Electronics recycling webinar final presentation
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Electronic recyclers are experiencing demands that are difficult to meet in today’s ever-changing regulatory environment. To help, Nimonik invited Ronald Lepore, a former RQO auditor, to discuss: 1- Common non-conformances during government and certification audits 2- Operational bottlenecks and best practices; with case studies 3- How to adapt to the changing trends
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Electronics recycling webinar final presentation
- 1. Electronic Recycling Challenges • Best Practices • Trends
- 2. Introduction A former RQO auditor, I have been instrumental in the development of multi-site Canadian electronics recycling operations, including shredding and manual teardown. I have years of experience implementing R2/RIOS, ISO 14001, ISO 9001 and OHSAS 18001 standards Ronald Lepore
- 3. Section 1- Overview of North American recycling programs Section 2- Non-conformances during certification audits Section 3- Operational challenges Section 4- Trends Section 5- Legal requirements Agenda
- 6. • Canada at the forefront since 2004 • The Electronic Recycling Standard (ERS) in 2004 • Governing body: Recycling Qualification Office (RQO) Canada Section 1- Overview
- 7. • USA lags behind Canada • Legislations not harmonized among States • E-waste treated as a commodity • R2 helps standardize all across North America United States Section 1- Overview
- 8. Section 2 Non-conformances 1. Significant aspects & Focus Material 2. Hazardous Materials / Health & Safety 3. Housekeeping 4. Security of the building/ data 5. Contingency & closure Plans 6. Emergency preparedness & response
- 9. • First concern in auditing for ISO 14001 or R2 • Significant Aspects: aspects of activities organizations can control within the life cycle of products • Life Cycle Approach to evaluate how organization interfaces with significant aspects Section 2- Non-conformances during certification audits 1. Significant Aspects & Focus Material
- 10. LIFE CYCLE Control Influence Atmospheric Emissions Servicing Extraction of raw Purchasing Manufacturing Distribution Use Disposal Materials Recycling Liquid effluent Solid Waste Life Cycle Section 2- Non-conformances during certification audits 1. Significant Aspects & Focus Material
- 11. PDCA Approach Section 2- Non-conformances during certification audits 1. Significant Aspects & Focus Material
- 12. • Ratings prior to and after control methods • How aspects are controlled and associated with legal regulations Section 2- Non-conformances during certification audits 1. Significant Aspects & Focus Material
- 13. • Usual downfall - changes to processes or equipment • Requirement: update the matrix and evaluation should changes occur • Common reason for non-compliance- insufficient local resources for monthly review Operational changes that affect Aspects Section 2- Non-conformances during certification audits 1. Significant Aspects & Focus Material
- 14. Solution • Environmental committee should develop and maintain the matrix • Should report back for Management Review Section 2- Non-conformances during certification audits 1. Significant Aspects & Focus Material
- 15. • Handling and storage of CRTs, batteries, circuit boards reviewed for compliance • Areas of concern- lack of secondary containment for ethylene glycol and the storage of lithium, alkaline batteries Section 2- Non-conformances during certification audits 1. Significant Aspects & Focus Material
- 16. Solution • Secondary containment for all stored hazardous liquid materials and lead acid batteries • Mercury or fluorescent light bulbs must be securely stored Section 2- Non-conformances during certification audits 1. Significant Aspects & Focus Material
- 17. • Min/max levels of time in storage • Approved downstream supplier • How materials are controlled • Actions taken to prevent employees from exposure • MSDS (Material Safety Data Sheets) sheets up to date and readily available Section 2- Non-conformances during certification audits 2. Hazardous Material/ Health & Safety
- 18. Personal Protective Equipment (PPE) • When greeting at the facility entrance, auditors look for required PPE • Examples: safety glasses, labcoats, masks, steel toed shoes etc. • Evidence that all personnel follow requirements • Masks: mask fit test Section 2- Non-conformances during certification audits 2. Hazardous Material/ Health & Safety
- 19. • Annual blood tests against lead exposure • Noise db testing in the plant required to meet 80db or less • Water tests for lead management • Annual air testing for contaminants Section 2- Non-conformances during certification audits 2. Hazardous Material/ Health & Safety
- 20. • Facility clean • Workstation free of clutter • Alley-ways free from obstructions • Fire exits free from wooden pallets • Electrical panels protected • Battery chargers at least 3 ft from electrical panels Section 2- Non-conformances during certification audits 3. Housekeeping
- 21. • Inadequate control over visitor/contractor management systems a common reason for non-compliance Section 2- Non-conformances during certification audits 4. Security of building/ data
- 22. Solution: • A guest register with sign in and out • Present your Health & Safety policy, requirements on the premises • Request contractors to inform you of any hazardous materials they would bring into the facility • There are software available to manage this ( i-visitor) Section 2- Non-conformances during certification audits 4. Security of building/ data
