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R2 Presentation

  1. 1. Responsible Recycling (R2): A Different Approach to a Different Waste Stream Beth Pelland Executive Committee Perry Johnson Registrars, Inc. PERRY JOHNSON REGISTRARS, INC. 1
  2. 2. Beth Pelland Senior Member of the Executive Committee and Lead Auditor • Conducting ISO 9001, ISO 14001, OHSAS 18001, ISO/TS 16949, and R2 audits. • Presenting numerous seminars and workshops on quality management systems, organizational management, and leadership and team building. PERRY JOHNSON REGISTRARS, INC. 2
  3. 3. PERRY JOHNSON REGISTRARS, INC. PJR is one of the largest certification bodies in the world. International presence: – HQ - Southfield, MI – Numerous offices throughout the United States – Monterrey and Mexico City, Mexico – Milan and Caserta, Italy – 7 offices in Japan, including Tokyo – Bangkok, Thailand PERRY JOHNSON REGISTRARS, INC. 3
  4. 4. PERRY JOHNSON REGISTRARS, INC. Accredited by ANAB (United States), EMA (Mexico), INMETRO (Brazil), UKAS (United Kingdom), RvA (Netherlands), SINCERT (Italy) and JAB (Japan) Accredited to grant certification for: – ISO 9001:2008 – ISO 14001:2004, Responsible Care, RCMS – OHSAS 18001:2007 (health safety) – ISO/TS 16949:2009 (automotive) – AS9100, AS9110, AS9120 – ISO 13485:2003 (medical devices) – ISO 22000:2005 (food safety) – ISO 27001:2005 (information security) PERRY JOHNSON REGISTRARS, INC. 4
  5. 5. PERRY JOHNSON REGISTRARS, INC. Responsible Recycling (R2) PJR is one of two ANAB Accredited certification bodies worldwide that is able to offer accredited certification to R2. PERRY JOHNSON REGISTRARS, INC. 5
  6. 6. PERRY JOHNSON REGISTRARS, INC. Accreditations are pending for: – BS 25999-2 Business Continuity Management Systems – RIOS - Recycling Industry Operating Standards PERRY JOHNSON REGISTRARS, INC. 6
  7. 7. Topics Growth and management of Essential R2 Concepts used electronics. – Understanding R2 Practices Development of the R2 – R2 Checklist practices – Integration/comparison to Export Rules/Regulations ISO standards – Basel Convention R2 Certification – OECD – Governing Rules Domestic – Stage 1 Rules/Regulations – Stage 2 – State Laws – Steps to Certification – EPA Rules Expectations for R2 Q&A PERRY JOHNSON REGISTRARS, INC. 7
  8. 8. Growth of Electronic Use Last year, Americans purchased an estimated 500 million new consumer electronic products. According to the Consumer Electronics Association (CEA), the average American household owns 15 separate electronic products. In 2010, the Federal Government is expected to spend 75 billion for IT goods and services. PERRY JOHNSON REGISTRARS, INC. 8
  9. 9. U.S. Management of Used and End-of-Life Electronics Over the last decade, consumers doubled the amount of electronics they discard However, consumer electronics still only comprise about 1.2% of the MSW stream EPA’s Electronics Waste Management in the US report, in 2007 tells us that: – 82% (1.8 million tons) of TVs, cell phones, and computer products were disposed, primarily in landfills. – 18% of TVs and computers were collected for recycling – 10% of cell phones were collected for PERRY JOHNSON recycling REGISTRARS, INC. 9
  10. 10. How Electronics Differ from other Waste Streams Electronics are complex devices Consist of a wide variety of materials, many of which would not be classified as hazardous under EPA testing procedures Contains hundreds of elements, compounds, and alloys – Include steel, plastic, glass, ceramics, copper, aluminum, lead, nickel, zinc, lithium, carbon, cadmium, mercury, beryllium, gold, silver, palladium, flame retardants, etc. – Virtually all materials are used for important functional or safety reasons – Some of these materials pose risks if PERRY JOHNSON improperly disposed of or recycled. REGISTRARS, INC. 10
  11. 11. Environmental Benefits of Reuse & Recycling Reuse: extends the life of the product; increasing use from the In 2007, the US recycled energy & material inputs 414,000 tons of electronics resulting in… Recycling: recovers materials – Greenhouse Gas (GHG) metals, glass, plastics – reducing Reductions: 974,000 the extraction and processing of MTCO2E, equivalent to the virgin resources annual emissions from more than 178,000 passenger – In a gold mine, one ton of ore vehicles. contains about only five to 10 Energy Savings: 18 trillion grams of gold, one ton of cell BTUs, equivalent to the energy phones – equivalent to about content of 140 million gallons of 10,000 cell phones – contains gasoline. 300 to 400 grams of gold". PERRY JOHNSON REGISTRARS, INC. 11
  12. 12. Environmental Issues? Increasing electronics discards raise numerous issues – some legitimate, some not – Disposal Danger? • Some are concerned with toxics from electronics leaching from landfills, we have no evidence that land-filling electronics in the US causes groundwater contamination • But there is some improper disposal in some developing countries – open burning – Recycling Risks? • EPA does not regulate how e-recyclers recycle the material; some practices are sound, some are not • Primitive recycling processes in developing countries have been shown to cause public health and environmental impacts – Lost Resources? • Electronics discarded into landfills or incinerators represent loss of important resources – precious metal, plastics, usable PERRY JOHNSON parts, etc. REGISTRARS, INC. 12
