E-Scrap. E-Scrap Recycling Standards Overview & Implementation Roadmap. 13 Considerations 14 Implementation Roadmap 15 About the Author

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1 E-Scrap E-Scrap Recycling Standards Overview & Implementation Roadmap 2 Introduction 3 Standards 5 e-stewards 7 R2 9 RIOS 11 Integration 13 Considerations 14 Implementation Roadmap 15 About the Author Excellence. Assured.

2 Introduction Commercial / Industrial Users Consumers Collectors Recycler / Refurbisher THE RECYCLING CHAIN Brokers / Agents Metal Refiners Incineration Landfill Refurbisher Smelters Glass to Glass FINAL DISPOSAL END REFURBISHER END PROCESSORS Each day, vast amounts of electronics are designed, marketed, manufactured, transported, sold, used, discarded and de-manufactured, fueled by rapid advancements in features and functionality. This cycle is most visible in consumer electronics but is also present in the business world, notably Original Equipment Manufacturers (OEMs), leasing organizations, government, etc. As a result, a similarly vast industry has emerged in response to the opportunities that come from demanufacturing or recycling discarded electronics, more commonly known as e-scrap. By one means or another, e-scrap arrives at a recycling facility. It may come through contractual or other arrangements, such as drop-off, collection events, collectors, retailers or municipal programs. Recyclers range from small organizations of less than 10 employees at one site to multi-national recyclers with upwards of 100 employees per site. They are characterized by the types of materials they accept and their de-manufacturing processes and equipment. Commonly received e-scrap includes: - Monitors - Computers - Printers - Servers - Televisions - Cell phones It s common for these items to be gradually demanufactured or refurbished by a series of organizations until the materials have been converted back into a raw material commodity, product or finally disposed. This series of entities is called a Recycling Chain and is represented within the following illustration.

3 3 Recycling Chain The entire recycling chain is primarily driven by two factors 1. The opportunity to generate revenue 2. Interest of upstream organizations in product stewardship. Product stewardship pressures typically manifest in the form of OEMs or retailers mandating specific recycling practices or certifications and government imposing similar requirements through legislation. For example, the US GSA Bulletin FMR B-34 calls for federal agencies to use R2 or equivalently certified recyclers, Pennsylvania and Vermont have regulations requiring R2 or e-stewards certification and the City of San Jose will give preference to e-stewards recyclers. standards is becoming the most practical method of demonstrating the desired product steward practices (e-stewards, R2 and RIOS are standards that will be discussed in greater detail). Certification not only demonstrates product stewardship but goes beyond this, providing opportunities for a wide variety of benefits: Demonstration of EHS due diligence & leadership Competitive advantage and increased revenue Satisfying customers data security needs Improved EHS compliance and relationship with regulatory agencies Lower EHS risks and costs Boost efficiency and effectiveness of practices Employee satisfaction Certification to a variety of electronic recycling Standards Management system standards are sets of best practices addressing administrative and operational areas in an organization. They are written generically enough so that virtually any organization can adapt them to their needs, yet are still precise enough to ensure that the benefits intended from implementing them will materialize. A standard is generally authored and periodically revised by a group of technical experts, under the oversight of the administrator of the standard. For example, the International Organization for Standardization oversees ISO and ISO 9001 through technical committees that extend into countries throughout the world. In the case of the e-scrap standards, technical committees or networks have been established by their oversight bodies. The oversight bodies will then engage an accreditation body to oversee the proper use of the standard. ISO standards such as ISO and ISO 9001 tend to be generic enough that they can be implemented by any organization in the world. Sector specific standards such as e-stewards, R2 and RIOS include requirements adapted for their sector, thus providing greater assistance to the organization implementing it. For example, an electronics recycler implementing ISO would not have specific requirements related to its downstream to follow. The purposes of a standard and the certification that accompanies it are many. Most importantly certification in a standard is intended to assist organizations with maintaining and improving their performance in a specific area to earn credibility with outside stakeholders such as customers, the public and regulatory bodies. To do that, the requirements of the standard must touch upon both the operations that can impact performance as well as the necessary supporting administrative tasks to ensure success.

