environmental systems - pjcinc.com · this booklet was created to promote awareness ... audit to...

AN EXECUTIVE OVERVIEW

CPJPERRY JOHNSONC O N S U L T I N G , I N C .

www.pjcinc.com 1-888-248-0256•

Environmental Systems

ISO 14000, R2 AND RIOS

ENVIRONMENTAL

MANAGEMENT SYSTEMS

The Groundwork For

Environmental Management

ISO 14001:2004

R2-RIOS (With Additional Guidance on REACH and RoHS)

An Executive Overview

Revised 03/13

PERRY JOHNSON CONSULTING, INC.

Detroit

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© Copyright 2013 by PERRY JOHNSON CONSULTING, INC.

All rights reserved. No part of this book may be reproduced in any form or by

any means without permission, in writing, from Perry Johnson Consulting, Inc.

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EMS Executive Overview Page 1 3/13

ENVIRONMENTAL

MANAGEMENT SYSTEMS

The Groundwork For

Environmental Management

AN EXECUTIVE OVERVIEW

CONTENTS

FOREWORD..................................................................................................................................2

MANAGEMENT SYSTEMS ........................................................................................................3

THE USERS OF THIS GUIDE ....................................................................................................3

MANAGEMENT SYSTEM REGISTRATION ..........................................................................4

Key Steps to Completing Registration .................................................................................5

What to Look For in a Registrar ..........................................................................................6

What to Look For in an Auditor ..........................................................................................6

PART I – ISO 14001:2004

WHAT IS ISO 14000? ...................................................................................................................7

The Origin of ISO 14000 ........................................................................................................8

ISO 14000 Series Standards....................................................................................................9

ISO 14000 Components ........................................................................................................11

Implementing an Environmental Management System ........................................................15

Meeting Environmental Auditing Requirements ..................................................................16

THE BENEFITS OF ISO 14000 .................................................................................................18

ISO 14001 ENVIRONMENTAL MANAGEMENT SYSTEM REQUIREMENTS ..............20

PART II – RESPONSIBLE RECYCLING (R2).......................................................................28

The History of R2 .................................................................................................................29

Integration & Comparison with ISO 9001 and ISO 14001...................................................31

Additional Rules and Requirements .....................................................................................34

The R2 Practices ...................................................................................................................36

PART III - RIOS ..........................................................................................................................47

RIOS Certification ...............................................................................................................49

The RIOS Standard ...............................................................................................................51

PART IV – RoHS AND REACH ................................................................................................59

RoHS ....................................................................................................................................59

REACH .................................................................................................................................62

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FOREWARD

Management System standards define generic and/or industry specific requirements necessary to

ensure the consistency of management requirements for various organizations all over the world.

The ISO 14000 series and other standards covered in this executive overview have positive

impacts on companies in industrialized nations spanning our global community. These standards

ensure environmental, quality, health and safety management responsibilities are addressed by

top management. The people with the greatest influence over company policies and procedures

also have the flexibility and freedom to define methods for implementing management system

requirements. Once a company decides to control the processes related to the scope of activities

performed, it can establish targets and objectives for achieving identified management system

goals.

Management system standards have made a tremendous impact in the global community, as they

outline methods for companies to manage their various activities. While management system

requirements are intended to be voluntary, some government agencies may require registration to

various standards or other related requirements commensurate with those defined within

applicable standards. As a result, organizations that do not implement effective management

systems may diminish their ability to compete in various markets, such as the European Union

(EU), where registration to some standards is required by governing states or other entities.

Marketing advantages, government mandates, benefits derived from strategic planning and the

growing interest of other public entities represent a basis for justifying the implementation and

maintenance of an effective management system(s).

The adoption of management system requirements provides enumerative benefits to various

interested parties. Interested parties can be represented by customers, stake holders, employees,

suppliers and members of communities affected by the scope of activities performed as well as

products and services delivered by organizations.

This booklet was created to promote awareness necessary for organizations to provide superior

products and services to customers while embracing a philosophy of environmental

responsibility and the provision of a safe and healthy work environment for employees. This

manual provides an overview of the intent and content of management system and other

standards addressed, including detailed descriptions of the standards, related requirements,

objectives and the implementation process that assists organizations in accomplishing their goals

and objectives.

Because management system registration is a lengthy and detailed process, it is strongly

suggested that organizations seeking registration retain the services of a reputable consulting

firm.

PERRY JOHNSON CONSULTING, INC.

March 2013

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MANAGEMENT SYSTEMS

This executive overview manual was originally created to provide general information and

guidance to accommodate requirements for ISO 14001:2004 Environmental Management

Systems. Since the initial release of this manual, industry specific environmental and other

management system standards have been released to address a broader range of environmental,

occupational health and safety, quality and other requirements applicable to subscribing

industries.

This version of The Groundwork For Environmental Management Manual has been expanded to

include additional industry specific requirements included in the Recycling Industry Operating

(RIOS) Standard adopted by the recycling industry (ISRI) and the Responsible Recycling (R2)

Standard sponsored by the United States Environmental Protection Agency (EPA).

THE USERS OF THIS GUIDE

Because management system requirements are adopted to support universal applications, this

guide can be used by various organizations, and tailored to meet business or industry specific

requirements appropriate for the scope of work performed. The use of this guide and the

information contained herein is unlimited.

Information contained within this guide is not limited to environmental management, but also

places additional emphasis on health, safety, legal compliance and quality management

requirements.

Environmental Management Systems (EMS) and other standards affect almost everyone, from

companies that manufacture products or provide services to individuals who are concerned about

the environment. The principles of these standards extend well beyond business and industry,

and are applicable to the readers and producers of this guide.

Various challenges are associated with an organization’s activities, the processes it engages in,

and the products and services it produces. Each activity can have an impact on the environment,

health and safety and quality in varying degrees. An organization seeking to control

environmental aspects and impacts through its EMS must identify them and implement

procedures to deal with these situations.

Business suppliers should also take note of this guide. Some companies have mandated that their

suppliers become registered to applicable management system requirements is addition to

complying with other related requirements.

The Environmental Protection Agency (EPA) has contributed extensively to the development of

ISO 14000, and its representatives have suggested that ISO 14001 registration is likely to reduce

the need for multiple environmental audits in the future. The Recycling Industry Operating

Standard (RIOS) and the Responsible Recycling (R2) Standard have extended requirements

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beyond those of ISO 14001:2004 in order to integrate quality, health and safety and

environmental requirements into common standards intended to maximize the benefits for the

scrap metal and electronics recycling industries.

This manual also provides additional guidance on the Restriction of Hazardous Substance

Directive (RoHS) and Registration, Evaluation, Authorization and Restriction of Chemicals

(REACH) Standards for organizations that are required to comply with regulatory requirements

defined within and complimentary to these standards.

MANAGEMENT SYSTEM REGISTRATION

Management system registration is a tangible expression of an organization’s commitment to

satisfying the needs of customers and other interested parties applicable to the management

system requirements defined. ISO 14001 defines environmental requirements that are suitable

for industries of any type and size. RIOS applies to the scrap metal recycling industry while R2

is tailored to meet the needs of organizations involved in processing and recycling used

electronics. RoHS and REACH are compliance standards adopted by the European Union (EU)

to control and manage chemicals in different states to better manage the environment and ensure

the health and safety of persons or communities in which such chemicals are used or transported.

The process necessary to achieve registration is described below as applicable to ISO 14001 and

is outlined briefly for different management system requirements throughout the text of this

manual.

Management Systems provide formal requirements to help organizations manage environmental

aspects and impacts applicable to the scope of activities performed. ISO 14001 is understood

and accepted globally.

There are a variety of reasons for seeking ISO 14001 registration. These include customer

mandates, a competitive advantage through reduced energy costs and improved efficiency,

cutting liability and regulatory compliance costs, and increased community goodwill from

preventing pollution and reducing waste.

ISO 14001 registration is carried out by registrars, accredited organizations that review the

facility’s environmental policy and other documentation during the Stage 1 (desktop) audit to

ensure that they meet the standard, and examine the firm’s processes during the Stage 2

(registration) audit to ensure that the EMS described in the documentation is in place and is

effective. Once registration is obtained, the registrar conducts regular surveillance audits of the

facility to determine if its EMS continues to meet the standard’s requirements.

As it typically takes 6 to 18 months to complete the ISO 14000 registration process,

organizations are advised not to put off registration for too long.

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Key Steps to Completing Registration

Before an organization can be considered for registration, several preliminary steps must be

taken:

1) The first step is to implement an EMS that meets ISO 14001 requirements.

2) To qualify for registration, it’s not enough to just conform to the standard. An environmental

policy must be created which stipulates a facility’s environmental commitments, procedures

and practices. This document plays a vital role in the registration process. Because the

policy is the principal document used during an audit, it must be a true reflection of the

facility’s EMS. The policy must also address, point by point, all ISO 14001 requirements.

3) The facility’s EMS must be in operation for a minimum of three to six months so that

employees are familiar with it and an evidentiary trail of documents has been created for

auditors to review.

After successfully completing the preliminary steps, a relationship must be established with a

registrar. The registrar’s job is to verify whether an organization’s EMS has been properly

implemented and conforms to ISO 14001 and any other applicable requirements.

Once the services of an accredited registrar have been obtained, a formal application must be

filed. When all of the paperwork has been submitted, the registrar examines the facility’s

environmental policy and other documentation during the Stage 1 (desktop) audit. After the

registrar has verified that the policy and other documentation satisfactorily reflect the

organization’s EMS and meet all ISO 14001 requirements, and any nonconformities have been

corrected, the on-site Stage 2 (registration) audit of the organization’s facility is scheduled.

During the Stage 2 audit, the registrar’s auditor interviews employees, reviews records, and

performs a detailed inspection of the facility’s EMS and procedures. The purpose of the audit is

to ensure that the facility’s EMS is functioning adequately and conforms to all ISO 14001

requirements.