  13. 13. Electronic Reuse and Recycling: Not Just an Environmental Issue Unlike more traditional waste streams, electronics can provide social and economic benefits – Social: Bridges the “digital divide”; reuse markets overseas improve access to information technology – Economic: Reuse and recycling provides jobs both domestically and overseas • Strong foreign demand for raw materials • From a production view, it makes sense that these materials go to overseas markets PERRY JOHNSON REGISTRARS, INC. 13
  14. 14. Increasing Safe Reuse and Recycling To recognize these benefits and promote greater electronics product stewardship, EPA is working to: Increase reuse and recycling of used electronics; and Ensure that management of used electronics is safe and environmentally sound PERRY JOHNSON REGISTRARS, INC. 14
  15. 15. Responsible Recycling Practices At a multi-stakeholder electronics summit in March 2005, participants asked EPA to lead an effort to develop a set of sound recycling practices and a system for certifying electronics recyclers who met them EPA convened a multi-stakeholder group to develop a set of practices – Stakeholders included: States (MN, WA, MD) electronic manufacturers (Dell, HP), Recyclers/Refurbishers, trade associations (ISRI, Information Technology Institute (ITI), Microsoft Authorized Refurbishers (MARs) and NGO’s (Basel Action Network, Electronics Take-back Coalition) R2 document process: – Drafted by neutral facilitator (EPA funded) in a consensus-driven process – Each version was discussed by working group and revised by facilitator – Reviewed by 4 experienced auditors – Field tested at 6 recyclers (included a range of sizes and processes) – EPA’s role in helping to get documentation from foreign countries was tested (China, Hong Kong, India) – R2 represents efforts of multiple stakeholders over a 3-year process; NGOs participated until the end, but left because of several key concerns. They have now developed their own approach PERRY JOHNSON REGISTRARS, INC. 15
  16. 16. R2 Practices Posted on EPA’s website at: www.epa.gov/epawaste/conserve/materials/ecycli ng/r2practices.htm It is also found on the facilitators website at: www.decideagree.com/TheR2Practices.html – Includes the auditors check list Developers are discussing how best to keep the practices current and relevant – Permanent home to be chosen On July 27, 2009 ANAB announced the availability of the accreditation rule for R2 – ANAB Rule #34 EPA is encouraging all refurbishers and recyclers to be certified to R2 – Third-party Accredited Certification based on ISO 17021:2006 – Currently, there are 2 Accredited Registrars PERRY JOHNSON REGISTRARS, INC. 16
  17. 17. Scope of R2 Practices Sets a high bar for environmental and worker protection Establishes environmental, worker safety, and public health practices Includes 13 general principles, and specific practices for recyclers to follow The practices largely go beyond what is required under regulation – recyclers are not required to be certified to R2 Some States have, or are, developing standards in their electronics regulations based on R2, e.g., Washington, Oregon As R2 gains footing, an increasing amount of used electronics will be managed by recyclers that adhere to sound practices – where ever the material is Covers electronics equipment including: computers, peripherals, cell phones, televisions, gaming systems… Materials getting specific “focus” are equipment and components containing: – Cathode ray tubes and glass – Circuit boards – Batteries – Items containing mercury/PCBs – While not a “focus” material, toner and toner cartridges have special on-site requirements identified PERRY JOHNSON REGISTRARS, INC. 17
  18. 18. Features of R2 Approach Signifies an upgrade of existing practices – Due diligence requirements, documentation of legality from countries of import – Proper on-site practices are identified – Requires clearing personal data from memory Allows export of materials if shown to be legal and if goes to sound recyclers Through field testing, R2 was found to be a practical approach that can be integrated into existing ISO systems. Smaller recyclers, refurbishers able to meet R2 if they have sound practices – Requires EMS and safety, but does not specify full ISO requirements R2 precludes landfill or incineration of focus materials – But allows for landfill and incineration in extraordinary circumstances R2 represents a sound and practical set of practices that if used will reduce issues surrounding electronic recycling significantly PERRY JOHNSON REGISTRARS, INC. 18
  19. 19. Details on Exports R2 requires exports of focus materials to be legal and responsible, by having: Export Markets Recycler’s responsibility extends to conducting due diligence on “focus materials” to Reuse allows usable international markets; and electronics to be used in Recycler must show documentation that export developing countries of any focus material to any non-OECD country is legal e-Scrap exported to countries can be used in – Law or court ruling; manufacturing new – Letter from the competent authority; or equipment – Request documentation from EPA • EPA website has information of who to US has no smelters or contact with what information glass furnaces to refine • Concept of Prior Informed Consent copper/precious metals requires documentation prior to from circuit boards or shipment produce new CRT glass Future: EPA website with information on PERRY JOHNSON exports REGISTRARS, INC. 19