4 This illustration demonstrates these two main components of a management system operations and administrative support. 4 Commitment & Policy Administrative Support Processes - Responsibilities & Resources EH&S Review Significant EH&S Risks Response to Emergencies - Communication - Documentation - Control of Documents - Evaluation of Compliance Applicable Legal Requirements Monitoring - Internal Audit - NC, CA and PA Continual Imporvement Efforts Operational Controls - Control of Records - Management Review Competence Training Awareness For Significant EH&S Risks, expect to identify issues such as employee exposure to toxins, employee lacerations, segregation of recyclable materials, handling of hazardous or regulated wastes and energy use. For Applicable Legal Requirements, expect to identify local or federal regulations related to universal or hazardous waste, export, worker health and safety, etc. For Continual Improvement Efforts, expect to identify projects such as new equipment layout to reduce ergonomic hazards, new data sanitization software, new shredding equipment, additional downstream vendors and so forth. For Competence, Training and Awareness, expect to put new employees through general company and job specific EH&S training, including on-the-job training. Provide them with an understanding of the management system and periodically re-train them. For Operational Controls, expect to have a maintenance program for your equipment and procedures to define key tasks. For Monitoring, Measurement and Analysis, expect to track your performance through workplace inspections, air sampling, ergonomic studies, mass balance, recycling rates, noise levels, energy usage and so forth. What follows is a discussion of the three primary standards that address e-scrap: e-stewards, R2 and RIOS.

5 5 e-stewards The purpose of e-stewards certification is to identify recyclers and refurbishers that will ensure e-scrap: will not result in toxic materials being exported or dumped in developing world nations will not result in broken down, non-functioning equipment being illegally exported to developing countries will not be incinerated or disposed of in landfills or incinerators will not be processed in a manner that puts the health and safety of recycling workers at risk will not result in your private data being unexpectedly exposed to outsiders will not be processed by prisoners without all the protections and benefits of private sector workers will be managed in compliance with the Basel Convention The standard also ensures worker protection through extensive baseline protections and monitoring of workers and accountability for the entire recycling chain of toxic materials. Use of certified e-stewards recyclers will assist international organizations in partnering with vendors who meet their own corporate sustainability goals. e-stewards includes the provisions of ISO and the R2 Practices of e-stewards Certification is open to electronics recyclers, refurbishers and processors in all developed countries. Development of the Standard e-stewards, also known as e-stewards Standard for Responsible Recycling and Reuse of Electronic Equipment, was created by the Basel Action Network (BAN) with the assistance of the electronic recycling and asset recovery industry, the occupational health and environmental community, and certification and accreditation advisors. The certification program is supported by the EPA, and is endorsed by Greenpeace USA, the Sierra Club, the Natural Resources Defense Council (NRDC), the Electronics TakeBack Coalition, as well as 68 other environmental organizations. The standard is further supported by e-stewards Enterprises who commit to using, whenever possible, recyclers that are audited and certified to the e-stewards Standard Basel Action Network BAN is an environmental watchdog organization concerned about preventing the export of electronic wastes to developing countries. It developed the e-stewards Certification and now manages it with the help of a broad multi-stakeholder group, the e-stewards Leadership Council, which includes representatives from original equipment manufacturers (OEM s), major corporations, recyclers, government, and other environmental groups. Members of the e-stewards Leadership Council represent all e-stewards stakeholders by providing recommendations to BAN in the areas of technical and business issues, policy expertise, marketing and at times and as appropriate, undertake promotional efforts and advocacy. The Council includes three subsidiary bodies: a technical committee, a promotional committee and a membership committee. Eventually, the governance of the program is envisaged to be spun off to a dedicated and separate organization with continued links to BAN and key stakeholders. Current governance activities include requiring recyclers to sign a licensing agreement with BAN prior to certification, listing certified recyclers on their website, maintaining accreditation rules with ANAB and defining additional certification and accreditation requirements for recyclers and certification bodies in an appendix of the standard.