Afterward, the registrar reports its findings in an audit report. If any nonconformities were found,

the organization (or auditee) must take corrective action to remedy them within a set time frame,

determined by the registrar. Once the registrar has closed out all outstanding nonconformities, a

registration certificate is issued.

The standard validity of a registration certificate is three years, after which a full re-audit is done

for renewal. To ensure that organizations are following ISO 14001 requirements after

registration is obtained, the registrar conducts on-site surveillance audits two times a year.

Remember: In order to achieve registration to ISO 14001, the organization must completely

embrace the standard, which focuses on performance, documentation and objective evidence.

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What to Look For in a Registrar

In selecting a registrar, it is extremely important for every organization to be aware of the

relevant qualifications.

A registrar must:

• Be accredited by a national accreditation body, such as the ANSI-ASQ Accreditation Board

(ANAB), the Raad voor Accreditatie (RvA) of the Netherlands, the United Kingdom

Accreditation Service (UKAS), or the Japan Accreditation Board for Conformity Assessment

(JAB) among others.

• Maintain a listing of its ISO 14000 qualified auditors;

• Have personnel on its executive (registration) committee or governing board with

environmental experience and expertise; and,

• Conform to ISO/IEC 17021:2011, Conformity assessment – Requirements for bodies

providing audit and certification of management systems.

What to Look For in an Auditor

Requirements have been established for the auditors working for accredited ISO 14000

registrars. Before an auditor can evaluate an organization’s facility to verify whether its EMS

conforms to ISO 14001 requirements, the auditor must satisfy the following conditions:

1) Auditors working for or on behalf of registrars must have satisfactorily completed ISO 14000

training courses and demonstrated their knowledge of ISO 14001 by passing an exam. A

certificate is awarded to those auditors who have successfully completed this training;

2) Auditors must comply with ISO/IEC 17021:2011, Conformity Assessment – Requirements

for Bodies Providing Audit and Certification of Management Systems; and,

3) They must be recognized and qualified as ISO 14000 auditors under the registrar’s criteria.

Before hiring the services of a registrar, it’s a good idea to make sure the registrar and its

auditors have met the above qualifications.

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PART 1 – ISO 14001:2004

WHAT IS ISO 14000?

ISO 14000 is a series of generic environmental management systems (EMS) standards created by

the International Organization for Standardization (ISO), a federation of 132 national standards

bodies based in Geneva, Switzerland. The American National Standards Institute (ANSI) is the

member body representing the United States. The goal of these standards is to give top

management of any organization a framework for managing its environmental aspects and

impacts.

An environmental aspect is defined by ISO 14001 Section 3.6 as an “element of an

organization’s activities, products or services that can interact with the environment.” ISO

14001 Section 3.7 defines an environmental impact as “any change in the environment, whether

adverse or beneficial, wholly or partially resulting from an organization’s environmental

aspects.”

The ISO 14000 series of standards attempts to harmonize environmental management activities

for industries all over the world. The series promotes a common approach to environmental

management that can be used by any organization, of any size, anywhere in the world.

These standards are divided into two classifications:

• Organization Evaluation

• Product and Service Evaluation

Organization Evaluation, in turn, consists of three components:

• Environmental Management Systems (EMS)

• Environmental Auditing

• Environmental Performance Evaluations (EPE)

Product and Service Evaluation also consists of three components:

• Environmental Labeling

• Life-Cycle Assessment (LCA)

• Environmental Aspects in Product Standards (EAPS)

The most important ISO 14000 standard, and the key member of the EMS component, is ISO

14001:2004, Environmental Management Systems – Requirements with Guidance for Use. This

standard sets EMS requirements to which an organization must conform, and is the single

standard within the ISO 14000 series to which an organization may become registered.

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All other ISO 14000 standards are guidance documents and technical reports, assisting an

organization in developing its EMS. These standards contain recommendations that

organizations may use to clarify or go beyond ISO 14001 requirements. Additional requirements

for R2/RIOS, RoHS and REACH are specified within applicable sections of this Executive

Overview document.

The Origin of ISO 14000

The international environmental movement that developed in the 1960s spurred environmental

legislation around the globe during the 1970s, with the strongest regulations in industrialized

nations. Regulatory compliance proved costly for many companies, with environmental

improvements sometimes falling short of expectations. Attempts by some industries to police

themselves failed to establish a viable and credible worldwide consensus.

ISO, which had released the ISO 9000 quality management systems standards in 1987, stepped

into the breach to create a voluntary global approach to environmental management. In 1991,

ISO established the Strategic Advisory Group on the Environment (SAGE) to research the need

for international environmental standardization. In addition to its ISO responsibilities, SAGE

was a major contributor to the 1992 United Nations Earth Summit in Rio de Janeiro, Brazil,

particularly in adopting a commitment to sustainable development.

At the same time, the British Standards Institution (BSI) released BS 7750, Environmental

Management Systems, the first EMS standard. BS 7750 stressed overall environmental systems

performance, with mandatory audits to confirm and maintain a company’s conformity and

registration to the standard. The European Union (EU) followed with its Eco-Management Audit

Scheme (EMAS), which contained similar requirements.

In light of these developments, SAGE recommended developing an international series of EMS

standards, and ISO established Technical Committee (TC) 207, Environmental Management, to

carry out this work. Both BS 7750 and EMAS were influential in developing the ISO 14000

standards.

In 1996, the first five ISO 14000 standards were released. They were ISO 14001; the guidance

document ISO 14004:1996, Environmental Management Systems – General Guidelines on

Principles, Systems and Supporting Techniques; and three auditing standards: ISO 14010:1996,

Guidelines for Environmental Auditing – General Principles, ISO 14011:1996, Guidelines for

Environmental Auditing – Audit Procedures – Auditing of Environmental Management Systems,

and ISO 14012:1996, Guidelines for Environmental Auditing – Qualification Criteria for

Environmental Auditors.

ISO/TC 207 has continued its work, releasing and revising ISO 14000 standards, guidance

documents and technical reports, some of which are still in draft status as of this writing.

The revised second edition of ISO 14001 was released in 2004, (ISO 14001:2004) and clarifies

various requirements specified within the first edition. Additional consideration has been given

to the requirements of ISO 9001:2000 (now ISO 9001:2008) to ensure consistency between the

standards to support a more uniform approach.

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The sub-clause numbers in Clause 4 and in Annex A now correspond to support ease of use.

Annex B now identifies broad technical relationships between ISO 14001:2004 and ISO

9001:2000(8). ISO 14001:2004 describes the requirements for an organization's environmental

management system that can be used to support certification/registration and/or self-declaration

of the organization’s environmental management system.

ISO 14004 was also revised to ISO 14001:2004 and is intended to serve as a non-certifiable

guideline intended to provide strategic assistance organizations wishing to establish, implement

or improve an existing environmental management system.

ISO 14000 Series Standards

Organization Evaluation Standards

ISO 14001:2004 Environmental Management Systems – Specification with Guidance for Use

ISO 14004:2004 Environmental Management Systems – General Guidelines on Principles, Systems

and Supporting Techniques

ISO 14015:2001 Environmental Management – Environmental Assessment of Sites and

Organizations (EASO)

ISO 14031:1999 Environmental Management – Environmental Performance Evaluation – Guidelines

ISO/TR 14033:2012 Environmental management – Quantitative environmental information –

Guidelines and examples

ISO 14050:2009, Environmental Management – Vocabulary

ISO 19011:2011 Guidelines for Auditing Management Systems

ISO/IEC Guide 66:1999 General Requirements for Bodies Operating Assessment and

Certification/Registration of Environmental Management Systems (EMS)

Product and Service Evaluation Standards

ISO 14020:2000 Environmental Labels and Declarations – General Principles

ISO 14021:1999, Amd 2011, Environmental Labels and Declarations – Self-Declared Environmental

Claims (Type II Environmental Labeling)

ISO 14024:1999 Environmental Labels and Declarations – Type I Environmental Labeling –

Principles and Procedures

ISO/TR 14025:2006 Environmental Labels and Declarations – Type III Environmental Declarations

ISO 14040:2006 Environmental Management – Life Cycle Assessment – Principles and Framework

ISO 14044:2006 Environmental management – Life cycle assessment – Requirements and guidelines

ISO 14045:2012, Environmental management – Eco-efficiency assessment of product

systems – Principles, requirements and guidelines

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ISO/TR 14047:2012 Environmental management – Life cycle assessment – Illustrative examples on

how to apply ISO 14044 to impact assessment situations

ISO/TS 14048:2002 Environmental Management – Life Cycle Assessment – Data Documentation

Format

ISO/TR 14049:2012 Environmental management – Life cycle assessment – Illustrative examples on

how to apply ISO 14044 to goal and scope definition and inventory analysis

ISO/TR 14062:2002 Environmental Management – Integrating Environmental Aspects Into Product

Design and Development

ISO 14063:2006 Environmental management – Environmental communication – Guidelines and

examples

ISO 14064-1:2006 Greenhouse gases – Part 1: Specification with guidance at the organization level

for quantification and reporting of greenhouse gas emissions and removals

ISO 14064-2:2006 Greenhouse gases – Part 2: Specification with guidance at the project level for

quantification, monitoring and reporting of greenhouse gas emission reductions or removal

enhancements

ISO 14064-3:2006 Greenhouse gases – Part 3: Specification with guidance for the validation and

verification of greenhouse gas assertions

ISO 14063:2006 Environmental management – Environmental communication – Guidelines and

examples

ISO Guide 64:2008 Guide for addressing environmental issues in product standards

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ISO 14000 Components

The ISO 14000 series of standards, organized into two classifications and six components.

Organization Evaluation Standards

Environmental Management Systems (EMS)

Environmental Management Systems (EMS) is the entire environmental program planned by an

organization. ISO 14001 Section 3.8 defines an EMS as “the part of an organization’s

management system used to develop and implement its environmental policy (3.11) and manage

environmental aspects (3.6).”

The overall intentions of an organization related to its environmental performance must be

documented in an environmental policy, along with other necessary documents, such as an

environmental manual. These documents must define the EMS in detail and clearly state the

organization’s environmental objectives and targets.