  20. 20. International Rules: OECD Countries Organization for Economic Cooperation and Development 30 OECD Countries – Mostly Developed – North America, West & North Europe, Australia, Japan, S. Korea & Mexico Well-established system for hazardous waste recovery – Covers recovery (recycling) only and facilitates trade – Notice and consent system, but more stream lined then Basel – Allows for tacit consent and pre-approved facilities – Some differences in hazardous waste list from Basel – more risk based • Basel looks at inherent toxicity – EPA rules consider risk To date, only CRTs have moved as hazardous waste under OECD controls — SLABs will be included in 2010 www.epa.gov/epawaste/hazard/international/oecd-slab-rule.htm Requires notification and consent for export of SLABs—CFR 40 part 262, subpart G and H PERRY JOHNSON REGISTRARS, INC. 20
  21. 21. For a list, go to: http://www.oecd.org PERRY JOHNSON REGISTRARS, INC. 21
  22. 22. International Rules: Basel Convention U.S. is not a Party to the convention; however, over 170 countries are – US signed the Convention in 1990; Senate provided its advice and consent to ratify in 1992 – EPA has not been given the necessary statutory authority to implement the Convention, enabling us to ratify – Every U.S. Administration has been in favor of ratification Basel established a control system on the import and export of hazardous wastes to prevent dumping of hazardous waste in developing countries – Requires written notification and consent of countries of export, import and transit – EPA assistance in getting documents. – Waste list is based on presence of toxics, not risk – U.S. perspective is based on risk – Basel hazardous waste is treated the same if going for recycling or disposal – U.S. has streamlined rules to encourage recycling US can not recycle or dispose of hazardous waste in non-OECD countries without a bilateral agreement – U.S. does not have such agreements with non-OECD countries; – Countries can not legally accept hazardous waste for the purposes of recycling or disposal from us • There are no Basel enforcement agencies List of Basel Competent Authorities: www.basel.int; on left side click “country contacts” US Competent Authority: For R2 Patti Whiting – whiting.patti@epa.gov PERRY JOHNSON REGISTRARS, INC. 22
  23. 23. Hazardous Waste Definition: Basel versus U.S. Countries interpret Basel Waste lists within their own domestic law, hence waste definitions may vary between countries. – Knowledge of the rules of importing and transit countries is important Basel applicability is sometimes unclear for electronics – Shipments for repair/refurbishment is under debate Basel definition of “hazardous waste” differs from U.S. rules especially with regards to non-traditional waste streams – U.S. conditionally exempts hazardous waste from regulation or exclude a material from being a waste to encourage recycling – Basel treats material going to recycling and disposal as the same – Most electronics waste in U.S. is either non-hazardous or non-waste Basel convention supports the concept that hazardous waste should be managed in an environmentally sound manner (ESM) and that transboundary shipments should be reduced - treat waste where generated! PERRY JOHNSON REGISTRARS, INC. 23
  24. 24. BAN & the BAN Amendments to the Basel Convention BAN (Basel Action Network): is an independent charitable organization with NO direct ties to the Basel Convention. – Promotes ratification of the Basel Convention – Promotes ratification of the BAN Amendment to the Basel Convention – Promotes e-stewards as the ONLY way to manage e-waste – Charges a licensing fee for e-stewards certification in addition to the general cost of certification, based on organization revenues BAN Amendment: Proposed amendment to the Basel Convention that would ban hazardous waste exports for final disposition or recycling from Annex VII countries (Basel Convention parties that are members of the EU, OECD and Liechtenstein) to non-Annex VII countries (all other parties to the convention). – Requires ¾ vote of all parties – Not in force – E-stewards’ standard requires recyclers to act as if the BAN Amendment was ratified and supported by the U.S. PERRY JOHNSON REGISTRARS, INC. 24
  25. 25. State Electronics Laws Currently 20 States and NYC (current lawsuit) have electronics take-back laws — follow a “Producer Responsibility Approach” – Most address TVs (e.g., Texas HB 2714 does not) and PCs; some also address peripherals and cell phones – Most require manufacturers to pay for collection/recycling through take- back programs — OEM must label all equipment it sells – Very few laws specify how the material should be handled by the recycler • Kansas & Illinois use R2 language in their recycling law, Washington State; WAC 173-900-650 gives preferred status for R2 certification – 11 States and NYC also ban disposal of these electronics in landfills • Most also require take-back – Each law is slightly different from the other — California uses an “ARF” approach — consumers pay “up-front” Resources on State Laws – www.ElectronicsRecycling.org – www.electronicstakebac.com PERRY JOHNSON REGISTRARS, INC. 25
