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Learning and Improving Through Spot Audits

Six spot audits of R2 certified facilities have been completed since SERI launched the spot audit program earlier this summer. The audits are part of SERI's continuing effort to raise the bar on quality for the electronics recycling industry in general, and R2 certified recyclers in particular. Attention so far has been focused on facilities in the Southeastern part of the United States and will soon expand to other regions.

Spot audits include a facility walk-through by SERI's assessor, interviews with facility employees, and a review of records and documentation required by the R2 Standard. Typically the audits last from two hours to a half day, and have been conducted either unannounced or with short notice given. Because spot audits are not done in conjunction with the certifying body of record, SERI's assessor is able to take a more consultative approach during the audit, offering companies suggestions for improvement.

Some of the facilities that SERI has visited to date have had minor and/or significant concerns identified during the spot audit. Minor concerns are shared directly with the recycler during the audit. Significant concerns, however, are also communicated to the company's certification body. The certifying body is responsible for working with the recycler to ensure concerns are resolved, and depending on the nature of the concerns, suspending or revoking the company's R2 certificate. Information gathered during a spot audit is confidential and only shared with the company's certifying body.

General trends, observations and lessons learned from the spot audit program will be shared by SERI with certification bodies, auditors and recyclers during regularly scheduled conference calls, and in the R2 Update newsletter as a teaching tool and means to improve the overall quality of the R2 certification program.

A Focus on Electronics for America Recycles Day

This year, America Recycles Day, an initiative of Keep America Beautiful, is placing special emphasis on electronics recycling. This is welcome news for SERI's executive director, John Lingelbach. Lingelbach is encouraged by the progress being made in the recycling arena by members of SERI's R2 Leader Program, a coalition of corporations, governmental and non-profit organizations working together to provide sustainable solutions for electronics recycling and reuse. SERI hopes that by calling attention to the successful efforts of R2 Leaders, other companies and communities will be encouraged to follow suit and make a difference in their own spheres of influence.

Just a few of the ways R2 Leaders are improving the electronics recycling landscape:

Keep America Beautiful is an effective leader in changing recycling attitudes and habits with initiatives such as America Recycles Day. "People commonly think of paper, plastic, and aluminum as recyclable items, but electronic devices are generally not top of mind," says Brenda Pulley, senior vice president, recycling, Keep America Beautiful. "The EPA estimates that 70 percent of used electronic devices are stockpiled in homes and small businesses or end up in landfills. It's important to know that every one of these gadgets can be responsibly recycled - and made into new products - which reduces the need to mine for new resources."

XEROX Corporation held its first America Recycles Day event in 2006 for employees, contractors and consultants. More than 57,000 pounds of electronics were collected in just eight hours. Since then, XEROX has expanded the event to include collection of bicycles, clothing and household items. Employees are enthusiastic about the opportunity to get rid of these items, and both the community and environment benefit.

DIRECTV provides their customers with the ability to recycle not only DIRECTV equipment, but also other small electronic devices. Partnering with Avnet (an R2 certified recycler) DIRECTV invites customers to visit their website to print out free shipping labels for eligible electronic devices. More than 16 million pounds of electronics were recovered in 2013, and more than 24 million pounds in 2014 as a result of DIRECTV's e-cycling program.

Arizona Department of Environmental Quality (ADEQ) created an E-Waste Recycling Event Toolkit to simplify the process for communities holding collection events. Included are resources such as a qualified recycler directory, marketing materials, educational resources and best practices for collection events. Since 2009, ADEQ has held over 100 electronics (e-waste) collection events in approximately 50 cities throughout Arizona.

Proper Materials Storage is Fundamental

Proper storage of materials is a fundamental element of the R2 Standard that is addressed in Provision 9. While the material storage requirements of R2:2013 are rooted in basic environmental and worker safety regulations in place in the United States, the general principles and intent behind the regulations apply to all responsible recycling facilities, regardless of where they operate.

Key storage considerations of Provision 9:

Electronics cannot be stored outside and uncovered without appropriate storm water controls, which is consistent with most general storm water regulations. Materials that come in contact with rain or snow run the risk of mixing with storm water runoff and contaminating soil and water. In the United States, most recyclers are required to manage storm water runoff based solely on their SIC code 5093. All recyclers are typically required to submit a No Exposure Certification to their respective state regulatory agency at the very least, even if all materials are stored inside. Best practices worldwide are to keep electronics sheltered from weather conditions, usually indoors, or at minimum, under an overhead shelter. This includes cover for roll-off containers usually containing recovered metals.

All containers and storage areas must be clearly labeled to identify contents. It is best practice to identify the status of the material, such as distinguishing between unprocessed equipment, material for recycling, or equipment for reuse. Best practices also dictate that material should be labeled with an accumulation start date of when material was received or generated from processing.

Storage practices must meet legal requirements. In many instances, legal requirements will coincide with common best practices. For instance, broken CRTs should be stored in structurally sound containers with liners and lids. Intact mercury lamps should be stored in closed boxes or drums to contain breakage during movement or shipping. Reactive batteries such as lead acid, nickel cadmium, and lithium batteries should be taped to prevent the terminals from making contact during storage to prevent risk of fire.

Equipment and materials must be securely stored. Provision 10 of R2:2013, provides more detail on specific security issues, but in general, security begins at the perimeter with locked doors and fencing, with additional layers of security in the warehouse depending on customer requirements and the sensitivity of equipment and media handled. Restricted areas and closed circuit cameras are common security measures in most facilities.

Bi-Monthly Webinars/Conference Calls

R2 Certified Recycler/Refurbisher Webinar

November 18, 12:00pm (Eastern Time)

A bi-monthly discussion of implementation questions and issues common to R2 certified companies. If your company is R2 certified and you are not currently receiving invitations for this bi-monthly event, please contact [email protected].

R2 Auditor Webinar

December 16, 7:00pm (Eastern Time)

A bi-monthly discussion of auditing questions and issues common to certifying body auditors (not internal auditors). If you perform audits for an R2 approved certifying body and are not receiving invitations to this bi-monthly event, please send you name, email address, and name of the certifying body you work for to [email protected].

R2 Training Webinars

Intro to R2

An overview of the R2 Standard requirements,

and the steps and costs

of certification.

Wed. November 11

10:00am-11:15am (CT)

Wed. December 2

10:00am-11:15am (CT)

Wed. December 16

10:00am-11:15am (CT)

NO CHARGE to attend.

Advanced R2 Training

This interactive 5-hour course covers the requirements of the R2 Standard in detail. Auditors, consultants and facility managers are welcome to attend.

Tues. November 10

10:00am-3:00pm (CT)

Tues. December 8

10:00am-11:15am (CT)

Cost: $300

Marketing Workshop

Making the most of

your R2 Certification

Learn strategies for building your business and marketing your R2 Certification from Bob McCarthy who successfully landed many Fortune 500 accounts during his tenure as VP of Business Development at a large electronics remarketing and recycling firm. Bob has more than 15 years of industry experience.

Thur. October 29

10:00am-11:00am (CT)

FREE of charge for:

R2 certified companies and companies that are pursuing certification and have paid the R2 license fee.

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