language allow for innovation?
  • Does the language support legal and safe international commerce?
  • Is the language globally relevant - does it resonate with electronic recyclers everywhere in the world?
  • Does the language make the consumer feel safer getting/giving to an R2 certified facility?
  • Is the language clear, grammatically correct, etc.?

 

One of the major areas of the Standard the workgroup is working on is Provision 1 on Environmental, Health, and Safety Management Systems (EHSMSs). The workgroup is considering whether to require that a recycler have a management system that is certified to ISO 14000 and OHSAS 18000, or to RIOS. Some commenters have raised issues regarding the auditing and rigor of management systems that are not certified to these other standards. So far, the workgroup is leaning against requiring separate certification of the EHSMS due to the associated costs. At the same time, though, it is considering ways of strengthening the existing language of Provision 1 to address the issues of auditing and rigor.

 

Another major area of the Standard the workgroup is working on is Provision 3's language covering exports. The workgroup is considering alternative, clearer language for the requirement that all international shipments containing Focus Materials be legal under the laws of both the exporting and importing countries. It also is considering the documentation requirements for these transactions. Its objective here is not to change the requirements in any big way but to make clearer the intent of R2 regarding exports.

 

One of key goals of the workgroup is to highlight the international applicability of the R2 Standard. Addressing the EHSMS and export requirements are two steps towards achieving this goal.

 

 
 

H.R. 2284 - "The Responsible Electronics Recycling Act"

 

2012 has started with a flurry of activity and buzz around H.R. 2284, the "Responsible Electronics Recycling Act". This bill is primarily intended "to prohibit the export from the United States of certain electronic waste." As the housing entity for an industry standard, R2 Solutions is not taking a position on what the law should be in this (or any other) substantive area.

 

The R2 Standard requires compliance with the laws in effect at the time of a transaction. It does not reference a specific piece of legal drafting such as the Basel Convention or the Basel Ban Amendment. Rather, it states that exports of Focus Materials must be legal under the law of importing countries in effect at the time of the shipment. Should H.R. 2284 or any other applicable import/export legislation be enacted, the R2 Standard will require conformance with it as well.

 

Although H.R. 2284 seeks to prohibit the export of electronic waste from the United States, history has demonstrated that the bad actors will continue to export. How is this addressed in the R2 program? R2 requires R2-certified recyclers to be independently audited by an ANAB-accredited certification body each year. It also establishes a network of downstream due diligence to ensure that each vendor in the supply chain is held accountable to the applicable requirements of the Standard. R2 Solutions is working to implement a quality assurance program which will provide further oversight of R2-certified recyclers. The R2 Technical Advisory Committee is currently revising guidance documents and the standard itself to strengthen and clarify R2's requirements. Regardless of whether H.R. 2284 is passed into law, the R2 Standard promotes responsible recycling practices; practices that are applicable to R2-certified recyclers regardless of their location in the world. 

 

 

 

 

Certified company spotlight: Taking R2 Certification International

 

 

From time to time, the R2 Update will be featuring an R2 Certified company. This article was provided by Technology Conservation Group (TCG). For more information about TCG, please contact Steve Craig at (352) 527-2534 x 325 or steve.craig@tcgrecycling.com.

 

Technology Conservation Group has the proverbial "started in a garage" history.  Hamilton Rice, TCG's President & CEO, having cut his professional teeth in the integrated circuits distribution market, decided to leverage what he had learned and open his own business in 1997.  His original start-up was an I.C. distribution company handling excess and obsolete inventory from the OEM components manufacturing industry.  But he quickly realized he was missing a huge opportunity in the electronics recycling market.

Fast-forward to 2012.  TCG has progressed from a one-bedroom house into a global company with seven processing facilities in four countries.  TCG has not only expanded its footprint, but has proactively added to its services, tailoring programs specific to each customer's requirements.  In an environment where mixed materials, volume throughput and standardized reporting is the norm, TCG bucked the trend, carving a niche in the business of electronics recycling. 

Technology Conservation Group is now a multi-faceted company specializing in asset disposition, reverse logistics, consignment and buyback program management, finished goods and component remarketing as well as precious metals refining.  TCG is extremely sensitive to data security and chain-of-custody integrity - from sealed shipments and GPS tracking to wiping hard drives to NIST 800:88 standards and physical shredding - the risk management programs they have developed meet or exceed the standards required by the various federal information protection acts.  