  26. 26. EPA’s APPROACH TO WASTE MANAGEMENT HAS EVOLVED TO ENCOURAGE REUSE AND RECYCLING. Universal Waste Rule: – Mercury-containing devices are in this rule and are considered hazardous waste, but have streamlined requirements when going for recycling or disposal CRT Rule: – CRTs and CRT glass are not considered solid or hazardous waste when reused or recycled if certain conditions are met (40 CFR, Subpart E, 261.39). Similar streamlined requirements as Universal Rule. Responsible Recycling Practices (R2): – Includes a broader spectrum of electronic materials; complements the other traditional approaches; does not replace any of the electronics recyclers legal obligations PERRY JOHNSON REGISTRARS, INC. 26
  27. 27. CRT Rule To encourage reuse, recycling, and better management of this rapidly growing waste stream. CRTs are the video display component of computers and TV monitors. Many CRTs from color monitors fail EPA’s testing requirement (TCLP) for lead. Not Regulated: Households: May send used CRT monitors to any collector for recycling or disposal. – Recyclers need to show 100% of material from households to be exempt Small Quantity Generators: Non-residential (businesses) generators of less than 100 kg. per month (about 7 or 8 monitors) are not subject to most Subtitle C standards. Customers: May send any CRTs to a recycler for potential reuse, repair or recycling. PERRY JOHNSON REGISTRARS, INC. 27
  28. 28. CRT Rule: Domestic Recycling Requirements Requirements for Recyclers: Used Intact CRTs sent for recycling within the U.S: – Labeling – No speculative accumulation. • 1 year- CFR 261.1 (e) (8) Used broken CRTs sent for recycling within the U.S. – Packaging and labeling for storage and shipment, – No speculative accumulation. Requirements for Glass Processors: Store CRTs indoors, or package and label them. No speculative accumulation. No temperatures high enough to volatilize lead. CRT Labeling: “used cathode ray tubes- contains leaded glass” OR “leaded glass from televisions or computers”, AND “do not mix with other glass materials”. Must also follow any specific state rules e.g. PERRY JOHNSON Maine “Waste Cathode Ray Tubes” REGISTRARS, INC. 28
  29. 29. CRT Rule Definitions CRT Glass Processer: Must do all three: – Receive broken or intact CRTs; – Intentionally break or separate; – Sort or otherwise manage (e.g., clean) glass removed from CRT monitors. Processed Glass: If sent to a glass manufacturer or a lead smelter, not regulated. If sent to other kinds of recycling, may be excluded on a case-by-case basis. No speculative accumulation. No CRT glass manufacturers currently in U.S. – Glass to Glass furnaces located in Asia PERRY JOHNSON REGISTRARS, INC. 29
  30. 30. CRT Smelters – Glass to Lead Recovery DOE Run – St. Louis Xstrata – Canada (New Brunswick and Rouen) PERRY JOHNSON REGISTRARS, INC. 30
  31. 31. CRT Furnaces- Glass to Glass Videocon – Poland and India Samtel – India Samsung – Malaysia Hankuk Electric – S. Korea PERRY JOHNSON REGISTRARS, INC. 31
  32. 32. Export Requirements: Used CRTs and CRT Glass Export for Recycling: Exporter must send notice to EPA 60 days before shipment. May cover export activities extending over a 12 month or lesser period. EPA forwards notice to the receiving country, then forwards response to the exporter. – Export may take place only when consent has been received. No speculative accumulation. Used Intact CRTs Export for Reuse: Exporters must send a one-time notification to state or EPA with contact info and a statement that the exporter plans to export the CRTs for reuse. Must keep normal business records demonstrating reuse for three years. PERRY JOHNSON REGISTRARS, INC. 32
  33. 33. CRT Rule Notices List of facilities approved to export CRTs and CRT glass for recycling on EPA website at: www.epa.gov/osw/hazard/international/crts/recycling.htm – Facilities approved to export CRTs for recycling – about 32. – Table lists the US exporter name, site address, and end date for CRT shipments. – If exporting processed CRT glass – no export notifications. List of facilities that have filed the one time notice for export of CRTs for reuse can be found on EPA’s website at: www.epa.gov/osw/hazard/international/crts/reuse.htm – Facilities filing one-time notices on exporting CRTs for reuse – about 60. Data on both lists are updated periodically. PERRY JOHNSON REGISTRARS, INC. 33
  34. 34. CRT Rule Enforcement EPA has initiated over thirty civil investigations in eight out of ten EPA Regions Plan to conduct additional inspections and information gathering efforts in FY 2010. – EPA has settled violations with two companies and filed three civil administrative complaints. – EPA has determined that seven companies did not have any violations. PERRY JOHNSON REGISTRARS, INC. 34
  35. 35. Other Electronic Materials Most electronics sent for recycling are not classified as hazardous wastes. Whole used and shredded circuit boards are exempted from regulation if they meet certain requirements (i.e., mercury and batteries have been removed) Unclear whether devices have enough Hg (switches, backlighting) to test hazardous under RCRA. – Some states include this material under universal waste rules. PERRY JOHNSON REGISTRARS, INC. 35
