July 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
New President for R2 Solutions Sought
R2 Solutions Offering Training Courses at E-Scrap
Certified Company Spotlight: HOBI International and Cell Phone Reuse
Conformity Review: Battery Handling Part 3 -- Pollution Liability Insurance

   

New President for R2 Solutions Sought

  

The R2 Solutions Board of Directors is conducting a search for a new President of R2 Solutions. The Board is seeking a new leader for R2 Solutions who has the experience and vision to take the organization to the next level - with a focus on solidifying the organization's financial base and expanding awareness about R2 and certification to the Standard both in the US and, particularly, internationally. Information about the new position can be found on the R2 Solutions website.

 

John Lingelbach, who has been serving as Executive Director of R2 Solutions since it was formed, is taking a leave of absence from the position in order to focus on health matters. He will be working a few hours a week for the next few months. Corey Dehmey, who has been working with John for the past 9 months, will take on a larger role and the title of Assistant to the Executive Director.  To further solidify the management of the organization, Lynn Rubinstein has agreed to serve as Chair of the R2 Solutions Board of Directors.

 

 

R2 Solutions Offering Training Courses at E-Scrap

 

 

R2 Solutions, with the help of ISRI, will provide 2 mini-courses on Tuesday, September 18, 2012 at the E-Scrap conference in Dallas, TX.  These courses are part of the workshops provided before the official start of the E-Scrap conference. 

 

The first course will offer a moderate level of detail on all 13 Provisions of R2:2008, as well as a preview of changes under consideration for R2:2013.  This course is targeted at newcomers to the R2 Standard. 

 

The second course will feature an in-depth look at Due Diligence under Provision 5 and Refurbishment under Provision 6 of the R2 Standard.  This course is designed to provide attendees with detailed information on how to design and execute their due diligence program.  It will also look at the key operational characteristics of R2 Refurbishers.

 

Sponsorships are available for these courses.  Please contact Corey Dehmey at cdehmey@r2solutions.org, or go to http://www.r2solutions.org/about/r2-education-series, for further information. 

 

 

Certified Company Spotlight: HOBI International and Cell Phone Reuse 

 

From time to time, the R2 Update will be featuring an R2 Certified company. This article was provided by HOBI International, Inc.. For more information about HOBI, visit www.HOBI.com.

 

 

HOBI International, Inc., a leading asset management and electronics recycling company, provides IT and mobile asset management services to Fortune 1000 clients. HOBI focuses on corporate IT, data and telecommunications infrastructure, providing resale and re-marketing, data erasure and data destruction, recycling, environmental and compliance reporting, de-installation services, and logistics management.

 

HOBI is somewhat unique in the industry because the company combines traditional IT asset management and demanufacturing with mobile device asset management, repair, refurbishment, and demanufacturing. As an R2 and ISO14001 certified firm, HOBI leads the electronics recycling industry in best practices for recycling and commodities recovery. Developed through a multi-stakeholder process over a three year period, the R2 standard sets a benchmark for performance by an electronics recycling firm with our IT recycling programs.

 

HOBI's cell phone operation presented some unique challenges for the R2 certification process. Unlike hard drives which are typically erased using a small number of software solutions, the erasure of the hundreds of different makes and models of cellular phones result in hundreds of unique solutions designed around the specific operating system and carrier implementation. As a result, the process audit required a thorough examination of these varied solutions and their implementation at HOBI.

 

Most obsolete cell phones have value, either as a refurbished phone for someone here or in another country, or as parts for a repair center. But old phones also carry risk in the form of personal or corporate data remaining on the phone after it is no longer in use. Clients want a phone-processing partner who can eliminate the risk and maximize the value of their inventory with best-in-class cell phone recycling. HOBI has been doing exactly this for a diverse client base, and as a result, more than four million phones flow through its facility every year.

 

HOBI works closely with four major cellular OEM suppliers to support their electronic asset recycling and environmental and legislative compliance needs. The company provides critical certified destruction services for prototype and engineering sample model phones, engineering or manufacturing flawed products, or obsolete products the client does not want to enter the secondary market.

 

IT asset management is another critical function for enterprise businesses. Proper preparation for the disposition of corporate electronic equipment includes the planning of the physical removal from the premises, data erasure/destruction, and a disposition plan that meets the overall objectives of the corporation. Companies must also comply with local, state, and federal regulations regarding the disposition of electronic assets, and partnering with an R2-certified company ensures responsible asset management.

 

To achieve these objectives for its clients, HOBI developed a comprehensive IT asset management system that maximizes the value of corporate IT assets, ensures complete data destruction, and provides transparent reporting for corporate and legal requirements.

 

HOBI has become the processor of choice for cell phone recycling. The company's processes, developed over the last eight years, ensure both the maximization of the phone's value and the elimination of any risk associated with data on the phone.

 

 

Conformity Review: Battery Handling Part 3 -- Pollution Liability Insurance   

 

Conformity review is a monthly column highlighting important operational information concerning the R2 Standard.  For further information regarding the matters discussed in this article, please contact Corey Dehmey at cdehmey@r2solutions.org.     

 

Most recyclers have been promised indemnification by a downstream processor at some point in their business transactions. In most cases though, indemnification is limited and requires due diligence to be effective. In the last R2 Update we discussed battery handling and specifically the selection of downstream vendors.

 

From a legal liability perspective we explored the United States laws on generator responsibility, including the Comprehensive Environmental Response, Compensation, and Liability Act, CERCLA (aka "Superfund") and the Superfund Recycling Equity Act (SREA). In this R2 Update, we will look at how pollution liability insurance fits into this picture.

 

R2 Provision 11 requires "adequate Comprehensive or Commercial General Liability Insurance including coverage for bodily injury, property damage, pollutant releases, accidents and other emergencies".   General liability insurance is fairly standard in language and coverage. It is "admitted" in most states and subject to state regulations. However, it does not typically include pollution liability. Pollution liability insurance is usually a separate policy in addition to any comprehensive or commercial general liability policy.

 

The pollution liability tool is an effective means of protecting both recycler and customer interests.   If properly structured and executed, risks to the processor and the processor's customers will be covered. In the example of battery handling, recyclers should be looking to all downstream vendors handling their batteries to have effective pollution liability coverage. The recycler, collectors, and processors should each have a pollution liability policy. Each upstream customer (1-level) should be named as "additional insured" on the downstream vendor's policy. This chain of pollution liability policies creates protection in the entire recycling chain.

 

Other parts of the pollution liability policies should be reviewed when selecting a downstream vendor. Look for Non-Owned Disposal Site liability coverage (NODS), additional insured companies, endorsement of coverage during transportation, and blanket coverage of disposal outlets. Most policies will require any covered sites to be properly licensed, not bankrupt, and not known to currently be polluted. These requirements of disposal sites align closely with the due diligence requirements of SREA for exemption from "Superfund" liability in the United States.

 

With the proper combination of internal training, legal compliance, and emergency preparedness; combined with downstream due diligence and pollution liability insurance, an effective and safe recycling chain can be established. Furthermore, closure plans and closure financing as required by the R2 standard will add protection to customers and the environment. Reclaiming and reusing heavy metals in batteries is an important part of environmental stewardship. Indemnification is only effective with the proper elements in place and verified before shipment. The R2 Standard calls for each of the critical elements for safe battery handling.

 

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!