- 23. • Cameras and security alarm systems to secure the building • Employees leaving garage doors open in the summer leads to non- compliance • Deploy iron gates if these doors are to be left open • Chocks under back wheel of 40 ft trailer rigs Section 2- Non-conformances during certification audits 4. Security of building/ data
- 24. • Required by most e-waste programs • Specified amount of insurance for environmental incidents/closure of the facility • Requirement based upon the capacity, square footage, and materials • Security bond usually issued to the program management or the municipality • Calculations not always adequate • A robust contingency plan in case of fire Section 2- Non-conformances during certification audits 5. Contingency & closure plans
- 25. • Common non-conformance- lack of spill drills in case of spills from fuel in the docking areas or hydraulics from process equipment • Prepare for possibilities from your neighboring facilities, example; outdoor propane tanks, large water towers, power shutdown, fire drills • Not all facilities conduct adequate drills for prevention Section 2- Non-conformances during certification audits 6. Emergency preparedness and response
- 27. • The issue of how much and the type of product given to process • Management should have a vision of future capacity and risks • Recycling programs administer material by a bid process • Capacity, footprint of the facility and transport requirements all come into play • Manually dismantling vs primary shredding facility depends on financial investments and business plan Section 3- Operational challenges
- 28. • Issues with the marrying of different equipment concern the balancing of the line • Throughput comes into play • If the shredder is operating at (x)mt/hr and conveyors and equipment downstream on the line are not calibrated, there will be a bottleneck • Outcome maybe different (possible health & safety risks) when an equipment that works fine in isolation is applied to the line • The ideal primary recycling facility is real a myth Section 3- Operational challenges
- 29. Material being fed to chain shredder (Inside view of chain shredder) Chains within the cylinder, which turn in order to break up material Section 3- Operational challenges
- 30. 4 shaft shredder Optical sorting machine used for plastics separation as well as cicuit boards Section 3- Operational challenges
- 31. Considerations: 1. Is my buisness plan one for manual dismantling? • What is the potential for the line, how many people required • Layout of production line • Capacity of the line and throughput (yield) • Who are my upstream and downstream suppliers • Where will I get material? • What are my legal requirements to operate? • How large a facility is required? • Data destruction capability ( KillDisk, Blanko etc…) • Refurbish for resale Section 3- Operational challenges
- 32. 2- Is my business plan for a Primary Recycling Facility? • Capital expense budget for equipment based upon capacity of the line and throughput (yield) • Who are my downstream suppliers? • Where will I get material? • What are my legal requirements to operate? • How large a facility is required? You can see that both scenarios follow the same path with the exception of cost $$$. Usually there are additional concerns over dust collection, air exchanges in the facility, C of A requirements etc.. Section 3- Operational challenges
- 33. Challenges • The mix of material as inputs • Approved downstream suppliers to receive output • Throughput and yields as estimates • Size of the facility: (staging and storage areas) • Location of the facility: zoning, transport etc. • Equipment integration and process flow • Compliance demands from e-waste Programs (packaging, data destruction requirements for re-use under R2) • Employee onboarding, training and safety programs Section 3- Operational challenges
- 34. Section 4 Trends
- 35. • Individuals keeping their old electronic devices as long as they can • Recyclers receiving old tube-style monitors and televisions which haven’t been sold for years • This is problematic-market for lead containing glass is drying out and the downstream supplier base is being affected • In the latter years CRT glass recycled for new equipment, but this is no longer an option Solution: • It is important to develop supplier base with the foresight of possible capacity issues • Limited supply of downstream suppliers may cause companies to deliver to developing countries Section 4- Upcoming trends
- 36. • The commodities market for ferrous metals as well as copper etc. fluctuating negatively • Re-align business plans, become more creative with processes to extract precious metals • Newer electronics present issues- harder to extract precious materials Section 4- Upcoming trends
- 37. Solution: • Possible hedging of commodities in the Commodities Markets in order to lock in • For this to be efficient, grade of commodity material is an important factor for pricing • At times the yield not appropriate and the output volume not large enough to participate Section 4- Upcoming trends
- 38. Section 4- Upcoming trends • Legislation in the USA needs to be more harmonized • Recyclers transport e-waste across border to other states that have little e-waste legislation • This is creating an unbalance advantage to non-certified recyclers who do not have the same constraints.