The environmental policy is defined by ISO 14001 Section 3.11 as an “overall intentions and

direction of an organization (3.16) related to its environmental performance (3.10) as formally

expressed by top management.” ISO 14001 Section 3.9 defines an environmental objective as an

“overall environmental goal, consistent with the environmental policy (3.11), that an

organization sets itself to achieve.” An environmental target is defined by ISO 14001 Section

3.12 as a “detailed performance requirement, applicable to the organization or parts thereof, that

arises from the environmental objectives and that needs to be set and met in order to achieve

those objectives.”

EMS standards are:

• ISO 14001:2004, Environmental Management Systems – Requirements with Guidance for

Use, which specifies EMS requirements that seek confirmation for self-declaration or

registration purposes.

• ISO 14004:2004, Environmental Management Systems – General Guidelines on Principles,

Systems and Support Techniques, which provides guidance to help an organization establish,

implement, maintain and improve an EMS, including guidance that goes beyond ISO 14001

requirements.

• ISO 14050:2009, Environmental Management – Vocabulary, which helps an organization

understand the terms and definitions used in the ISO 14000 series standards.

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Environmental Auditing

The ISO 14000 series relies heavily on auditing to ensure that ISO 14001 requirements are being

met. ISO 14001 mandates audits, with Element 4.5.4 stating, “The organization shall establish

and maintain (a) program(s) and procedures for periodic environmental management system

audits to be carried out.” Both internal and external audits are used to ensure conformity to ISO

14001, and can be of great benefit to a facility.

Environmental Auditing standards are:

• ISO 19011:2011, Guidelines for Auditing Management Systems, which provides guidance on

auditing principles, audit program management, the conduct of management system audits

and auditor competence. More detail on this support document appears in the section on

Meeting Environmental Auditing Requirements.

• ISO 14015:2001, Environmental Management – Environmental Assessment of Sites and

Organizations (EASO), which helps an organization to identify and assess the environmental

aspects and associated business consequences of sites and organizations to support the

transfer of properties, responsibilities and obligations from one party to another.

• ISO/IEC Guide 66:1999, General Requirements for Bodies Operating Assessment and

Certification/Registration of Environmental Management Systems (EMS), which sets

operational requirements for ISO 14000 registrars.

Environmental Performance Evaluation (EPE)

Once an EMS is implemented, its performance must be evaluated for effectiveness. The

Environmental Performance Evaluation (EPE) should be conducted by front-line employees who

continually monitor the production process to ensure that environmental requirements are being

met.

EPE standards are:

• ISO 14031:1999, Environmental Management – Environmental Performance Evaluation –

Guidelines, which provides guidance on selecting and using indicators to evaluate an

organization’s environmental performance.

• ISO/TR 14033:2012, Environmental Management – Quantitative Environmental Information

- Guidelines and Examples, which provides guidelines on how to acquire quantitative

environmental information and data and implement methodology.

• ISO 14063:2006, Environmental Management – Environmental Communications –

Guidelines and Examples, provides guidance on communication of an organization’s

environmental aspects and performance.

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Product and Service Evaluation Standards

Environmental Labeling

Many companies use environmental claims as a marketing tool for their products and services.

With ISO 14001 registration providing a similar labeling opportunity, these support documents

seek to prevent unwarranted claims, ensure that environmental claims are accurate and verifiable,

and set standards for the three types of environmental labels. These labeling categories are:

• Type I – Third-party certified labels

• Type II – Self-declared labels

• Type III – Product information claims based on life cycle inventory data

Environmental Labeling standards are:

• ISO 14020:2000, Environmental Labels and Declarations – General Principles, which

provides general principles for developing ISO guidelines and standards on environmental

claims and declarations.

• ISO 14021:1999, Amd 2011, Environmental Labels and Declarations – Self-Declared

Environmental Claims (Type II Environmental Labeling), which provides guidance on the

terminology, symbols, and testing and verification methodologies an organization should use

for self-declaring the environmental aspects of its products and services.

• ISO 14024:1999, Environmental Labels and Declarations – Type I Environmental Labeling –

Principles and Procedures, which provides the guiding principles and procedures for third-

party environmental labeling certification programs.

• ISO/TR 14025:2006, Environmental Labels and Declarations – Type III Environmental

Declarations, which identifies and describes elements and issues to be considered when

making quantified product information declarations based on life cycle inventory data.

Life Cycle Assessment (LCA)

Several support documents provide life cycle assessment study guidance. These standards

describe how to conduct a study of the environmental performance of a company’s products,

including inventory analysis, impact assessment and interpretation.

LCA standards are:

• ISO 14040:2006, Environmental Management – Life Cycle Assessment – Principles and

Framework, which provides the general principles, framework and methodological

requirements for the LCA of products and services.

• ISO 14044:2006, Environmental Management – Life cycle Assessment – Requirements and Guidelines, specifies requirements and provides guidelines for LCA.

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• ISO 14045:2012, Environmental management – Eco-efficiency assessment of product systems – Principles, requirements and guidelines.

• ISO/TR 14047:2012, Environmental Management – Life Cycle Assessment – Examples of

Application of ISO 14044, provides examples that illustrate current practice of life cycle impact assessment according to ISO 14044:2006.

• ISO/TS 14048:2002, Environmental Management – Life Cycle Assessment – Data

Documentation Format, which provides information regarding the formatting of data to support an LCA.

• ISO/TR 14049:2012, Environmental Management – Life Cycle Assessment – Illustrative

examples on how to apply ISO 14044 to impact assessment situations, which provides examples to illustrate how to apply the guidance in ISO 14044.

Environmental Aspects in Product Standards (EAPS)

Guidelines for environmental aspects in product standards recognize the potential effects of products on the environment, and recommend consideration of environmental aspects in developing future products and product standards. EAPS standards are: • ISO/TR 14062:2002, Environmental Management – Integrating Environmental Aspects Into

Product Design and Development, which provides concepts and current practices for integrating environmental aspects into product design and development.

• ISO Guide 64:1997, Guide for the Inclusion of Environmental Aspects in Product Standards,

which helps product standard writers address environmental aspects. • ISO 14064-1:2006, Greenhouse Gases – Part 1: Specification with Guidance at the

Organization Level for Quantification and Reporting of Greenhouse Gas Emissions and Removals, provides guidelines principles and requirements at the organization level for quantification and reporting of greenhouse gas (GHG) emissions and removals.

• ISO 14064-2:2006, Greenhouse Gases – Part 2: Specification with Guidance at the Project

Level for Quantification, Monitoring and Reporting of Greenhouse Gas Emission Reductions or Removal Enhancements, provides guidance at the project level for quantification, monitoring and reporting of activities intended to cause greenhouse gas (GHG) emission reductions or removal enhancements.

• ISO 14064-3:2006, Greenhouse Gases – Part 3: Specification with Guidance for the

Validation and Verification of Greenhouse Gas Assertions, provides guidance for those conducting or managing the validation and/or verification of greenhouse gas (GHG) assertions.

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Implementing an Environmental Management System

Implementing an EMS affects an entire organization and requires commitment across the board.

The implementation process begins with top management identifying the appropriate resources,

and then creating a personnel structure to plan and oversee the process.

IS0 14001 places this initial task in the hands of top management to provide direction for the

program and convey the importance of the EMS to employees. It also requires top managers to

draft policies, allocate resources, establish support systems, mandate training, formulate

appraisal systems and provide necessary communication.

Executive management must also select the management representative (MR), who is

responsible for the EMS throughout implementation, maintains the day-to-day EMS operations,

and reports on EMS performance to top management. ISO 14001 Element 4.4.1 requires top

management to appoint a management representative with “ensuring that an environmental

management system is established, implemented and maintained.”

The MR must identify available resources and personnel, develop procedures, track costs and

benefits, and gather information from each department manager for EMS review and

improvement.

Every employee must play a role in EMS implementation. Department managers are involved to

the degree that their operations produce environmental aspects and impacts. Floor employees are

the backbone of the whole system, since they carry out most of the organization’s activities that

can affect the environment.

Environmental training plays a big role in ISO 14001 EMS implementation. Element 4.4.2

requires all employees whose job duties may significantly affect the environment to be

competent on the basis of appropriate education, training and/or experience.

To ensure that employees have the resources they need to meet EMS requirements, the

organization must identify training needs. Element 4.4.3 recommends that the organization

inform interested parties, such as subcontractors, regulators and customers, of its significant

environmental aspects.

Auditors who evaluate an organization’s EMS must also be trained, with these requirements set

forth in ISO 19011.

ISO 14001 requires documentation, which the MR is responsible for establishing and

maintaining. Element 4.2 mandates an environmental policy that provides the framework for

setting environmental objectives and targets. Other documents include a description of the scope

of the environmental management system, procedures, work instructions and records. While

ISO 14001 does not define explicit requirements for an Environmental Manual, it is good

practice to maintain EMS documentation in some structured format such as a manual.

Documents are controlled under procedures required by Element 4.4.5.

Documentation presents a clear picture of a facility’s EMS as it compares to ISO 14001

requirements, providing objective evidence of EMS status. It also establishes an archive of EMS

information that aids in both operations and audits.

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Meeting Environmental Auditing Requirements

ISO 14001 requires organizations to continually monitor their performance through a systematic

auditing approach that compares a company’s environmental achievements to its objectives and

targets.

Auditing requirements are found in ISO 19011:2011, Guidelines for Auditing Management

Systems, which contains definitions of auditing terms, sets forth auditing principles, describes

audit program management requirements, provides guidance for conducting management system

audits, and presents auditor competence and evaluation requirements.

Understanding the Audit Process

An audit is a systematic, independent and documented process for obtaining audit evidence and

evaluating it objectively to determine the extent to which the audit criteria are fulfilled. During

an audit, an auditor measures the adequacy of the EMS, its effectiveness, and its conformity to

ISO 14001.