6 6 e-stewards Management Review Act ACT OPERATIONS PLAN Plan Policy Environmental Aspects Legal & Other Requirements Objectives, Targets & Programs Check Monitoring Competence Training Awareness Emergency Preparedness Controls -Reuse/Refurbishment -HPS -Data Security -Hazardous e-waste -Downstream chain -Recovery/Disposition -Export -Site Closure Do Evaluation of Compliance NC, CA & PA Control of Records Internal Audit CHECK DO Resources, roles, responsibility & authority Communication Documentation Control of Documents SUPPORT PROCESSES

7 7 Responsible Recycling (R2) The R2 Standard sets forth requirements relating to environment, public health, worker health and safety, and security aspects of electronics recycling. It also requires recyclers to assure that toxic material streams are managed safely and responsibly by downstream vendors (all the way to final disposition) and prohibits recyclers and their downstream vendors from exporting these more toxic materials to countries that have enacted laws making their import illegal. It is based on the following underlying principles: Serve as a market-oriented mechanism for: o identifying top-performing electronics recyclers and refurbishers - in terms of environmental responsibility, worker health and safety, and data security - throughout the world; o promoting a high level of protection of the environment and human health and safety that does not vary geographically; and o requiring due diligence throughout the recycling chain regarding the management of potentially toxic materials. Require that all trade in end-of-life electronic assets is conducted legally. Maximize the reuse of working equipment and components and the recovery of commodity materials. Provide performance requirements that allow electronics recyclers to innovate and adopt improvements in technology and advances in best practices. Reflect the experience and input of each stakeholder group by revising the Standard in an open, transparent and balanced manner. Development of the R2 Standard The R2 Standard, also known as Responsible Recycling Practices for use in Accredited Certification Programs for Electronics Recyclers, was developed through a fully open multi-year stakeholder public process. Key stakeholders participated throughout its development, and today the standard is administered by R2 Solutions. This provided the R2 Standard with its core strength - it raises the bar for environmental performance substantially while providing some flexibility regarding the steps recyclers take in achieving this bar. Further, R2 Solutions has as a core tenet maintaining transparency and multi-stakeholder participation in sustaining and improving the R2 Standard. R2 seeks to be open and flexible to changes in technology, processing techniques, markets, and legal requirements. This flexibility allows recyclers to be inventive and continuously improve their technology and solutions to recycling. R2 Solutions R2 Solutions is a nonprofit organization formed to administer and promote the R2 Standard. It is responsible for promoting the standard, encouraging electronic recyclers to become certified to R2, educating the public about responsible recycling and providing administrative support to the multistakeholder R2 Technical Advisory Committee (TAC). As a non-profit, R2 Solutions has a governing council and board of directors. This structure allows for transparency, continued industry engagement, and organizational guidance from experts. R2 Certification is open to recyclers, which includes but is not limited to electronic resellers, refurbishers, recyclers, de-manufacturers, asset recovers, brokers, as well as leasing companies that engage in these activities.