- 39. • Ontario Electronics Stewardship (OES) directed to wind up the Waste Diversion Program for WEEE by the Ministry of Environment of Ontario by 2020 • Program was harmonized under EPRA • Management of e-waste material and distribution to recyclers was difficult in the past years • RPRA (Resource Productivity & Recovery Authority) will lead, it is anticipated that the remuneration based on capacity, location and bid process will change • Most probably companies will be responsible to get their own input material • Smaller companies at a disadvantage • There may be more cross-border activity as well Section 4- Upcoming trends
- 40. DELL Design for Environment Initiative Section 4- Upcoming trends • Industry far from being stable! • Challenges with complex plastic materials, composites of mixed materials, as well as new additives such as nanoparticles • Very little done in researching how to extract these materials • Their applications have been very secretive and proprietary • OEMs have started to recycle their own plastics and looking at future designs and recycling technologies to ensure recyclability of products • We will start to see more partnering, both with downstream and upstream suppliers to secure business plans
- 41. • We are starting to see a downsizing trend • The smaller the units, the harder to extract valuable materials • Technology for e-waste extraction will need to keep up and we will see more re-use of cell phones for the secondary markets • Not everyone will afford the new X-phones from Apple Section 4- Upcoming trends
- 42. • Increase in automotive electronics • We may start to see car metal recyclers having more of a presence into e-waste recycling market rather than just metal recycling Section 4- Upcoming trends
- 44. Main challenges for corporations : • Maintain their legal registries • Resources to monitor and understand the changes • Attach legal compliance to the significant aspects evaluation matrix as well as to the Health & Safety Risk analysis Section 5- Legal requirements
- 45. Solution • As a Nimonik user, I have had personal experience with the software and I am very satisfied • It certainly has served us well under registration audits Section 5- Legal requirements
Editor's Notes
- Cliff Hacking & Jay Illinworth EPRA
- it was originally based on ISO 14001 elements concerning environmental good practices as well as ensuring the collection and distribution of electronic end-of-life products. Canada has been at the forefront of compliance measures globally since 2004. The Electronic Recycling Standard (ERS) was first developed in 2004 by the Electronic Product Recycling Association (EPRA) and governed by the Recycling Qualification Office (RQO) in order to maintain audits of Electronic Recyclers throughout Canada.
- look for a global Standard to assist with the maintenance of programs throughout Canada as well as an indirect attempt to harmonize USA recycling requirements and Global Downstream Suppliers. This is where R2 (Responsible Recycling) came into play.R2 requires the compliance of each facility site and cannot be obtained on a single certification for multi-site operations, as is the case with EPRA certification. ISO 14001 can be obtained under one certificate for multi-site applications. Unfortunately, USA electronic end-of-life requirements have lagged their Canadian counterparts over the last years. Legislations have not been harmonized between States as is the case in Canada. In the USA, it is common for e-waste to be treated as a commodity, where individuals are paid for materials that are deposited at recycling facilities; whereas in Canada it is primarily funded by eco-fees under a harmonized structure. R2 does create an effective way of standardizing North America and including OEMs into the process.
- Using a process-based approach, our first concern in auditing for ISO 14001 or R2 is to identify the process to deal with significant aspects. These are aspects of activities that organizations can control or influence within the life cycle of their products, along with their associated environmental impacts. An auditor will also use a Life Cycle Approach to evaluate how an organization interfaces with their significant aspects:
- the life Cycle approach is used to follow the waste stream and operations in alignment with the significant aspects. Controls are defined for each aspect and associated legal requirements. Actions are then defined in order to reduce risk. A PDCA ( Plan-Check-Do-Act) method is used to evaluate progression. During R2 audits under the area of Focus Material, a review of the policies and processes covering the removal, handling and storage o
- Interface with ISO 14001:2015 clauses to achieve continual improvement
- RPN (Risk Priority Number) = Severity x Occurrence X Detection Comes From FMEA ( Failure Mode & Effects Analysis) Interested Parties: Customers, Neighbors, Gouvernments, shareholders etc..