ISO 14001 Element 4.5.5 requires periodic audits of an organization’s EMS, with the scope,

frequency and methodologies of these audits covered by procedures. In registering an

organization to ISO 14001, the environmental policy and other documentation are reviewed first

during the Stage 1 (desktop) audit. Following this process, the auditor then examines the

company’s on-site operations during the Stage 2 (registration) audit, to ensure that the EMS

requirements are met. Both stages are incorporated into an internal audit.

Upon completing the Stage 2 audit, it is the auditor’s job to identify areas of operation where the

EMS does not meet ISO 14001 requirements. The auditor will require the organization to take

corrective action to close out any nonconformities before a registration certificate can be issued.

In an internal audit, implementation of these actions must be verified during either a follow-up

audit or the next surveillance audit.

If corrective actions are required for the organization’s environmental policy, procedures or other

EMS components as a result of nonconformities, the ISO 14000 management representative,

together with the department manager of the affected area, should guide these activities. The

management representative is also responsible for updating documentation to reflect changes that

result from corrective and preventive actions.

Documentation Review

A thorough review of an organization’s EMS documentation is conducted during the Stage 1

audits. Documentation includes the environmental policy, procedures, work instructions and

records, which are reviewed for conformity to ISO 14001 requirements, along with other

applicable requirements, such as regulatory mandates. Documentation is an invaluable reference

source because it serves as the foundation of the EMS and provides objective evidence on its

status.

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In most organizations, documentation is structured in the following four-tier hierarchy:

• Tier 1 – Environmental Policy with optional EMS Manual

• Tier 2 – Procedures

• Tier 3 – Work Instructions

• Tier 4 – Records

The environmental policy defines the criteria against which the EMS measured. If this review shows that the organization’s documentation fails to meet ISO 14001 requirements, the Stage 2 audit cannot be scheduled until the situation is corrected.

Performing Internal Audits

An internal audit is performed by an organization’s personnel, and may be carried out by the management representative or any employee who has demonstrated competence based on education, training, skills and experience as referenced in ISO 19011 Section 7.2.4. The goal of an internal audit is to assess the adequacy and effectiveness of the management system and to determine where improvements can be made. In order to maintain impartiality, internal auditors are not allowed to audit their own work.

Auditor competence is a critical component for ISO 14001 registration. It is important for auditors, especially internal auditors, to receive training that is relevant and comprehensive with regard to the entire ISO 14000 series, and is conducted according to ISO 19011 requirements.

Taking Corrective Action

There are several reasons why an EMS might not meet ISO 14001 requirements. The program may have failed to keep up with environmental regulations during a period of rapid change. Perhaps employees have not been trained to new procedures or no provisions have been made to ensure that all employees have the resources needed to implement these procedures.

In any case, it is the responsibility of the management representative and top management to review the plan and correct it when necessary. The goal is to detect and then correct the root causes of deficiencies. This is another area in which an external auditor or consultant may prove invaluable.

If an audit reveals that your company needs to take corrective action for nonconformities, it is not a cause for alarm. If the nonconformity was identified as a minor, it is a problem that can be easily rectified and will not usually block the registration process

The corrective action process is more involved for a major nonconformity, a deficiency or break down in the EMS that is preventing the organization from achieving its environmental objectives and targets. When a major nonconformity is identified, it usually means that a significant change must be made to the EMS by adding a procedure or changing a practice to eliminate its root cause and prevent it from recurring.

Once the nonconformities are corrected, a follow-up audit specific to the areas of concern is usually required. This is done to confirm that the problem has been resolved. In the case of a Stage 2 audit, registration cannot be achieved until it is verified that all nonconformities have been corrected.

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THE BENEFITS OF ISO 14000

ISO 14001 registration creates innumerable advantages and unlimited benefits for organizations

within both the public and private sectors. Reasons for seeking registration include fulfilling

legal requirements, satisfying contractual requirements, achieving internal improvements,

reducing multiple audits, regulatory and legal concerns, and marketplace benefits.

In some countries, ISO 14001 registration may become a legal requirement to enter the

marketplace. This may occur in the European Union (EU) and Japan.

ISO 14001 registration enhances a company’s public image while offering safeguards against

lawsuits through reduced exposure to liabilities. Companies can face stiff fines and time-

consuming lawsuits for not adhering to environmental regulations. Furthermore, registration can

greatly improve a company’s competitive stance, especially when it comes to overseas trade.

In the business sector, ISO 14001 registration has become a contractual requirement of some

major companies in purchasing products and services. Additional mandates are expected in the

future.

To consumers, a company’s registration to ISO 14001 provides assurance that it is committed to

protecting the environment through proactive activities that can be objectively demonstrated.

Even if ISO 14001 registration is not a customer-mandated requirement, businesses may opt to

pursue it for such benefits as cost reduction, prestige, an assumed perception of environmental

responsibility, and a positive public response.

Most companies realize that self-improvement is imperative for business prosperity and growth.

Internal improvement is yet another reason for ISO 14001 registration. When environmental

management is a high priority of a company’s management team, this positive message is

reinforced throughout the workplace.

Organizations that have implemented ISO 14001 often see improvements in productivity, waste

reduction, energy efficiency and regulatory compliance costs.

We are all becoming increasingly aware of the costs of environmental damage: contaminated

ground water, polluted air, doubts and uncertainties about a sustainable future, and the expense

of remediation.

ISO 14000, by requiring organizations to plan, implement and maintain an EMS, can be used to

prevent and minimize environmental impacts through a common sense approach, allowing

companies to take charge of their environmental affairs while improving regulatory compliance.

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There are monetary benefits as well. Through the continual improvement process, an

organization can save money by preventing pollution, avoiding cleanup and liability costs, using

energy more efficiently and reducing waste.

ISO 14001 registration, besides easing regulatory compliance, can improve a company’s

competitiveness, as a growing number of major firms have set supplier registration mandates.

Registration can also aid companies seeking to enter the EU and Japanese markets.

There are many benefits to be derived from implementing a well-structured ISO 14001 EMS,

and the registration process is rigorous and timely. For this reason, not to mention the high rate

of failure that afflicts organizations seeking registration for the first time, it is a good idea to seek

the services of an outside professional consulting firm.

A competent environmental consultant can walk your organization through the ISO 14001

requirements, interpret and implement the standard to your specific situation, and identify any

problems that may halt the implementation and registration process.

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ISO 14001 ENVIRONMENTAL MANAGEMENT SYSTEM

REQUIREMENTS

NOTE: Requirements are paraphrased to avoid issues associated with potential copyright infringements.

4.1 General Requirements

The organization shall establish, document, implement, maintain and continually improve an

environmental management system in accordance with the requirements of ISO 14001:2004 and

determine these requirements will be fulfilled.

The organization shall define and document its environmental management system scope.

4.2 Environmental Policy

Top management shall define the organization's environmental policy and ensure that the scope

of its environmental management system:

a) Is appropriate to the nature, scale and environmental impacts of its activities, products or

services provided.

b) Includes a commitment to continual improvement and pollution prevention.

c) Includes a commitment to comply with applicable environmental legislation and regulations,

and with other requirements to which the organization subscribes that relate to its

environmental aspects.

d) Provides the framework for establishing and reviewing environmental objectives and targets.

e) Is documented, implemented and maintained.

f) Is communicated to employees and other persons working for or on behalf of the

organization.

g) Is available to the public.

4.3 Planning

4.3.1 Environmental Aspects.

The organization must establish and maintain (a) procedure(s):

a) To identify environmental aspects related to its activities, products and services within the

defined scope of the environmental management system that it can control and those that it

can influence giving consideration to planned or new developments, or new or modified

activities, products and services.

b) To determine aspects that have or can have significant impact(s) on the environment.

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The organization must keep this information up to date.

The organization shall ensure that the significant environmental aspects given consideration

when establishing, implementing and maintaining its environmental management system.

4.3.2 Legal and Other Requirements

The organization shall establish, implement and maintain a procedure:

a) To identify and have access to relevant legal and other requirements to which the

organization subscribes, that are applicable to its environmental aspects.

b) To determine how these requirements relate to its environmental aspects.

The organization shall ensure that these relevant legal and other requirements to which the

organization subscribes are given consideration when establishing, implementing and

maintaining its environmental management system.

4.3.3 Objectives and Targets

The organization shall establish, implement and maintain documented environmental objectives

and targets, at relevant functions and levels within the organization.

The objectives and targets shall be measurable and consistent with the environmental policy,

including the commitments to prevention of pollution, to compliance with applicable legal and

other requirements to which the organization subscribes, and to continual improvement.

When establishing and reviewing its objectives and targets, an organization shall give

consideration to the legal and other requirements to which the organization subscribes, and its

significant environmental aspects. It shall also consider its technological options, its financial,

operational and business requirements, and the views of interested parties.

The organization shall establish, implement and maintain a program(s) for achieving its

objectives and targets. Program(s) shall include:

a) Designation of responsibility for achieving objectives and targets at relevant functions and

levels throughout the organization.

b) The means and time-frame for achieving the objectives.

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4.4 Implementation and Operation

4.4.1 Resources, Roles, Responsibility and Authority

Management shall ensure the availability of resources necessary to establish, implement,

maintain and improve the environmental management system. Resources include human

resources and specialized skills, organizational infrastructure, technology and financial

resources.

Roles, responsibilities and authorities shall be determined, documented and communicated in

order to facilitate effective environmental management.

The organization's top management shall appoint a management representative(s) who,

irrespective of other responsibilities, shall have defined roles, responsibilities and authority for:

a) Ensuring that an environmental management system is established, implemented and

maintained in accordance with the requirements of ISO 14001:2004.

b) Reporting to top management on the performance of the environmental management system,

including recommendations for improvement, for review.

4.4.2 Competence, Training and Awareness

The organization shall ensure that any person(s) working under its control that have the potential

to cause a significant environmental impact(s) identified by the organization is (are) competent

on the basis of appropriate education, training or experience, and shall retain associated records.

The organization shall determine training requirements associated with its environmental aspects

and its environmental management system. It shall provide training or take other action to meet

these needs, and shall retain associated records.

