May 2012  

R2 Update
The latest information on the Responsible Recycling (R2) Standard 
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SGS 


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
Six accredited Certification Bodies now available for R2 including new presence in South and Central America
TAC meets in Colorado
What you need to know about Responsible Recycling (R2) Certification
Conformity review: battery handling part 1 -- in-house requirements

   

Six accredited Certification Bodies now available for R2 including new presence in South and Central America

  

 

Recently TÜV SÜD America, a global, independent third-party certification, inspection and testing organization, became the sixth accredited Certification Body for R2.  TÜV SÜD America was accredited by ANAB last week.  Of particular note, TÜV SÜD America has a growing presence in Central and South America, offering responsible electronics refurbishers and recyclers in the region the opportunity to become certified to the global R2 Standard. This in turn will help to increase environmentally-responsible recycling options for organizations in the Central and South America region.

 

R2 Solutions has long believed that to create a truly environmentally-responsible electronics recycling industry, responsible recyclers need to be identified in all regions of the world and certified to a strong global standard.  Today over 200 facilities are R2 certified and the global presence of these facilities continues to grow.

 

TÜV SÜD America has provided third-party certification services since 1987, and works with thousands of clients annually.  The company chose to be accredited to certify to R2 for a number of reasons including the global reach, stringent requirements and consistency of the R2 Standard.

 

"In order to continue to provide our clients the services they seek, the decision to obtain R2 accreditation was one that presented itself in a most prominent way", said Craig S. Casillas, Vice President of TÜV SÜD America's Management Services Division. "The addition of R2 strengthens our portfolio of environmental and sustainability services and, when presented alongside our other service offerings, allows our customers a clear path to meeting their internal objectives as well as market expectations and customer requirements."

 

R2 Solutions will continue to work with ANAB and other accreditation bodies to increase the number of third-party Certification Bodies that can work with responsible recyclers to achieve R2 certification as the need for responsible recycling of used electronics continues to grow globally.

 

TAC meets in Colorado

 

The R2 Technical Advisory Committee (TAC) is meeting in Keystone, Colorado on May 30th and 31st. The TAC is discussing potential revisions to the R2 Standard. The expectation is to have a revised version of the Standard, to be called R2:2013, completed by the end of 2012. This revised version will then be implemented over the following eighteen months.

 

At this point, the TAC is focusing primarily on potential revisions to Provisions 1, 3, 5, and 6. For Provision 1, the main issue under discussion is whether to require a management system that is certified to an accredited management-system standard such as ISO 14000 or RIOS. For Provision 3, issues include how best to assure compliance with import/export laws and how to address legal compliance more generally. For Provision 5, a key issue is what downstream due diligence to require when the downstream vendor is R2 certified. For Provision 6, the TAC is considering how to recognize quality and promote transparency in the refurbishment and resale of used electronics equipment.

 

When the TAC has completed a draft revision early in the 4th quarter, the draft will be put out for public comment. The TAC will then review the comments and make any revisions to the draft before finalizing it and sending it to the R2 Solutions Board of Directors for final adoption.

 

What you need to know about Responsible Recycling (R2) Certification  

  

This article is written by John Mequio from the perspective of NSF-ISR and their clients and auditors. NSF-ISR, which recently merged with AQA International, is a subsidiary of NSF International Strategic Registrations, Ltd.  It is one of the largest North American-based accredited registrars in the world, with a mission of protecting and improving the environment and human health. John is the Global EH&S Business Unit Manager for NSF-ISR. He can be reached at jmequio@nsf.org or 734-913-5707 or visit www.nsf.org.

 

Companies across the globe are realizing the benefits of implementing quality, environmental and safety management systems. Managements systems provide a framework for companies to manage, prioritize, control, review, correct and continually improve their operations. Responsible Recycling (R2) is a standard that includes the requirements for an environmental, health and safety (EH&S) management system specifically developed for the electronic waste recycling industry.

 

Consumers and corporations are increasingly concerned about protecting the environment and the impacts of inadequate controls on electronic waste disposal and recycling. Responsible disposal and recycling practices are just good business. Certification to the R2 standard validates to consumers, government agencies and customers that your company and downstream vendors are operating in an environmentally reasonable and safe manner in compliance with applicable domestic and international laws. Certification improves your competitive advantage and can give you access to new customers. For example, the United States government (nation's largest single consumer of electronics) has announced that it will only contract with certified electronic recyclers. Also, there are state run programs that require recyclers to be certified by a third-party, including Vermont. Additionally, Dell, Sprint and Sony have made commitments to only use certified recyclers.