- In most of the cases reviewed, the matrix is well developed but the usual downfall occurs when there are operational changes to processes or equipment. It is a requirement to review and update the matrix and evaluation should changes occur in these areas under the change management process. (another possible area for non-compliance and one that could be very easily avoided) One reason for non-compliance associated with this area is due to the fact that 3rd parties are usually responsible for the initial compliance matrix as well as compliance audits (legal compliance) and that the organization does not have local resources to review it on a monthly or ongoing basis.
- Company can initially have a 3rd party but be prepared to communicate and take over the maintenance This matrix should be developed and maintained by the environmental committee of the organization, and should be reported back to Management Review for potential actions. The auditor will also review if these actions or evaluations have been reported in Management Review meetings in order to assess whether management is engaged within the process.
- During R2 audits under the area of Focus Material, a review of the policies and processes covering the removal, handling and storage of CRTs, batteries, circuit boards will be reviewed for compliance. Areas of concern are usually associated with the lack of secondary containment for the storage of Ethylene glycol from projection TVs and CRTs as well as lead acid batteries, and the storage of lithium, alkaline batteries which may pose risks for fire or leaching. Solution: Make sure that there is secondary containment for all stored hazardous liquid materials and lead acid batteries. Also any mercury bulbs or fluorescent light bulbs must be properly securely stored in order to comply.
- Company can initially have a 3rd party but be prepared to communicate and take over the maintenance This matrix should be developed and maintained by the environmental committee of the organization, and should be reported back to Management Review for potential actions. The auditor will also review if these actions or evaluations have been reported in Management Review meetings in order to assess whether management is engaged within the process.
- Min/max levels for length of time in storage and the approved downstream supplier where the material will be sent for processing. In line with hazardous material storage and inventory levels, also comes how these materials are controlled, and if there are issues, what actions can be taken to prevent your employees from exposure? MSDS (Material Safety Data Sheets) sheets must be up to date and readily available on the floor. This can be done electronically using software for this purpose or with paper at specific locals, to provide employees with the information in case of an accident or exposure.
- As part of the greeting at the facility entrance, auditors are looking for what are the required PPE. Examples include: safety glasses, labcoats, masks, steel toed shoes etc.. In certain cases I have had to wear hazmat suits. Upon entering the facility we will seek evidence that these requirements are followed by all personnel. On the issue of masks: if your employees wear them, they must be given a mask fit test in order to establish if it is the right mask for their face as well as the pprope way to wear them. (Another opportunity for a NC.)
- Annual Blood testing for employees to guard against lead exposure is required to safeguard employees ( Cadmium, Berylium depending if Primary recycler) Noise db testing in the plant required to meet 80db or less. Water tests for lead management in any process using water, including the cleaning of the shop floor Annual air testing for contaminants. ( Is the dust collector system doing the job?) Could also use swab testing.
- Have seen basketball hoops in the middle of alleyways.
- Many non conformances are issued due for not having adequate control over visitors and contractor management systems in place. A simple solution is to have a guest register with sign in and out. At the same time you could present your Health & Safety policy , requirements on the premises as well as request that your contractors inform you of any hazardous materials or significant aspects that they would be bringing into the facility. There are softwares available to manage this. ( i-visitor)
- Many non conformances are issued due for not having adequate control over visitors and contractor management systems in place. A simple solution is to have a guest register with sign in and out. At the same time you could present your Health & Safety policy , requirements on the premises as well as request that your contractors inform you of any hazardous materials or significant aspects that they would be bringing into the facility. There are softwares available to manage this. ( i-visitor)
- Some companies require the driver to give them their keys. Cameras and security alarm systems are usuall required in order to secure the building. One potential area for NC is that employees have tendancies to leave garage doors open in the summer months due to the heat. In order to eliminate any NCs, there should be iron gates deployed when these doors are left open to deter any security breach. We would also look for chocks deployed under the back wheel of 40 ft trailer rigs in order to avoid any accidents on the charging or discharging of trailers.
- As part of the requirements of most e-waste Programs, a recycler requires to have a specified amount of insurance for environmental incidents as well as for the possible closure of the plant facility. This requirement is based upon the capacity and square footage as well as materials. A security bond is usually issued either to the Program management or the municipality. Somehow these calculations are not always adequate. The organization should also have a robust contingency plan in case of fire,etc….