The organization shall establish, implement and maintain a procedure(s) to make persons

working under its control aware of:

a) The importance of conforming to the environmental policy and procedures and with the

requirements of the environmental management system.

b) The significant environmental aspects and related impacts associated with their work, and the

environmental benefits of improved personal performance.

c) Their roles and responsibilities in conforming with the requirements of the environmental

management system.

d) The potential consequences of departing from specified procedures.

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4.4.3 Communication

With respect to its environmental aspects and EMS, the organization shall establish and maintain

procedures for:

a) Internal communication between the organizations various levels and functions.

b) Receiving, documenting and responding to pertinent communication from external interested

parties.

The organization shall decide whether to communicate information regarding its significant

environmental aspects to external interested parties and shall document its decision. Where the

organization decides to communicate, the organization shall establish and implement a method(s)

to support external communication.

4.4.4 Documentation

Environmental management system documentation shall include:

a) The environmental policy, objectives and targets.

b) A description of the scope of the environmental management system.

c) A description of the main elements of the environmental management system including their sequence and interaction, and reference to related documents.

d) Documents, including records, required by ISO 14001:2004.

e) Documents, including records, determined to be necessary to ensure the effective planning, operation and control of processes that relate to the organization’s significant environmental aspects.

4.4.5 Control of Documents Documents required by the environmental management system and by ISO 14001:2004 shall be controlled. Records are a special type of document and shall be controlled in accordance with the requirements given in 4.5.4. The organization shall establish and maintain procedures for controlling EMS documents to ensure:

a) Documents are approved for adequacy prior to issue.

b) Documents are reviewed and updated as necessary and re-approved.

c) Changes and the current revision status of documents are identified.

d) Ensure that relevant versions of documents are available at points of use.

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e) Ensure that documents are maintained in a manner that preserves their legibility and availability.

f) Ensure that external documents required by the organization to support the planning and operation of the environmental management system are identified and their distribution controlled.

g) Prevent the unintended use of obsolete documents and ensure they are suitably identified if they are retained for any purpose.

4.4.6 Operational Control

The organization shall identify and plan those operations and activities that are associated with its significant environmental aspects in line with its policy, objectives and targets in order to ensure that they are carried out under specified conditions by:

a) Establishing, implementing and maintaining documented procedures to cover situations where their absence could lead to deviations from the environmental policy, objectives and targets.

b) Stipulating operating criteria in the procedures.

c) Establishing, implementing and maintaining procedures related to the identifiable significant environmental aspects of goods and services utilized by the organization, and communicating relevant procedures and requirements to suppliers and contractors.

4.4.7 Emergency Preparedness and Response

The organization shall establish, implement and maintain procedures to identify potential

emergency situations, and accidents that can impact(s) its environment and determine how it will

respond to them.

The organization shall respond to emergency situations and accidents in order to prevent or

mitigate associated adverse environmental impacts.

The organization shall periodically review and revise, its emergency preparedness and response

procedures, especially after the occurrence of accidents or emergency situations.

The organization shall periodically test such procedures where it is practical to do so.

4.5 Checking

4.5.1 Monitoring and Measurement

The organization shall establish, implement and maintain procedures to monitor and measure, on

at regular intervals, the key characteristics of its operations and activities that can have a

significant impact on the environment. The procedures shall include documenting information to

monitor performance, related to operational controls and conformity with the organization's

environmental objectives and targets.

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The organization shall ensure that monitoring and measurement equipment used is calibrated or

verified and maintained and shall retain associated records.

4.5.2 Evaluation of Compliance

4.5.2.1 Consistent with its commitment to comply with applicable legal requirements, the

organization shall establish, implement and maintain a procedure(s) for periodically

evaluating compliance.

The organization shall keep records of the results of the periodic evaluations.

4.5.2.2 The organization shall evaluate compliance with other requirements to which it

subscribes. The organization may choose to combine this evaluation with the evaluation

of legal compliance referred to in 4.5.2.1 or to establish a separate procedure.

The organization shall keep records of the results of the periodic evaluations.

4.5.3 Nonconformity, Corrective and Preventive Action

The organization shall establish, implement and maintain procedures for responding to and

investigating nonconformity(ies) and for taking corrective and preventive action. The

procedure(s) shall define requirements for:

a) Identifying and correcting nonconformity(ies) and taking necessary action(s) to mitigate their

environmental impacts.

b) Investigating nonconformity(ies), performing cause analysis and taking actions to prevent

their recurrence.

c) Evaluating the need for action(s) to prevent nonconformity(ies) and implementing

appropriate actions needed to prevent their occurrence.

d) Documenting and maintaining the results of corrective action(s) and preventive action(s)

taken.

e) Reviewing the effectiveness of action(s) taken.

Actions taken shall be appropriate for identified problems and the environmental impacts

encountered.

The organization shall ensure that necessary changes are made to relevant environmental

management system documentation.

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4.5.4 Control of Records

The organization shall establish and maintain records required to demonstrate conformity to the

requirements of its environmental management system and ISO 14001:2004, and the results

achieved.

The organization shall establish, implement and maintain a procedure(s) for the identification,

storage, protection, retrieval, retention and disposal of records.

Records shall be maintained in a manner that ensures they are legible, identifiable and traceable.

4.5.5 Internal Audit

The organization shall ensure that internal audits of the environmental management system are

conducted in accordance with planned arrangements to:

a) Determine the extent to which the environmental management system:

1. Conforms to the arrangements determined for environmental management including the

requirements of ISO 14001:2004.

2. Has been implemented and maintained as planned.

b) Provide information on audit results to management.

Audit program(s) shall be planned, established, implemented and maintained by the organization,

based on the environmental importance of the operation(s) concerned and previous audit results.

Audit procedure(s) shall be established, implemented and maintained that address:

• The responsibilities and requirements for planning and conducting audits, reporting results

and retaining related records.

• The planning of the audit criteria, scope, frequency and methods.

Selection of auditors and conduct of audits shall ensure that auditors are objective impartial.

Auditors shall not audit their own work.

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4.6 Management Review

Top management shall review the organization's environmental management system, at regular

intervals, to ensure its continuing suitability, adequacy and effectiveness. Management reviews

shall include assessing opportunities for improvement and the need for changes to the

environmental management system, including the environmental policy and environmental

objectives and targets. Records of the management reviews shall be retained.

Input to management reviews shall include:

a) Results of internal audits and compliance evaluations related to legal requirements and other

requirements to which the organization subscribes.

b) Communication(s) to and from external interested parties, including complaints.

c) The performance of the organization’s environmental management system.

d) Performance related to environmental objectives and targets.

e) The status of corrective and preventive actions.

f) Follow-up actions from prior management reviews.

g) Changes related to the environmental management system including developments in legal

and other requirements related to its environmental aspects.

h) Recommendations for improvement.

The outputs from management reviews shall include any decisions and actions related to

potential changes to the environmental policy, objectives, targets and other elements of the

environmental management system, commensurate with the organization’s commitment to

continual improvement.

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PART II – RESPONSIBLE RECYCLING (R2)

Introduction

The responsible recycling (“R2”) standard is applicable to organizations engaged in electronic

recycling and related activities. R2 defines practices supported by accredited certification

programs that assess the effectiveness of electronics recyclers’ environmental, health and safety,

and security practices.

The standard gives consideration to the needs of various interested parties. Customers benefit

from confidence that due diligence is practiced when processing and handling used and end-of-

life electronic equipment. Participating recyclers and refurbishers benefit through adherence to

value-added practices. Employees benefit through enhanced safety. Local and global

communities benefit by knowing that used and end of life electronics are processed in a manner

consistent with environmental responsibility and stewardship.

R2 requirements are conformance requirements and are not intended to replace legal or other

requirements to which participating organizations subscribe. Adherence to this set of R2

practices are determined and implemented on a voluntary basis. Where conflicts exist, legal

requirements take precedence over R2 or other requirements in all cases.

Electronics possess unique properties that differ from other Waste Streams. Most electronics

dispositioned for recycling are not classified as hazardous waste. Electronics are complex

devices that consist of a wide variety of materials, many of which would not be classified as

hazardous under EPA testing procedures.

Electronics contain hundreds of elements, compounds, and alloys including steel, plastic, glass,

ceramics, copper, aluminum, lead, nickel, zinc, lithium, carbon, cadmium, mercury, beryllium,

gold, silver, palladium, flame retardants, etc. Many of these materials possess residual value and

may pose risks if improperly disposed of or recycled.

Challenges related to the disposal of electronics have given rise to numerous environmental

concerns over the past many years including concerns about toxics from electronics leaching

from landfills and improper disposal methods such as open burning utilized in some developing

countries. Electronics that end up in landfills or incinerators represent lost resources.

Fact: In a gold mine, one ton of ore contains about only five to 10 grams of gold. One ton of

cell phones (about 10,000 cell phones) contains 300 to 400 grams of gold".

Focus Materials (FMs)

Some of the primary materials contained in electronic products represent hazards to the

environment or possess latent value that makes them prime candidates for reuse and/or recycling.

These materials are referred to as Focus Materials (FMs).

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Focus Materials include equipment and components containing:

• Cathode ray tubes and glass;

• Circuit boards;

• Batteries;

• Items containing mercury/PCBs; and

• While not a Focus Material, toner and toner cartridges are generally managed as FMs.

The History of R2

The EPA Recognized the need for a certification program that addressed the operational and

environmental needs of the electronics recycling industry and utilized a multi-disciplinary

process to develop the R2 Standard,“Responsible Recycling practices for Use in Accredited

Certifications Programs”.

A multi-stakeholder electronics summit was convened in March 2005. The objective was to

create a voluntary, market-based mechanism for ensuring best practices, that also provides

prospective customers with an enhanced sense of confidence by knowing that their used

electronics are processed in a safe, secure manner that is consistent with applicable

environmental requirements.

The R2 standard was developed through these collaborative efforts. It took 3 years to develop

the R2 standard. The R2 Standard was released on October 30, 2008.