  36. 36. Contacts Karen Pollard (R2) 703-308-3948 Pollard.karen@epa.gov Patti Whiting (Export Issues) 703-308-8421 Whiting.patti@epa.gov Marilyn Goode (CRT Rule) 703-308-8800 Goode.marilyn@epa.gov PERRY JOHNSON REGISTRARS, INC. 36
  37. 37. Essential “R2” Concepts Reuse and Recycling Required – Disposal of focus materials only in exceptional circumstances On-site Worker & Environmental Protection – Federal OSHA consulted for section – On-going hazard identification & assessment of risks – Special handling for focus materials Downstream Due-Diligence for Focus Materials – Throughout the recycling stream – Includes international vendors – Written focus material management plan for recyclers & downstream vendors; posses & PERRY JOHNSON have documentation on downstream controls REGISTRARS, INC. 37
  38. 38. Essential “R2” Continued Evidence of Legality of Export – Documentation must be from the Government Comprehensive Management System – Includes, environmental, health and safety concepts – Includes requirements of many of the practices – Written programs using “Plan-Do-Check-Act” model for continual improvement Compliance with all Laws and Rules – An R2 certification audit is NOT a compliance audit (ANAB Accreditation Rule #9) PERRY JOHNSON REGISTRARS, INC. 38
  39. 39. R2 Continued… Destroy, purge or sanitize data from all memory; – NIST Guidelines for Media Sanitation - 800- 88, or other standard or certification program (i.e., NAID) Track throughput and recordkeeping; – Business records of all transfers of equipment and materials into and out of facility Store and transport materials securely and safely; and Possess insurance, closure plans and financial mechanisms to cover the potential risks of the facility. PERRY JOHNSON REGISTRARS, INC. 39
  40. 40. R2 Practice #1 Environmental, Health & Safety Management System R2 electronic recycler shall develop and use an EHSMS – Define scope of the system (e.g. part of a larger complex with some shared activity). Based on PDCA model for continual improvement – Policy supporting a “reuse, recover”, dispose hierarchy throughout the recycling chain. – Documented goals to support the policy: goals that reflect R2, not “reduction of paper” – Policy and goals understood by all employees – Identification of all site activities (e.g. process flow) – Identification and monitoring of on-site occupational & environmental risks – Focus materials plan – Emergency response Important to understand the component parts of the PDCA model per note 2 – Includes international monitoring (auditing) and system review to ensure effectiveness of the EHSMS. PERRY JOHNSON REGISTRARS, INC. 40
  41. 41. R2 Practice #2 “Reuse, Recover…” Hierarchy of Responsible Management Strategies Reuse, Recover, Dispose - Written Policy – Communicated to employees and downstream vendors Consistent with FM Plan – Apply hierarchy to focus materials Includes control of vendors – Expect downstream hierarchy to address reuse/recovery. PERRY JOHNSON REGISTRARS, INC. 41
  42. 42. R2 Practice #3 Legal Requirements Compliance with all environmental, health, and safety legal requirements – R2 certification audit is NOT a compliance audit- ANAB Accreditation Rule #9 Export FM components to countries that legally accept them – Documentation from EPA or Competent Authority: Documents sent with each shipment Periodic compliance evaluation – Identity and document all legal requirements applicable to the facility (e.g. CFR 40, CFR 29, local, state, county regulations, International regulations, etc.) • Keep in mind that a regulation can have several components or requirements - a title is not enough! – Document the steps necessary to comply (e.g. work instruction that shows how to label CRT’s) – Take Corrective Action (NOT just correction) for any identified non-compliance • Fix so it doesn’t happen again PERRY JOHNSON REGISTRARS, INC. 42
  43. 43. R2 Practice #4 On-Site Environmental, Health & Safety Expertise and capability for processes Ongoing hazards identification of occupational and environmental risks - e.g. new processes or materials – Regular, documented training/refreshers - includes entire workforce (any volunteers) Manage risks on priority basis: Engineering controls, Administrative controls, PPE Monitor/sample for risk management - e.g. PELS – Two-way communication encouraged Designated site coordinator for promotion of health/safety Respond/report releases/accidents – Emergency planning, drills, training This section essentially addresses the major portion of OSHA 18001 and ISO 14001 PERRY JOHNSON REGISTRARS, INC. 43
  44. 44. R2 Practice #4 Environmental & Safety hazards include but are not limited to: High traffic areas – heavy equipment traffic Trips and falls Cuts from glass or sharp metals Burns in facilities that do assaying Eye injuries from debris Head injury from falling objects Improper outside storage resulting in impacts to storm water. Exposure to high decibel noise levels for a short time Improper labeling resulting in diminished equipment reuse opportunity Particulate or metals dust exposure from cleaning CRT’s, crushing, washing CRT’s, shredding metals Improper evaluation & sorting resulting in diminished equipment ruse opportunity. Chemical exposure from processing areas PERRY JOHNSON Transportation spills REGISTRARS, INC. 44