8 8 R2 Annual Progress Review Changes to the EHSMS Action Plan for Continual Improvement Act ACT OPERATIONS Emergency Response Management Support PLAN Plan SUPPORT PROCESSES Policy EHS Impacts Legal Requirements E-goals, Objects, Targets Monitor & Track Performance Measurement System Tracking Throughout Check Training and Capability Controls - Reusable Equipment & Components - Reuse/Recover - Onsite EHS - R2 Focus Materials - Data Destruction - Storage - Facility Secuirty - Insurance - Transport Do Correct Problems & Prevent Reccurance Record Keeping Internal Audits CHECK DO Roles, Resposibilities, Resources Communication Documentation Control of Documents R2 Solutions Goals are: Assure open, transparent, and balanced governance of the R2 Standard Educate about responsible recycling practices Promote the use of the R2 Standard Explore opportunities for collaboration in furthering responsible electronics recycling worldwide Central to sustaining the success of R2 is the work of the TAC. The R2 Technical Advisory Committee is responsible for developing and recommending guidance and changes in the R2 Standard to the R2 Board of Directors. It is balanced in its makeup and transparent in its deliberations, providing the opportunity for input and due process to all interested parties. The group is made up of representatives from key stakeholder groups, including: customers of electronic recyclers, recyclers, government, NGOs and certification bodies. This 20-member TAC serves as the cornerstone underlying R2 s credibility and integrity. Other current governance activities include listing certified recyclers on their website, maintaining accreditation rules with ANAB.

9 9 Recycling Industry Operating Standard (RIOS ) The Recycling Industry Operating Standard (RIOS) is the scrap recycling industry s integrated management system standard for quality, environment, and health & safety (QEH&S). RIOS includes the key operational and continual improvement elements that are also found in ISO 9001, ISO 14001, and OHSAS without the redundancies and technical language. Designed for the scrap recycling industry, RIOS provides the framework for a comprehensive, integrated management system to drive continual improvement in QEH&S performance and to achieve superior operational efficiency. When paired with R2, it becomes a QEH&S management system for the electronics recycling industry. RIOS offers electronics recycling companies the vital tools to: Monitor and improve product quality, increasing customer satisfaction and confidence Keep on top of environmental compliance, decreasing environmental risks and costs Improve health & safety practices, reducing health & safety risks and costs Improve relations with your neighbors, legislators, and regulators Ensure continual improvement in your operations, boosting efficiency and profitability Empower your employees to work towards common goals, increasing productivity scrap industry in using the available ISO management system standards and the potential benefits of an integrated QEH&S management system standard designed for them. ISRI Services Corporation (ISC) ISRI Services Corporation, a subsidiary of the Institute for Scrap Recycling Industries, Inc., was established to develop and administer RIOS and RIOS membership. RIOS membership benefits include the RIOS Implementation Guide, which contains the QEH&S Footprint Identification Tool and other continual improvement tools, and the RIOS Internal Auditor Training Materials. The RIOS program is managed with the assistance of the RIOS Committee, which includes member companies, who are also eligible to serve on the RIOS Board. The Committee provides input to the Board on matters related to the RIOS program, guidance documents, certification and administration. The Board is the decision making authority for the RIOS program. Other current governance activities include listing certified recyclers on its website, maintaining its ANAB accreditation rules and associated additional requirements defined in ISC documents and requiring candidates to sign a RIOS member licensing agreement. ISC also supports adoption of RIOS through its own and public training programs. RIOS certification is open to any scrap recycling company who becomes a RIOS member of ISRI. Developing the RIOS Standard Designed exclusively for the scrap recycling industry, RIOS, also known as Recycling Industry Operating Standard, was authored by an environmental consulting firm at the request of ISRI and about 50 RIOS charter members who funded its development. ISRI Services Corporation, a subsidiary of the Institute for Scrap Recycling Industries, Inc., administers RIOS and RIOS membership. ISRI saw the difficulty for the

10 10 RIOS Management Review Act ACT OPERATIONS PLAN Plan Management Structure Resources & Facilities Document & Recordkeeping Policy Environmental Impacts and HS Risks Legal/Product/Other Requirements Improvement Planning Check Monitoring and Measurement - Suppliers - Raw Materials - Equipment Training Emergency Preparedness Operational Controls - Customers - Suppliers - Contractors Do EHS Compliance NC, CA & PA Nonconforming Product Internal Audit CHECK DO Communication Documentation Control of Documents SUPPORT PROCESSES When paired with R2, it becomes a QEH&S management system for the electronics recycling industry. RIOS offers electronics recycling companies the vital tools to: Monitor and improve product quality, increasing customer satisfaction and confidence Keep on top of environmental compliance, decreasing environmental risks and costs Improve health & safety practices, reducing health & safety risks and costs Improve relations with your neighbors, legislators, and regulators Ensure continual improvement in your operations, boosting efficiency and profitability Empower your employees to work towards common goals, increasing productivity Who Can be certified to RIOS? RIOS certification is open to any scrap recycling company who becomes a RIOS member of ISRI.