- One of the most common NCs in this areas is the lack of spill drills in case of spills from either fuel in the docking areas, or hydraulics from process equipment. One should also look at the possibility of preparing for possibilities from your neighboring facilities ( example outdoor propane tanks, large water towers, power shutdown) and of course fire drills. As auditors, we see that not all facilities conduct adequate drills for prevention.
- There is always the issue of how much and the type of product you will be given to process. Management is required to have a vision of future capacity and risks. Usually the recycling programs administer the percentage of material from a bid process. Capacity, footprint of the facility and transport requirements all come into play. Are you going to manually dismantle or are you building a Primary shredding facility? It will certainly depend on the amount of financial investments that you have available and your business plan.
- Some of the issues that you will run into with the marrying of different equipment suppliers concern the balancing of the line. This is where throughput comes into play. If the shredder is operating at( x )mt/hr and conveyors and other equipment downstream on the line are not calibrated, there will certainly be bottle necking. In certain cases technology, if isolated may be fine but if you take that piece of equipment and apply it the line, the outcome may be very different, or may demonstrate possible health & safety risks including fire risks. Why are companies always changing equipment? The ideal primary recycling facility is real a myth. The capacity, throughput and yields are always estimates due to the fact that the input material is never constant.
- Individuals, in the USA specifically, are keeping their old electronic devices as long as they can and that recyclers are receiving old tube-style monitors and televisions which haven`t been sold for years. This is problematic since the market for lead containing glass is drying out and the downstream supplier base is being affected. In the latter years CRT glass would be recycled for new equipment, but this is no longer an option. Solution: It is important to develop your supplier base with the foresight of possible capacity issues. There is a limited supply of downstream suppliers which may cause companies to deliver to developing countries.
- The commodities market for ferrous metals as well as copper etc.. has been fluctuating negatively and affecting the bottom line for most e-waste recyclers. They will need to re-align their business plans and become more creative with processes to extract precious metals. Newer electronics present issues since it is harder to extract these precious materials that contain fewer valuable materials and therefore less revenue. Solution: Possible hedging of commodities in the Commodities Markets in order to lock in. Unfortunately for this to be efficient, the grade of commodity material is an important factor for pricing and at times the yield is not appropriate and the output volume is not large enough to participate.
- The commodities market for ferrous metals as well as copper etc.. has been fluctuating negatively and affecting the bottom line for most e-waste recyclers. They will need to re-align their business plans and become more creative with processes to extract precious metals. Newer electronics present issues since it is harder to extract these precious materials that contain fewer valuable materials and therefore less revenue. Solution: Possible hedging of commodities in the Commodities Markets in order to lock in. Unfortunately for this to be efficient, the grade of commodity material is an important factor for pricing and at times the yield is not appropriate and the output volume is not large enough to participate.
- Currently (Ontario Electronics Stewardship) OES was directed to wind up the Waste Diversion Program for WEEE by the Ministry of Environment of Ontario by 2020. This program has been harmonized under EPRA , however the management of e-waste material as well as the distribution to recyclers has been difficult in the past years. Although RPRA ( Resource Productivity & Recovery Authority) will be taking the lead, it is anticipated that the remuneration based on capacity, location and bid process will change. Most probably companies will be responsible to get their own input material and will be paid by the tonnage processed. Unfortunately this will place the smaller companies at a disadvantage and unable to compete. There may be more cross-border activity as well.
- As we can see, this industry is far from being stable! There are other challenges with complex plastic materials, composites of mixed materials, as well as new additives that are starting to emerge such as nanoparticles. Very little has been done in researching how to extract these materials and their applications have been very secretive and proprietary. OEMs have started to recycle their own plastics in housing parts of laptops and are looking at future designs and recycling technologies to assist and ensure the recyclability of products. We will start to see more partnering , both with downstream and upstream suppliers in order to secure business plans.
- We are starting to see a downsizing trend (electronics are becoming smaller and their life extension are beginning to lengthen, creating less turn-over. The smaller the units, the harder to extract valuable materials. Technology for e-waste extraction will need to keep up and we will se more re-use of cell phones for the secondary markets. Not everyone will afford the new X-phones from Apple.
- Maintain their legal registries. In most cases it is accepted that a legal compliance audit be performed every 3 years by a 3rd party.The challenge is to be up to during that period of time. If laws have change after 6 months, there is a posssibility that the company may be non-compliant for the balance of the period until the next compliance audit. This would result in a non-compliance Resources to monitor and understand the changes Attach the legal compliance to the significant aspects evaluation matrix as well as to the Health & Safety Risk analysis