  45. 45. R2 Practice #5 R2 Focus Materials Items containing polychlorinated biphenyls (PCB’s) – Ballasts, capacitors, medical equipment - need training to identify/manage - hazwaste Items containing mercury – Switches, bulbs, flat-panel tubes CRT’s and CRT glass Batteries – Handle as universal waste; many U.S. facilities for final destination Whole and shredded circuit boards except for whole and shredded circuit boards which do not contain solder and have undergone safe and effective mechanical processing or manual dismantling to remove mercury and batteries – Toner and toner cartridges, while not FM’s, should be reused, recovered as possible. PERRY JOHNSON REGISTRARS, INC. 45
  46. 46. R2 Practice #5 R2 Focus Materials Develop FM Plan: downstream vendors Removal of FM’s Exceptions: mercury if too small to safely remove, and, CRT’s, batteries and circuit boards prior to shredding/recovery when sent to properly licensed facilities. Facilities properly licensed FM strategy should not utilize energy recovery, incineration or land disposal – May consider when normal system is disrupted as allowed by law. Due diligence of downstream vendors – Conformance to 5e (1-7) – Audit/monitor recycling chain • On-site or self review, or combination • Needs to be a robust process PERRY JOHNSON REGISTRARS, INC. 46
  47. 47. R2 Practice #5 R2 Focus Materials FM Plan should include, as a minimum – Identification of site FM’s – Responsibility for specific activities – How/which FM’s will be removed • Decisions on deminimus levels – Statement on use of energy recover, incineration, land disposal – Transportation issues - export requirements – Selection and due diligence of downstream vendors • Method of risk assessment • Audits/monitoring • Contractual requirements - communication of R2 expectations • How material will be tracked – Reference to supporting documents Matrix is a good way to show FM’s and their movement though the vendor chain PERRY JOHNSON REGISTRARS, INC. 47
  48. 48. R2 Practice #6 Reusable Equipment & Components Comply with commercial agreements Label and sort to allow tracking (R2 #7) Transport/handle in conformance with R2 #12 Confirm key functions Confirm recipient vendor certified R2 electronics recycler (Or) Key functions – Vendor manages all residual FM’s in conformance with R2 • Exceptions for number of units – Less than 15 for evaluation • New in original packaging – Need not comply if satisfy R2 3 or 5 PERRY JOHNSON REGISTRARS, INC. 48
  49. 49. R2 Practice #7 Tracking Throughput 3 year retention of records for transfer of equipment, components and materials, and brokerage transactions. Should be consistent with FM plan Link to R2 #13 for overall records management and document controls PERRY JOHNSON REGISTRARS, INC. 49
  50. 50. R2 Practice #8 DATA Destruction R2 recycler shall follow NIST special publication 800-88 or generally accepted standard, or be certified (e.g. NAID) Documented destruction practices – Trained employees: Refreshers – Process reviewed and validated by independent, third-party on periodic basis PERRY JOHNSON REGISTRARS, INC. 50
  51. 51. R2 Practice #8 DATA Destruction Steps to consider: per NIST guideline 800-88 – Sanitization decisions based on security needs of the information on the media- on-site or outsourced, cost, training, volume – Decision on “clearing, purging, destroying” - based on security • Clearing: software overwriting • Purging: degaussing (suggests NSA/CSS approved equipment) • Destroying: disintegration, incineration, pulverization, melting - best way If outsourced – Contract for confidentiality control – Review and validate the process by R2 trained individual – Controlled shipments – Tier 1 vendor Equipment Maintenance & Calibration Competency of personnel - hiring/screening Records of sanitization to document what media were sanitized Insurance? PERRY JOHNSON REGISTRARS, INC. 51
  52. 52. R2 Practice #9 Storage FM’s, equipment, and components – Protect from atmospheric conditions/floods – Access controlled/security – Container labeling and storage area identification • Pay attention to any legal requirements (e.g. CRT’s, batteries) • Consider inclusion in ongoing monitoring activities to ensure any compliance issues, and container integrity to eliminate leakage (dust, liquids) PERRY JOHNSON REGISTRARS, INC. 52
  53. 53. R2 Practice #10 Facility Security Controlled access – Consider equipment and customer needs – Consideration of shared resources (e.g. part of a MRF), or responsibility by a corporate entity not in the scope of R2 certification PERRY JOHNSON REGISTRARS, INC. 53
  54. 54. R2 Practice #11 Insurance, Closure Plan and Financial Responsibility Comprehensive or Commercial General Liability Insurance – Bodily injury, property damage, pollutant releases, accidents - need evidence for all categories Written and funded closure plan – May be state minimums Need to address as part of downstream vendor controls PERRY JOHNSON REGISTRARS, INC. 54
  55. 55. R2 Practice #12 Transport Package to minimize risk – CRT rules Transporters have/met regulatory authorization – No significant violations during past 3 years • Need documentation – If using trucking brokerage firm, verify requirements of their contracts – Be sure to include transport as part of environmental and health/safety risk assessment PERRY JOHNSON REGISTRARS, INC. 55