 

EH&S management systems require companies to set goals, continually improve and go beyond compliance with domestic and international laws. Organizations that have implemented management systems prioritize their EH&S issues and operate using more proactive and preventive approaches rather than reactive. Companies that ignore or don't excel in EH&S management are more likely to experience inefficiencies, recurring problems, government violations, injuries, and accidents, all of which can hurt a company's reputation and bottom line.

 

The following are some key lessons learned by organizations that have existing certified R2 management systems:

 

  • A company must truly embrace R2 to get the benefits. Use R2 as a tool to improve your business and meet customer expectations.
  • Management support and employee buy-in is critical. Your management system must be driven from the top down and supported from the bottom up. Implemented correctly, it will improve awareness of EH&S issues at all levels.
  • Don't be afraid of nonconformances identified during an audit. Addressing audit findings are how you improve.
  • EH&S training must be effective and tracked because employees will be audited.
  • Do a thorough root cause analysis of audit findings and EH&S incidents. Avoid short-term and quick fixes.
  • Implement EH&S goals that improve regulatory compliance, save money and avoid costs, and help you meet customer expectations.
  • Develop practical and user friendly procedures that improve compliance to domestic and international laws and increase efficiencies and consistency.
  • Ensure that your internal audits/inspections are effective and that auditors understand company priorities.
  • Share best practices between multiple facilities.
  • The R2 standard is relatively new. The benefits will increase as your system and the R2 standard matures

 

After a company has implemented R2, the next step is third-party certification by an accredited registrar. A registrar independently verifies your management system to ensure it conforms to the requirements of R2. The initial audit and periodic subsequent audits increases the credibility of your management system. Also, certification audits allow an outside set of eyes and EH&S expert to review your management system and help you make improvements. Third party independent audits supplement your own internal inspections and audits, and verify if your EH&S management system processes and procedures are effective.

 

 

Conformity review: battery handling part 1 -- in-house requirements   

 

Conformity review is a monthly column highlighting important operational information concerning the R2 Standard.  For the last number of months it has been written by Corey Dehmey of Momentum, Inc.  Corey can be reached at CDehmey@m-inc.com.    

 

R2 Solutions last reported on batteries in February 2011. The issue of battery management still remains a common pitfall for many electronics recyclers not R2-certified.   Batteries are often found co-mingled in insufficient storage containers and improperly packaged for shipment. However, with R2-certified companies the requirements of certification combined with the oversight of independent auditors are improving battery handling by the entire electronics recycling industry.

 

To begin, let's evaluate the scope. Batteries are referenced as Focus Materials (FMs) throughout the R2 Standard. R2 does not distinguish between types of batteries. All batteries are FMs, including alkaline batteries. At the highest level in the organization, batteries must follow the hierarchy of reuse, recover in planning operational flows. However, batteries cannot be directed to energy recovery, incineration, or landfill in accordance with Provision 5(d) for Focus Materials unless it is an exceptional situation, such as a spill cleanup.

 

Planning for battery management should be found in the EH&S Management System (EHSMS). Evidence of battery planning will be referenced in the environmental, health and safety hazard and impact assessments. It will be referenced specifically in emergency plans in accordance with Provision 4(h) including plans for spill response, fire, and exceptional releases. The EHSMS will have documented procedures for handling of batteries, as well as monitoring activities to ensure conformance to the plans and compliance with all legal requirements.

 

The legal requirements of battery handling will be addressed in the legal compliance plan required under Provision 3. This plan will address rules and regulations at all levels of government. In the United States, this should include, for example, CERCLE, SREA, RCRA, and in California Title 22 Chapter 23. It will also include Department of Transportation regulations under 49 CFR 171-180 when batteries are transported.

 

Transportation is of particular concern. Often recyclers do not identify this as a legal requirement.   In reality, if a business is offering batteries for someone else to transport, the recycler usually must document training of the hazardous materials regulations for its shipping employees.   Depending on the classification of the battery material, it may require hazardous endorsements. Futhermore, R2 Provision 12 as well as legal requirements require only qualified transporters with proven safety records.

 

Another common mistake of recyclers is the mishandling of batteries within the recyclers' facilities. Specific attention to labeling, accumulation times, and packaging are important in ensuring legal compliance. In addition, it is important in mitigating the environmental risks of spills and fires. Documented procedures and training in these areas will ensure appropriate responses to these exceptional situations. Inappropriate responses tend to compound the issues. Finally, the safety of employees is an important benefit of proper battery handling.   This may be as simple as providing personal protective equipment (PPE) such as a face shields and gloves for protection from the wet acid in some batteries.

 

In the next R2 Update we will continue the discussion of battery handling and look at the impacts of downstream processing and due diligence.

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!