Participants in the multi-stakeholder group included representatives from:

• The U.S. EPA,

• Regulators from state agencies,

• Electronics recyclers, refurbishers, and their trade associations,

• OEMs and customers of electronics recycling services,

• Non-Governmental Organizations (NGOs).

Representatives from environmental justice organizations participated throughout much of the

R2 development process, but withdrew participation prior to inception of the standard.

The Responsible Recycling (R2) Standard was developed as an output of this meeting. The R2

standard was issued as an authorized document after it was reviewed and approved by ANAB.

Development of the R2 standard included the following steps:

• R2 was drafted by an EPA funded neutral facilitator in a consensus-driven process,

• Each version was discussed by the quorum and revised by the facilitator,

• All versions were reviewed by 4 experienced auditors,

• Each version was 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).

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The R2 Technical Advisory Committee (TAC) develops and recommends changes to the R2

Standard. The TAC is comprised of representatives from the stakeholder group.

Essential R2 Concepts

• Reuse and Recycling Required,

• Focus materials can be disposed of only under exceptional circumstances,

• Provides for on-site worker and environmental protection,

• Requires downstream due diligence when handling and processing Focus Materials,

• Requires written programs based on a “Plan-Do-Check-Act” model for continual

improvement,

• Requires compliance with applicable legal requirements,

• Complimentary to ISO 14001 and OHSAS 18001 requirements,

• Ensures facility security and the security of data during storage and disposal of hard drives

and other equipment,

• Recyclers and refurbishers are required to track throughput and maintain records, and

• Requires a written policy based on a hierarchy of Reuse-Recover-Dispose.

R2 Certification provides additional value by demonstrating that your organization:

• Cares about the environment,

• Has implemented and maintains an effective environmental, health and safety management

system,

• Assumes accountability for electronic products, components and materials,

• Places a strong emphasis on controls necessary to ensure data security,

• Adheres to the highest industry standards and best practices, and

• Is committed to safety.

Electronics Use and Recycling Facts

• Americans purchase over 500 million new consumer electronic products annually.

• Over 15 separate electronic products can be found in the average American household.

• In 2010, the Federal Government spent approximately 75 billion for IT goods and services.

• Approximately 3-5 million tons of electronics are processed by the electronics recycling

industry annually.

• Electronic recycling volumes have more than doubled in past 5 years. This rate of growth is

expected to expand in the future.

• Consumer electronics comprise less than 5% of the electronics waste stream.

• Developing countries are on the fast track to generate more than double the developed

world’s used and end-of-life computers

The R2 standard is currently undergoing revision and a 2013 draft version of the Standard

has been documented and was recently going through the review and approval process.

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Integration & Comparison with ISO 9001 and ISO 14001 Requirements

There are many situations where R2 requirements do not specifically align with requirements of

ISO 9001 and 14001. Additional requirements that are distributed throughout the standard serve

to meet corresponding requirements of ISO 9001 and 14001 but are not clearly aligned with the

requirements of the other standards. These requirements include but are not limited to

requirements for:

• An R2 manual,

• Objectives and Targets,

• Internal Audits,

• Maintenance and Calibration,

• Nonconformance, Corrective and Preventive Actions,

• Training,

• Document and Record Control.

R2 Manual

There is no specific requirement for an R2 manual. There is a requirement to document a written

EHSMS that includes additional requirements for a policy in addition to written goals and

procedures. The scope of the management system should also be identified within the

documented EHSMS.

Objectives and Targets

There are no R2 Practices that address requirements for establishing and/or monitoring goals,

objectives and targets. R2 does require participating organizations establish objectives and

targets for tracking performance and planning activities that work toward achieving identified

goals. Additional requirements address the creation and implementation of an action plan for

continual improvement.

Internal Audit

There is no R2 Practice for internal auditing. There are requirements for a recycler to use an

EHSMS to plan and monitor its processes and activities to conform to R2 Practices. Additional

requirements mandate that a recycler confirm “through audits or other similarly effective means”

that downstream vendors comply with FM controls. There are also requirements for tracking

throughput. The R2 checklist used by recyclers also meets requirements for “internal auditing”.

Maintenance/Calibration

There is no R2 Practice that addresses equipment maintenance or calibration of test equipment

but there are implied requirements throughout the standard.

Nonconformance/Corrective/Preventive Action

There is no R2 Practice specifying requirements for nonconformances, corrective or preventive

actions. The PDCA structure of the standard tends to be complimentary to the use of corrective

and/or preventive actions. Other requirements implied within the standard can easily be

accommodated through the use of a formal corrective and preventive action process.

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Training

Training requirements are not called out in explicit terms within the standard but training issues

are addressed. There are requirements that recyclers possess expertise and technical capability to

process each type of equipment, component and material in order to protect employees, public

and the environment. The standard also requires regular, documented health and safety training

as well as refresher training.

Additional training requirements apply to volunteer and temporary workers. There are also

requirements for the assignment of an individual (consultant or employee) to coordinate and

promote worker health and safety and requirements for employees involved in data destruction to

be trained on a regular basis.

Document/Records Control

There is no R2 Practice for the control of internal external documents and obsolete documents,

records retention times, etc. These requirements however are clearly implied. There are

requirements for record maintenance included within the standard.

The EHSMS has to be documented implying some level of document control must be

implemented. There are additional requirements for written procedures, a list of the

documentation and multiple other references to requirements for documents requiring at least

minimal control interspersed throughout the standard.

R2 Certification

On July 27, 2009 ANAB announced the availability of the accreditation rule for R2 ANAB Rule

#34.

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 and must reference ISO 17021,

• Registrars certificates must have ANAB seal to be valid,

• Registrars are required to maintain a publicly available list of clients,

• Only single-site certification is possible.

ISO 17021:2006 requirements for bodies providing management system certifications

• 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 (annually or more frequently as required,

• Establishes requirements for recertification (3 year intervals), and

• Establishes what the requirements for activities to be conducted during the course of audits.

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R2 Certification Requirements

Stage 1 Requirements:

• Documents needed to address R2 requirements,

• Client understanding and awareness of requirements and of the of the organization’s

significant environmental/safety risks,

• Site-specific conditions/profiles,

• The scope of the ESHMS must be defined,

• Compliance evaluations need to completed and findings addressed,

• Evaluate internal audit planning and performance processes and annual (management)

reviews.

Stage 2 Requirements:

• Conformity to requirements – Implementation,

• Performance monitoring against key performance indicators (KPIs),

• Evidence of ongoing legal compliance,

• Provision of operational controls,

• Internal audits and annual reviews are carried out as required, and

• Determining responsibility and authority for policies.

Certification Steps:

In addition to Stage 1 and 2 requirements, the following steps need to be followed:

• Contract with an accredited certification body,

• Address any nonconformities determined during the Stage 1 and 2 audits,

• Certification granted.

R2 Solutions

R2 Solutions is an independent non-profit organization tasked with managing and overseeing

implementation of the R2 Practices standard. R2 Solutions promotes environmental protection,

human health and safety, and a financially stable global electronics recycling industry through

the responsible management of used electronic equipment. R2 Solutions possesses a highly

regarded Board of Directors representing stakeholder interests, has an open and transparent

governance structure, and provides a long-term sustainable quality control mechanism.

R2 Solutions provides the following benefits to R2 certified processors:

• Increased awareness of R2 Practices amongst industry and government sectors,

• Listing of certified facilities in the directory on the R2 Solutions website,

• Continues to works with key stakeholders to ensure the standard meets current and future

needs,

• Represents R2 certified processors in national and international forums, and

• Creates a transparent methodology for managing the R2 standard.

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Security Benefits

Data breach from discarded computers is ranked as the number one concern when disposing of

IT equipment. Establishing environmental practices, ensuring proper e-waste disposal, and

finding asset disposition support for remarketing or reusing equipment are also high priorities.

The R2 Standard addresses all of these areas of concern. Certified R2 recyclers are subject to

independent, third party audits to assess the effectiveness of the management system and

conformance to related requirements.

Additional Rules and Requirements

International and Governing Rules

The Organization for Economic Cooperation and Development (OECD Countries) has developed

additional controls for hazardous waste recovery. Only CRTs have been exported as hazardous

waste under OECD controls.

Basel Convention

Basel established a control system for importing and exporting hazardous wastes to prevent

unauthorized processing or dumping in developing countries. Hazardous waste cannot be

remanded to non-OECD countries without a bilateral agreement. The U.S. is not a Party to the

Basel Convention but is in favor of ratification.

Hazardous Waste Definitions

Basel Waste definitions vary between different countries. The Basel definition of “hazardous

waste” is not the same as the U.S. Definition. The U.S. conditionally exempts hazardous waste

from regulation or excludes certain materials from being defined as waste to encourage recycling

Basel treats material dispositioned for recycling and disposal in the same manner.

Basel convention requirements state that transboundary shipments should be reduced. The waste

should be treated where it is generated.

BAN and the BAN Amendments to the Basel Convention

The BAN (Basel Action Network) is an independent charitable organization with NO direct

relationship with the Basel Convention. BAN charges licensing fees for e-stewards certification

as well as a general cost for certification.

Many states have adopted electronics take back laws. For a list of participating states, see

www.ElectronicsRecycling.org or www.electronicstakebac.com.

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Universal Waste Rule

The Universal Waste Rule applies to mercury-containing devices considered to be hazardous

waste. Additional requirements have been stream lined to accommodate materials designated for

recycling or disposal.

CRT Rule

The CRT Rule and related requirements have been established to address Cathode Ray Tube

(CRT) processing. CRTs and CRT glass are not considered solid or hazardous waste when

reused or recycled if certain conditions are met (i.e., mercury and batteries have been removed)

(see 40 CFR, Subpart E, 261.39).

Whole used and shredded circuit boards are exempted from regulation if they meet certain

requirements.

R2 Practices

R2 Practices are posted on EPA’s website at:

www.epa.gov/epawaste/conserve/materials/ecycling/r2practices.htm

They are also found on the facilitator’s website at:

www.decideagree.com/TheR2Practices.html

The auditors checklist can also be obtained from decide agree.