  56. 56. Recordkeeping Maintained in a single site location – Show conformity to R2 requirements – Linkage to R2 practice #7 PERRY JOHNSON REGISTRARS, INC. 56
  57. 57. Integration/Comparison with ISO 9001 and ISO 14001 Implementation/Auditing Implications R2 manual Objectives and Targets Internal Audit Maintenance / Calibration Nonconformance / Corrective / Preventive Action Training Document/Records Control PERRY JOHNSON REGISTRARS, INC. 57
  58. 58. Integration/Comparison with ISO 9001 and ISO 14001 R2 Manual: There is no requirement for an R2 manual. However, there is a requirement to document a written EHSMS that includes written goals and procedures. 1a1 requires written goals (continual improvement) and procedures 1a3A requires a policy for managing end of life electronic – it is expected that this POLICY is understood by all employees and communicated to downstream vendors 1a3C requires a FM plan 1a3F requires a list of activities necessary to conform to R2- NOT an interaction of processes, but identification of ALL activities/processes (perhaps as a simple electronics flow chart) needed to meet requirements for R2 SCOPE of the organization should be identified within the documented EHSMS to conform with ISO 17021 requirements While organizations may indeed have a variety of documents that integrate their activities, a MANUAL is not required. PERRY JOHNSON REGISTRARS, INC. 58
  59. 59. Integration/Comparison with ISO 9001 and ISO 14001 Objectives and targets: Again, no specific R2 Practice addresses how to establish and/or monitor goals, objectives and targets. 1a2, note 2, requires establishing goals, objectives and targets, tracking performance, plan activities that work toward achieving identified goals, create and implement an action plan for continual improvement. PERRY JOHNSON REGISTRARS, INC. 59
  60. 60. Integration/Comparison with ISO 9001 and ISO 14001 Internal Audit: there is no R2 Practice specific to internal auditing. The R2 General Principle 1, requires a recycler to use EHSMS to plan and monitor its processes and activities to conform to R2 Practices. Monitor is the key terms as it suggests some methodology equivalent to an internal audit to verify effectiveness of the EHSMS. ISO 17021 requires CB’s to verify effectiveness of the internal audit/monitoring program. 1a2, note 2, requires monitoring of key activities and tracking performance of the EHSMS 5f requires recycler to confirm “through audits or other similarly effective means” that downstream vendors comply with FM controls 6c3 requires “an appropriate combination of…materials tracking…and auditing” for reusable equipment and components. Use of the R2 checklist by recyclers could meet the requirements for “internal auditing”. We should expect that a “monitoring (auditing) plan/schedule” is established and followed, and that people using the checklist are competent. We should expect that this information is submitted for review (input) of the EHSMS. We could logically expect that the audit/monitoring program covers all key activities of the recycler show “effectiveness” - however a “process approach” is not required. PERRY JOHNSON REGISTRARS, INC. 60
  61. 61. Integration/Comparison with ISO 9001 and ISO 14001 Maintenance/Calibration: There is no R2 Practice specific to equipment maintenance or calibration of test equipment to ensure meeting any OSHA PEL testing, e.g. test for noise or lead dust. However, the activities are implied, or would be required by CFR 29 or CFR 40. 3 (general principle) requires conformance to applicable health and safety requirements - this would imply all of CFR 29 applicable to equipment maintenance expectations (e.g. LOTO, hand tool inspections, etc.) 4b recycler adheres to Good Housekeeping Practices- equipment, tools, infrastructure (e.g. 29 CFR 1910.22, 1910.76, 1910.178, 1910.242) - virtually any maintenance issue could be written against clause 4b. 4e requires recycler to use sampling protocols that are effective - and to comply with all PEL’s for sampling monitoring - calibration of sampling or test equipment is necessary to assure effectiveness. 6c1 requires “use of effective testing methods”, confirms reusable equipment is working properly. PERRY JOHNSON REGISTRARS, INC. 61
  62. 62. Integration/Comparison with ISO 9001 and ISO 14001 Nonconformance/Corrective/Preventive Action: There is no R2 Practice specific to nonconformance, corrective or preventive action. However, it is implied by 1a2 that bases the EHSMS on the PDCA model. 1a2 note requires identification and correcting of problems to prevent recurrence. It is important to remember that Karen Pollard of the EPA included this note to help recyclers understand the elements of an EHSMS that should be in place, based on the PDCA - it is expected to be adhered to in order to meet expectation of R2 effectiveness. 3a1 requires recycler to “take corrective action to address any issues of non-compliance”. This would be driven by compliance evaluations or daily observance of noncompliance, e.g. improper use of PPE, failure to follow the reuse/recover policy, etc. PERRY JOHNSON REGISTRARS, INC. 62