These achievements, among others, were accomplished through the strength and vision of its leadership.  The addition of Bill Stockburger, V.P. Operations, in 2000 provided the processing organization needed to accommodate the increase in business.  Don Andes, V.P. Business Development, joined TCG in 2002 to grow the business development team in addition to managing marketing and logistics.  They each bring unique strengths to the table and work together seamlessly to move the company forward.

As a global company with a long-standing ISO 14001:2004 certification already in place, TCG was well aware of the increasing number of global and country-based directives being issued to make certain recyclers were using the highest standards possible.  Management knew that the next step, R2/RIOS™ certification, was a worthy and necessary investment and an assessment of the documented policies and procedures already in place helped build a strategy for implementing R2 and RIOS. 

TCG was aggressive in its pursuit of its R2 certifications.  Not only did management want to have TCG's three US facilities certified, they amped up their game by deciding to be the first electronics recycler with multiple R2-certified international locations.  "Was it a challenge? Absolutely." said Hamilton Rice "But we knew we had a top-notch team in-house that could get it done, and we were right.  We are a global company so it made perfect sense for us to include our facilities in Mexico and the United Kingdom." 

Steve Craig, Corporate Compliance Director states "R2 creates a standard set of practices that if fully implemented gives Electronics Recyclers a competitive edge and legitimacy within an industry that is in dire need of such".  He also goes on to say that "our certifications are proof that the R2 Standard can support international and domestic regulatory requirements while providing increased transparency for our customers, regulators and public that's well defined and easily understood."  

 

Conformity review: LCD panels    

 

Conformity review is a monthly column highlighting important operational information concerning the R2 Standard   

 

As consumers continue to purchase televisions and monitors with liquid crystal displays (LCDs) instead of the old cathode ray tubes (CRTs), the proper handling of these electronics grows increasingly important. LCD TV's and LCD Monitors contain mercury in their cold compact fluorescent lamps (CCFLs). The CCFLs are often fragile and the equipment containing them can be difficult to disassemble.

 

R2-certified recyclers employ a variety of strategies to manage these devices, ranging from partial disassembly of the housing containing the bulbs to full removal of the bulbs, and then shipment to a downstream mercury retorter. Regardless of the method, the R2 Standard contains several provisions applicable to the handling of mercury lamps, since they are identified as R2 Focus Materials in Provision 5 of the Standard.

 

Provision 5 talks explicitly about mercury. Provision 5(a) requires recyclers to plan the management of equipment containing Focus Materials, including mercury containing devices, in the Focus Material Management Plan. According to Provision 5(b)(1), mercury lamps do not need to be removed from equipment if it is not safe and economical to do so and the equipment is sent to a properly licensed facility, i.e.; a RCRA Part B permitted mercury retorter. This is important as it may be difficult to safely remove small, thin mercury bulbs in LCD panels without breakage. Additionally 5(c)(1) requires mercury lamps that have been removed be sent for mercury retorting.

 

Provisions 5(e) and 5(f) require downstream due diligence of the mercury retorter. The weight of mercury lamps in LCD's is minimal. Consequently, for most recyclers the per-unit cost of the due diligence they perform on their mercury retorter is high relative to other Focus Materials. In addition, there are just a few mercury retorters in the US so each is fielding due diligence requests from numerous small quantity customers. To address these issues, one strategy might be to use a 3rd party auditor to conduct one audit for review and use by many recyclers.

 

In addition to Provision 5, mercury lamps from LCD TV's and monitors must be properly stored under Provision 9(a)(1). Planning for exceptional releases or spills under Provision 4(h) must include planning for the breakage of mercury lamps. Depending upon the recycler's practices in removing or processing CCFLs, requirements under Provision 4 may also need to be met in protecting the health and safety of workers from potential mercury exposure. Finally, one of the most important considerations in handling CCFLs is the legal compliance with hazardous and/or universal waste regulations. Full legal compliance is required under Provision 3(a)(1). 
We want to hear from you!  Please send along any R2 related news or information that you think would be important to share with the electronics recycling community. 

Thank you!