11 11 Integration SAI Global is a North American and global leader in integrated management system audits. These audits are offered to accommodate the degree of integration of the organization s management system. We conduct parallel audits when the organization has independent management systems i.e. there exist two or more completely separate sets of processes and procedures under the oversight of separate people for each standard. We offer partially integrated audits when there is one set of administrative support processes for multiple management systems. When all processes within an organization are organized to manage the requirements of each standard simultaneously, then we conduct a fully integrated audit. Benefits of Integrated Audits Integration can be an efficient use of resources, promote sharing of best practices, and in many cases can be less expensive. Referring back to the illustration of a common EH&S management system, you will see the supporting administrative components extracted. As can be expected by the previous discussion, these requirements tend to be replicated in most management systems. As a result, most organizations tend to create single processes for Roles, responsibilities and resources Communication Documentation Control of documentation Evaluation of compliance Non-conformance, corrective and preventive action Records Internal audit Management review and apply them to the requirements of each of the implemented management systems. The benefit to the organization is a single set of best practices for a particular activity, resulting in an integrated system. There are also sometimes opportunities to integrate the operational areas of the different systems. Generally the optimal approach is to create a single process or procedure for a particular activity and then enhance it to cover all the requirements for each standard. For example, Policy EHS Risks/Impacts/Hazards Legal requirements Improvement Training/Competence/Capability EHS Controls Emergency Preparedness Monitoring and measurement Note that a discussion of the differences, sometimes subtle, between the requirements of the above become rapidly out-dated because the standards are rapidly evolving in terms of revisions and clarifications.

12 12 Integration Management Review Act ACT OPERATIONS PLAN Plan Policy EHS Experts/ Hazards/ Risks Legal Requirements Improvement Monitoring and Measurement Training, Competence/ Capability Emergency Preparedness EHS Controls Check Do CHECK Evaluation of Compliance NC, CA & PA Records Internal Audit DO Resources, Roles, Resposibilities Communication Documentation Control of Documents SUPPORT PROCESSES

13 Considerations 13 Considerations and Reasons to Certify to an E-scrap Management System Standard Many organizations are certifying to e-stewards and R2 while the most ambitious ones are striving and earning certification to RIOS, ISO 14001, OSHAS and ISO 9001 as well. While this may seem excessive, the unique business environment of each organization may make this approach a necessity, although certification decisions are not always driven entirely by external factors. Business models, company culture and personal beliefs related to continual improvement, equity and effective EH&S outcomes may direct an organization to one certification or another. SAI Global has seen how organizations decide: Product Stewardship: Awareness of the EH&S impacts of improper recycling or disposal of e-scrap and recognition that these standards are excellent tools to minimize impacts. Benefits of Certification: Organizations that already have one certification see the value derived from the relationship with their auditors who assess adherence to their own processes and share opportunities for improvement. Business Model: The requirements of one of the available standards may align best with the current business model, if it has been assessed as successful and sustainable. Customer Mandate: A customer requires a particular certification as a condition for business. This mandate may come in the form of a communication from an existing customer who has adopted this new criterion as part of their supplier management program or it may be incorporated into an RFP or Tender for new business. For example, a GSA Bulletin calls for federal agencies to use R2 or equivalently certified recyclers. Regulatory Mandate: Many jurisdictions have some form of e-scrap law in place. The specifics are a mixed bag, with about 20 states having enacted or drafted laws that call for e-stewards, R2 or ISO certification for e-scrap recyclers. Continual Improvement: The commitment to continual improvement is at the core of these management system standards. The structure of the certification with its requirements to set goals, control operations, monitor performance, assess performance and act on performance under an external audit program places the organization in a great position for continual improvement.