  63. 63. Integration/Comparison with ISO 9001 and ISO 14001 Training: There is no R2 Practice that specifically addresses recycler/ employee training. However, specific training issues are addressed. 4a requires recyclers to possess expertise and technical capability to process each type of equipment, component and material in order to protect employees, public and the environment- implementation would require a training program with associated records maintained 4d2A requires regular, documented health and safety training, and refreshers for all employees 4f requires training of volunteer and temporary workers per 4d2A 4g requires assignment of an individual (consultant or employee) to coordinate and promote worker health and safety 8c requires employees involved in data destruction to be trained on a regular basis. PERRY JOHNSON REGISTRARS, INC. 63
  64. 64. Integration/Comparison with ISO 9001 and ISO 14001 Document/Records Control: There is no R2 Practice that specifically addresses document control, external documents, control of obsolete documents, records retention times, etc. However, document control and records maintenance activity and effectiveness is clearly implied. R2 practice 13 (recordkeeping) addresses records for showing conformity - it is likely the catch-all clause to write against if there is a records issue. 1a requires a “documented, fully implemented, update as needed, written EHSMS”. – this is likely the catch-all clause implying some method of document control and availability of most current revision of an EHSMS document. 1a1 requires “written procedures”. 1aF requires a “list of the documentation necessary…” 3a2 (ABC) requires documentation that allows transboundary shipments 4d2A requires documented health and safety training 7a requires maintenance of commercial contracts, bills of lading, etc. for 3 years minimum 8b requires “documenting” data destruction practices 12b requires recycler to obtain documentation of transporter certification and performance 13a requires maintaining “documentation necessary to show conformity to each requirement” maintained in a single location - the main clause to support records management. PERRY JOHNSON REGISTRARS, INC. 64
  65. 65. R2 Certification Governing Rules: ANAB: ANSI-ASQ National Accreditation Board – Rule 34 • References R2 Standard/checklist and ISO 17021:2006 • No unaccredited R2 certificates may be issued – Registrars certificate MUST have ANAB seal to be VALID • Certificate must reference ISO 17021 • Registrar maintains publicly available list of clients • Only single-site certification is possible ISO 17021:2006 - requirements for bodies providing audit and certification of management systems – Rules of engagement for the Registrar (certification body) – Establishes how R2 audits will be conducted (Stage 1 and Stage 2) – Establishes timing for surveillance audits - annual at minimum – Establishes requirements for recertification - 3 years – Establishes what the Registrar should review during specific audit cycles. PERRY JOHNSON REGISTRARS, INC. 65
  66. 66. R2 Certification Stage 1 Requirements: Documentation reflecting R2 requirements Client understanding of requirements: training Site-specific conditions Scope of the ESHMS Compliance evaluation completed and issues being addressed Understanding of organizations’ significant environmental/safety risks Evaluate internal audit planning and performance or equivalent monitoring of processes Evaluate management review- called annual review in R2 PERRY JOHNSON REGISTRARS, INC. 66
  67. 67. R2 Certification Stage 2 Requirements: Conformity to requirements - Implementation Performance monitoring against key performance objectives Ongoing legal compliance Operational process controls Internal auditing and management review Responsibility and authority for policies PERRY JOHNSON REGISTRARS, INC. 67
  68. 68. R2 Certification Certification Steps: Training to R2 requirements – Staff – Internal Audits by “competent auditors” Create R2 documents or integrate with existing systems (e.g. ISO 9001, 14001 or OSHAS 18001) Implement R2 requirements – Conduct internal audits of system – Conduct compliance evaluation – Conduct review of system based on input from internal audit Contract with a certification body Complete S1 and S2 audits – Address any nonconformities ☺ Certification! PERRY JOHNSON REGISTRARS, INC. 68
  69. 69. Expectations for R2 Widespread Use EPA was asked for a way for refurbishers/recyclers to highlight their sound recycling practices and a way for customers to easily find recyclers that are sound Members of the stakeholder group that support R2: – States and local governments • Some have R2 elements in law • Some have added R2 requirements to procurement contracts – ISRI (recyclers trade assoc) • Is offering RIOS/R2 training to recyclers – ITI (OEMs trade assoc) • Encouraging OEMs to get their recyclers certified • Many state laws require the OEMS to provide take back – MARs (Microsoft Authorized Refurbishers) - 500 + members • Looking to find a way to get their members certified Federal Government – Currently must use recyclers that meet the Plug-In To eCycling Guide & must do their own diligence – When there are R2 certified recyclers, EPA will replace the Plug-In To eCycling guide with R2 practices PERRY JOHNSON – Plug-In To eCycling Partners- OEMs REGISTRARS, INC. 69