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THE R2 PRACTICES

NOTE: Requirements are paraphrased to avoid issues associated with potential copyright infringements.

1. Environmental, Health, and Safety Management System

General Principle – An R2 electronics recycler shall develop and maintain an Environmental,

Health, and Safety Management System (EHSMS) to plan and monitor the performance of its

environmental, health, and safety practices, including the activities it undertakes to conform to

these R2 Practices.

R2 Practices:

(a) An R2 electronics recycler shall develop, document implement, maintain, review and

update annually or more frequently as required (e.g., as products and/or technologies

change) a written EHSMS that:

(1) Includes written objectives and procedures that require organizations to

systematically manage their environmental, health, and safety matters, and

(2) Uses a “Plan-Do-Check-Act”* model for continual improvement, and

(3) Includes sections that include the following:

(A) A policy governing used and end-of-life electronics equipment that is based on

a “reuse, recover, dispose” hierarchy of responsible management strategies and

addresses materials management on site and throughout the Recycling Chain (as

described in Provision 2),

(B) A plan for compliance to environmental, health, and safety legal requirements

relating to its operations, and for ensuring it only exports items containing

Focus Materials to countries that legally accept them (as described in Provision

3),

(C) A “FM Management Plan” – addressing the manner in which R2 Focus

Materials (FMs) that pass through the R2 recycler’s facility or control should be

properly managed, on site and throughout the Recycling Chain (as described in

Provision 5) – this can be a subsection of the section described in (A) above,

(D) An EHS hazards assessment identifying on-site occupational and environmental

risks (as described in Section (c) of Provision 4),

(E) A plan for responding to and reporting exceptional releases, accidents, spills,

fires, explosions, and other out-of-the-ordinary events that represent risks to

worker safety, public health, or the environment – this section should be

provided to local emergency responders as needed, and

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(F) A list of the activities necessary to conform to R2 Practices and a list of the

documents required to demonstrate evidence conformity with these

requirements.

(b) An R2 electronics recycler shall be certified by an Accredited Certification Body stating

that:

(1) Its EHSMS conforms to the requirements of this practice, and

(2) Its practices conform to requirements related to the EHSMS and of these R2

Practices.

*Elements of this model include:

Plan – (a) Identify environmental and worker health/safety, and legal and regulatory

requirements; (b) Determine and implement environmental goals, objectives and targets; (c) Plan

actions that work toward achieving goals, objectives and targets; (d) Plan for emergencies and

response; and (e) Identify management commitment.

Do – (a) Establish roles and responsibilities for the EHSMS and provide necessary resources; (b)

Ensure that staff associates are trained and competent for functions performed; and (c) Establish

a process for communicating information related to the EHSMS.

Check – (a) Monitor key activities and measure performance; (b) Identify and correct problems

to prevent recurrence; and (c) Provide a system for measuring performance.

Act – (a) Conduct annual performance reviews; (b) Make necessary changes to the EHSMS; (c)

Determine and adopt an action plan for continual improvement.

2. “Reuse, Recover, ...” Hierarchy of Responsible Management Strategies

General Principle – An R2 electronics recycler shall develop and abide by a policy for managing

used and end-of-life electronic equipment that is based on a “reuse, recover, dispose” hierarchy

of responsible management strategies.

R2 Practices:

(a) An R2 electronics recycler shall develop and adhere to a written policy stating how it

manages used and end-of-life electronics equipment, components, and materials –

governing both onsite activities and the selection of downstream vendors – which is based

on prioritized responsible management strategies:

(1) Reuse – An R2 electronics recycler shall disposition properly functioning equipment

and components for reuse unless a customer directs otherwise,

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(2) Materials Recovery – An R2 electronics recycler shall separate materials in

equipment and components that are not dispositioned for reuse and direct them to

properly-equipped materials recovery facilities when technically and economically

feasible.

(3) Energy Recovery or Disposal – An R2 electronics recycler shall direct remaining

materials to approved energy recovery and/or disposal facilities in conformity with

Provision 5.

(b) This policy shall correspond with the Focus Material Management Plan that the R2

electronics recycler develops in accordance with Provision 5.

3. Legal Requirements

General Principle – An R2 electronics recycler shall comply with all applicable environmental,

health, and safety legal requirements and regulations and shall only export equipment and

components containing FMs to countries that legally accept them.

R2 Practices:

(a) In order to maintain its compliance with all applicable environmental, health, and safety

legal requirements and to assure it only exports equipment and components containing FMs

to countries that legally accept them, an R2 electronics recycler shall determine and

implement a plan addressing these matters to be included as a section of its EHSMS.

(1) The plan shall identify and document the environmental, health, and safety legal

requirements that cover the recycler’s scope of activities. The recycler shall ensure

the plan is current, identify and implement the steps necessary to comply with

applicable requirements, document the implementation of these steps, periodically

evaluate its compliance with the requirements and take corrective actions to address

any issues resulting from non-compliance.

(2) The plan shall identify and document the applicable legal compliance – under the

laws of the importing countries – of all international shipments of equipment,

components, or materials containing FMs that have passed through the R2 recycler’s

facility or control*. The recycler shall identify the countries that receive these

shipments, obtain documentation showing that each non-OECD** country legally

accepts such shipments, and only make shipments to countries for which it has such

documentation***. The documentation shall be comprised of one of the following:

(A) A copy of the applicable information from the United States Environmental

Protection Agency, or

(B) Documentation**** from the country’s Competent Authority stating that such

imports are legally accepted, or

(C) A copy of a law or court ruling from the importing country that provides

evidence of the legality of the import.

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* This includes materials handled by downstream vendors.

** The R2 Document implies that these shipments are legal to import into OECD countries.

*** Recyclers that export used CRTs for reuse and CRT or mixed CRT glass for recycling

also have to meet export requirements under USEPA's CRT rule (FR: July 28, 2006

Volume 71, Number 145).

**** The documentation must be in a language consistent with the language of the R2

recycler’s third-party R2 auditor to enable easy interpretation.

4. On-Site Environment, Health, and Safety

General Principle – R2 electronics recycler shall adhere to practices at their facilities that

ensure worker health and safety and environmental protection.

R2 Practices:

General

(a) An R2 electronics recycler shall be competent and possess the technical capability to

process each type of equipment, component, and material it accepts in a manner that

protects worker safety, public health, and the environment.

(b) An R2 electronics recycler adheres to good housekeeping practices, including maintaining

work and storage areas clean and orderly manner. Clean up procedures for all areas of the

facility should be planned, regularly implemented, and evaluated.

Workforce and Environmental Protection

(c) An R2 electronics recycler shall conduct hazards identification and assessment of

occupational and environmental risks on an ongoing basis addressing existing risks or risks

that could reasonably be expected to develop at the facility.

Such risks could result from various sources, including but not limited to emissions of

and/or exposure to substances*, noise, ergonomic factors, thermal stress, substandard

machine guarding, cuts and abrasions, etc. The hazards identification and assessment shall

be documented and included as a component of the recycler’s EHSMS.

(d) An R2 electronics recycler shall control hazards and minimize the releases it identifies

using an appropriate combination of strategies, including but not limited to (1-3 below are

in order of priority, per OSHA regulations):

(1) Engineering controls such as (A-C below are prioritized in accordance with OSHA

regulations):

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(A) Substitution (e.g., replacing a hazardous material with one that is less hazardous

and more environmentally friendly);

(B) Isolation (e.g., automating a process to avoid exposure), or

(C) Ventilation and if appropriate, retention (e.g., fume hood),

(D) Dust control, retention, and clean up,

(E) Emergency shut-off controls and

(F) Fire suppression equipment.

(2) Administrative and work practice strategies, including appropriate combinations of:

(A) Documented health and safety training that covers information from the

hazards assessment, as well as safe management handling, spill prevention,

engineering controls, equipment safety, and use and care of personal

protection equipment conducted on a regular basis. Training shall be provided

to new associates and refresher training provided to all employees in a

language that is easy to understand and is appropriate for their educational

background.

(B) Cross training as feasible given workforce size,

(C) Safe work practices,

(D) Medical oversight,

(E) Safety meetings,

(3) Personal protective equipment, including respirators, protective eyewear, cut-resistant

gloves, etc., as needed for the risks associated with the work performed.

(e) An R2 electronics recycler shall utilize monitoring and sampling procedures to provide

confidence that the practices it employs are effectively and continuously managing the

risks it has identified. This includes complying with all applicable Federal or State

regulations, OSHA standards and PELs for sampling and/or monitoring.

(f) An R2 electronics recycler shall treat all workers, including volunteer workers, temporary

workers, and anyone else performing activities for or on its behalf, using the standard of

care established pursuant to Section (d) of this provision.

(g) An R2 electronics recycler shall designate a qualified employee or consultant to coordinate

its efforts to ensure worker health and safety. This individual shall be identified to all

employees and two-way communication shall be encouraged between employees and this

individual regarding potential hazards and how best to manage them.

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Exceptional Releases

(h) An R2 electronics recycler shall be able to at all times, implement the plan set forth in its

EHSMS for responding to and reporting exceptional releases, accidents, spills, fires,

explosions, and other out-of-the-ordinary events that pose risks to worker safety, public

health, or the environment.

*Risks posed by exposure to substances may arise from various situations – sometimes involving

substances that do not normally pose a risk to worker safety or the environment. Such substances

may include mercury, lead, beryllium, cadmium, PCBs, some phosphor compounds, certain

brominated flame retardants (i.e. polybrominated biphenyls, pentabrominated diphenyl ether, and

octabrominated diphenyl ether), silica dust, chlorinated or brominated dibenzodioxins and

dibenzofurans, and hexavalent chromium. Special attention should be given to potential lead and

cadmium exposures during the processing and handling of broken CRT glass, as well as where

lead solder is melted during chip recovery.

5. R2 Focus Materials

General Principle – An R2 electronics recycler shall manage – on site and during the selection of

downstream vendors – the R2 Focus Materials that pass through its facility or control in a

manner that ensures worker health and safety, public health, and the environment; and shall

require due diligence from downstream vendors to which it ships these materials.