14 14 Implementation Roadmap The team involved on the path to certification are critical to the success of an organizations efforts in achieving certification. The SAI Global team typically consists of: Business Development Manager (BDM) Regional Account Representative (RAR) Lead Auditor (LA) SAI Global e-scrap Expert The BDM will likely be the first point of contact and will learn the key details of a business through conversations and a questionnaire before issuing a proposal that fully explains the details of certification. The proposal will account for the materials processed, how to process them and the size of an organizations operations and downstream. Once the proposal has been accepted, a RAR will be appointed. The RAR will handle scheduling, changes, technical assistance and so forth, they will then introduce the Lead Auditor who will become the prime contact. Auditors are a wealth of information on best practices. The assigned auditor will be the key player in the road to continual improvement. He or she will be in touch with an organization internal audit team during the planning for each audit to get updated on changes within an organization and share updates and answer any questions during the audit, formal meetings, debriefings, or at other times throughout the year. An organizations early effort in achieving certification will focus on strategic planning and gaining knowledge of the standard. Learning about the available standards, how their differences could affect operations and how they will be perceived by customers and regulators. The best sources of information will be your certification body (SAI Global), the owners of the standards, the standard itself, consultants and the marketplace. At the same time, key decisions will need to be made on the design of the e-scrap management system. Structurally decisions such as, who does what, which is especially important if there is more than one location. Many multi-site recyclers will centralize key functions at one location and roll out virtual cookie cutter processes to the satellite locations. The objective of the e-scrap management system must also be decided in order to design and resource it appropriately. For instance, the main objective could be to earn a new major customer, improve internal processes, gain better control over a rapidly expanding organization or improved EH&S compliance. If other certifications exist, an advantage would be to consider how to integrate these systems and maximize the use of best practices throughout the organization. With the key groundwork laid, an organization will then be in a position to layout a successful project plan that identifies operational and administrative gaps with the chosen standard, development of the required new or modified activities and rollout of the changes. At about this time, your certification bodies (SAI Global) involvement will become more visible through: Optional preliminary assessment for early identification of gaps with the standard Documentation review of your procedures against the requirements of the standard Onsite evaluation of your readiness for certification Certification audit Presentation of your Certificate and Annual or semi-annual surveillance audits.

15 15 About the Author John Fraser Technical Manager Environment John Fraser is a veteran of the industry. He is SAI Global s Technical Manager for the e-scrap standards, as well as ISO 14001, RC14001, RCMS, GHGs and ISO As a result, he has great insight into the development and direction of standards through his involvement on the technical committees charged with writing and updating them and through his consultation to the owners of them. He is also a lead auditor for eight programs. SAI Global can be instrumental in the success of your Environmental Management System (EMS) including ISO 14001, e-stewards and R2 and RIOS programs. SAI Global auditors are trained, capable and motivated to bring value and credibility to your EH&S management system, while assessing its conformity to the standard. SAI Global also routinely offers integrated environmental, quality and health and safety audits. SAI Global is a global leader in Environmental Management System programs committed to exceptional customer service and advancing business excellence.

16 SAI Global helps organizations manage risk, achieve certification and drive improvement by providing training, registration audits, and supplier management programs that can improve business performance. With more than 800 auditors and 24,000 registrations worldwide, we are a global leader committed to exceptional customer service and advancing business excellence. We re focused not only on evaluating business practices against a standard, but also on understanding how compliance with those standards can improve the operations of our customers. SAI Global auditors are industry veterans with years of experience in the sectors they serve, enabling them to interpret the standards precisely. For more information about e-scrap programs, contact SAI Global at certification.americas@saiglobal.com or visit / Excellence. Assured.