Electronics Recycling EMS - Case Study of System Development

Transcription

1 Electronics Recycling EMS - Case Study of System Development Dwight Clark, CHMM Ninyo & Moore Presenter Dwight Clark is an Environmental Engineer and Certified Hazardous Materials Manager with over 25 years of experience in a wide array of environmental projects. He is the National Lead for Ninyo & Moore s Compliance Practice Sector and the Environmental Group Manager in Arizona. Dwight is as an ISO Lead Auditor as well as an auditor to the Responsible Recycling, e- Stewards, and Recycling Industry Operating Standards (RIOS) certification programs. Basics Electronic waste (e-waste) is a term that is used loosely to refer to obsolete, broken, or irreparable electronic devices like televisions, computer central processing units (CPUs), computer monitors (flat screen and cathode ray tubes), laptops, printers, scanners, and associated wiring. E-waste has become a concern in the United States due to the high volumes in which it is generated, the hazardous constituents it often contains (such as lead, mercury, and chromium), and the lack of regulations applicable to its disposal or recycling. "What is in a Computer?" Rekacewicz, P. (2004) Vital Waste Graphics [map]. maps.grida.no/ go/graphic/ what_is_in_a_ computer

2 A RECYCLING NIGHTMARE The Problem Discarded electronics is one of the fastest growing segments of our nation s waste stream, already accounting for 5% of the total waste volume. Researchers estimate an additional 75% of old electronics are stuck in storage, in part because consumers don t know what to do with them. If properly handled; these materials pose little risk and can be recycled or reused safely. AN ELECTRONICS REYCLING FACILITY

3 Situation A new electronics recycler wishes to come into the marketplace The facility wishes to focus on the largest stream in the e-scrap world, CRT glass Facility realizes those before them have tainted the regulators view of e-scrap facilities Facility wants to use Third Party Certification to mitigate client concerns CRTs in Storage Mountains of CRT Glass

4 Storage Awaiting Processing Facility Basics Developed to process CRT glass under CRT rule exemptions from solid waste definition Anticipated employment 60 persons Anticipated volume 12,500 tons per month Long term goal to start up new lead removal process to remove lead from glass. Yielding saleable lead and glass. Task Develop a World Class EMS for an E-Scrap Facility while developing the facility from the ground up Supported by COO whom had over 15 years of recycling experience and had developed 5 other e-scrap facilities Consensus standards for e-scrap specific facilities; Responsible Recycling (R2) and e-stewards both finalized about days prior to project Mitigate Client and Regulator concerns over CERCLA and RCRA issues

5 R2 and e-stewards Standards Responsible Recycling (R2) and e-stewards These standards are similar in nature to ISO certification through a Certifying Body Responsible Recycling At a multi-stakeholder electronics summit in 2005, EPA was asked 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 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

6 R2 Features 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. e-stewards Practices and Features Requires a certified environmental management system Prohibits all toxic waste from being disposed of in solid waste landfills and incinerators Requires full compliance with existing international hazardous waste treaties for exports and imports of electronics scrap Prohibits the use of prison labor Requires extensive protections for and monitoring of workers Is written for international use ISO Certifications and RIOS ISO 14001, ISO 9001, and OSHAS are helpful, but may be too costly for smaller recyclers. The Institute of Scrap Recycling Industry (ISRI) has developed an industry specific Quality, Environmental, and Health and Safety (QEH&S) Framework (management system) the is called the Recycling Industry Operating Standard (RIOS). This system is comparable (or a light version of) to a combined 14001, 9001, and system.

7 The Plan Develop framework of EMS while building the Facility Meet ISO 14001, OSHAS 18001, R2, and e- stewards in one integrated management system Roll out EMS with staff during initial training phase of startup Initial Criteria for Development All operations and storage interior to building No water in operations Glass breaking on downdraft tables with HEPA Filter Plant operators in Level C with full tyvek suit Initial Development Unloading and Glass Breaking in isolated room Storage of incoming and processed glass in containers

8 Significant Aspects and Hazards Lead dust Glass breaking operations above PEL Employee blood lead elevated 250% in one year still below action levels Significant cut hazards Internal record 35 stitches in one cut 16 recordable in first two weeks Aspects and Hazards Forklifts Lifting and Handling Air Emissions Conveyor belts Shredder PPE Wastes Issues Difficult to identify Aspects, Impacts, and Hazards when no facility Start up operations are difficult to manage change Staff retention mitigated initial training almost immediately 90% turn over in first three months

9 Issues Along the way the scope was reduced to meet only R2 and RIOS based on costs of certification Lack of experienced EHS Manager on staff prevented implementation for first nine months Observations If developing an EMS of any sort without a facility, hire an experienced EHS manager (preferably a CHMM) prior to starting EMS development Have a solid understanding of the facility design and the physical duties prior to EMS development Observations Multiple layers of standards make application of prior work very difficult Management of Change if imperative, use qualified staff to review Management Team / Management Review should be conducted more often

10 Results Facility is on track for certification in fourth quarter 2011 Facility receives rave reviews for best Management System regularly by auditors (downstream audits by clients) Facility passed first regulatory inspection with minor comments