R2 Practices:

Development and compliance with a FM Management Plan

(a) An R2 electronics recycler shall analyze and determine how the R2 Focus Materials (FMs)

that pass through its facility or control will be properly managed both on site and

throughout the Recycling Chain (and include this analysis and plan within the “FM

Management Plan” section of its EHSMS). The FM Management Plan shall define how

the recycler and its downstream vendors shall meet the requirements set forth in the rest of

this Provision 5.

Removal of FMs

(b) Prior to shredding, materials or energy recovery, incineration, or land disposal of

equipment or components, FMs (including toner and toner cartridges) shall be removed

using safe and effective mechanical processing or manual dismantling, with two

exceptions:

(1) Items containing mercury, if they are too small to safely remove at reasonable cost

and workers are protected from the risks posed by the mercury during and prior

processing any equipment containing it, and the equipment and components

containing such items are sent to materials recovery facilities that are suitably

licensed to receive, and that use technology designed to safely and effectively

manage, equipment or components containing such mercury-containing items.

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(2) CRTs, batteries, and circuit boards contained in equipment or items destined for

materials recovery need not be removed prior to shredding and/or materials recovery

if the processing occurs in facilities that are properly licensed to receive, and that

utilize technology designed to safely and effectively manage, equipment or items

containing these FMs.

Processing, Recovery, and Treatment of FMs

(c) An R2 electronics recycler shall send removed FMs to processing, recovery, or treatment

facilities that are suitably licensed to receive, and that employ technology designed to

safely and effectively manage, the FMs. This shall include:

(1) For equipment or components containing mercury – mercury retorting,

(2) For circuit boards – removal of batteries and mercury containing items and then

smelting for metals recovery, and

(3) For items containing PCBs – technology developed for PCB destruction and licensed

under the Toxic Substances Control Act and/or any other applicable law.

(4) Toner and toner cartridges, though not an FM, shall be recycled through the OEM or

other qualified toner recycling facility except where it is not economically feasible to

do so.

Energy Recovery, Incineration, and Land Disposal of FMs

(d) An R2 electronics recycler shall not utilize energy recovery, incineration, or land disposal

as a methodology for FMs or equipment and components containing FMs*. However, if

circumstances beyond the control of the R2 recycler affect its normal management of an

FM, it may consider these technologies to whatever extent allowed under applicable law.

Selection and Ongoing Due Diligence of Downstream Vendors for FMs

(e) For shipments of removed FMs, equipment and components containing FMs, an R2

electronics recycler shall determine downstream vendors that possess and conform to:

(1) The R2 recycler’s FM Management Plan (developed in accordance with and

including the requirements defined in Sections (b) - (d) above),

(2) A documented environmental, health, and safety management system,

(3) A roster of its environmental permits and copies of each,

(4) This Section (e) of Provision 5, thereby establishing that each vendor in the Recycling

Chain meets the requirements established in these subsections (1) – (7),

(5) Provision 6 (Reuse),

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(6) The exporting requirements set forth in Provision 3 (a) (2), and

(7) Provision 7 (Tracking Throughput).

(f) An R2 electronics recycler shall verify, through audits or other similarly effective means

that each downstream vendor in the Recycling Chain to which Section (e) applies continues

to meet the requirements of Section (e) for as long as it receives FMs directly or indirectly

from the R2 recycler.

*Unless applicable law requires the use of one of these technologies (e.g., thermal destruction of

PCBs)

6. Reusable Equipment and Components

General Principle – An R2 electronics recycler shall refurbish as necessary, properly test,

and\suitably package equipment and components going to reuse.

R2 Practices:

(a) An R2 electronics recycler shall not allow equipment or components to be sold or donated

for reuse if this is conflict with any commercial agreements.

(b) An R2 electronics recycler shall, with respect to equipment and items it ships downstream:

(1) Label and sort shipments in a manner sufficient to track throughput in conformity

with Provision 7.

(2) Handle and package shipments in accordance with Provision 12.

(c) An R2 electronics recycler, prior to shipping equipment and other items (except equipment

and items that are new and in their original packaging) that contain FMs and that will be

reused as is or repaired, refurbished, or remanufactured, shall:

(1) Apply effective testing methods to confirm that the Key Functions of the equipment

or components are in good working order, or

(2) Determine that the receiving facility is a certified R2 electronics recycler, or

(3) Confirm through a combination of contractual agreements, comprehensive materials

tracking, record keeping, and auditing that:

(A) The equipment or items meet the requirements of the recipient vendor, and

(B) The receiving vendor sells the equipment or items for reuse, with their Key

Functions working properly, and

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(C) The recipient vendor controls all residual FMs resulting from refurbishing

operations in a manner consistent with the R2 Practices.

(d) An R2 electronics recycler is not required to conform to Section (c) for shipments of less

than 15 items that either are going to a new vendor as a representative sample for purposes

of evaluation of whether to purchase larger quantities for refurbishment or that are being

sold with an equitable return policy to an end user. This Section (d) does not apply to

multiple sales or shipments within a given timeframe to the same entity.

(e) An R2 electronics recycler does not need to conform to the downstream requirements of

Provision 5 for shipments that satisfy the requirements of Section (c) or (d), or are new and

in their original packaging.

(f) An R2 electronics recycler does not need to conform to the exporting requirements of

Provision 3 (a) (2) for shipments that meet either the functionality requirement of Section

(c) (1) or Section (d), or are new and in their original packaging.

7. Tracking Throughput

General Principle – An R2 electronics recycler shall maintain business records sufficient to

demonstrate the material flow of equipment, components, and materials that pass through its

facility.

R2 Practices:

(a) An R2 electronics recycler shall maintain commercial contracts, bills of lading, or other

commercially accepted documents for all transfers of equipment, components, and

materials into and out of its facility, including brokering transactions for at least three

years.

8. Data Destruction

General Principle – An R2 electronics recycler shall employ generally accepted data destruction

procedures.

R2 Practices:

(a) An R2 electronics recycler shall sanitize, purge, degauss or destroy data on hard drives and

other data storage devices (the National Institute of Standards and Technology’s (NIST’s)

Guidelines for Media Sanitation – Special Publication 800-88 88 9 lists categories of

devices which need sanitization consideration), unless otherwise requested in writing by

the customer. The R2 electronics recycler shall comply to the data sanitization, purging, or

destruction practices described in the NIST Guidelines for Media Sanitation: Special

Publication 800-88* or another current generally-accepted standard, or be certified by a

recognized certification program.

(b) An R2 electronics recycler shall maintain procedures describing their data destruction

methods.

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(c) Employees involved in data destruction shall receive suitable training on a regular basis.

(d) Data destruction processes shall be reviewed and validated at planned intervals by an

independent party.

*See - http://csrc.nist.gov/publications/nistpubs/800-88/NISTSP800-88_rev1.pdf

9. Storage

General Principle – An R2 electronics recycler shall store items and materials that may result in

risk to worker health or safety or the environment if inappropriately stored, and equipment and

components going to reuse, in a suitable manner.

(a) An R2 electronics recycler shall store items removed in accordance with Provision 5, and

equipment and items destined for reuse, in a manner that:

(1) Protects them from adverse environmental conditions and floods and, as warranted,

includes a containment system, and

(2) Prohibits unauthorized entrance, and

(3) Is in clearly labeled containers, bins and/or storage areas.

10. Facility Security

General Principle – An R2 electronics recycler shall employ facility security measures suitable

for the equipment they handle and customers they serve.

R2 Practices:

(a) An R2 electronics recycler shall maintain a security program that controls access to all or

parts of the facility in a manner and to a degree appropriate for the type of equipment

handled and the needs of the customers served.

11. Insurance, Closure Plan, and Financial Responsibility

General Principle – An R2 electronics recycler shall possess insurance that is adequate to cover

the potential risks and liabilities associated with the scope of work performed and size of the

company’s operations, and shall have necessary legal and financial assurances in place for the

proper closure of its facilities.

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R2 Practices:

(a) An R2 electronics recycler shall possess suitable Comprehensive or Commercial General

Liability Insurance including coverage for bodily injury, property damage, pollutant

releases, accidents and other emergencies.

(b) An R2 electronics recycler shall determine and keep current a written plan and a sufficient

financial instrument that assures proper closure of the facility and protects against

abandonment of any electronics recycling products, components, or materials.

12. Transport

General Principle – An R2 electronics recycler shall transport all equipment, components, and

materials using vendors that possess the necessary regulatory authorizations and in a manner

protective of public health and the environment.

R2 Practices:

(a) An R2 electronics recycler ensures that all equipment, components, and materials to be

transported are packaged appropriately to mitigate the risk they could pose during

transportation to public health or the environment and the level of care warranted by their

intended use.

(b) An R2 electronics recycler obtains documented evidence or a third-party certification

indicating that their transporters possess all the necessary regulatory authorizations and

have had no significant violations of legal requirements during the past 3 years.

13. Record Keeping

General Principle – An R2 electronics recycler shall maintain documents necessary for an

auditor to assess its conformity to the requirements of this standard.

R2 Practices:

(a) An R2 electronics recycler shall maintain applicable records in a single location to show

conformity to each requirement of this standard.

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PART III –

RECYCLING INDUSTRY OPERATING STANDARD (RIOS)

Introduction to RIOS

The intent of the Recycling Industry Operating Standard (RIOS) is to establish a common

standard that integrates the benefits of ISO 9001:2008 (Quality Management System), ISO

14001:2008 (Environmental Management System) and BS/OHSAS 18001:2007 (Occupational

Health and Safety Management System) requirements combined in one Quality, Environmental,

Health and Safety (QEH&S) management system. The Institute of Scrap Recycling Industries,

Inc. (ISRI) recognized the benefits of ISO 9001, ISO 14001 and BS/OHSAS 18001 and decided

to combine all of the pertinent requirements into one common standard that affords organizations

the opportunity to realize the benefits of all of the standards under one scope of registration.

The RIOS Standard is independent of yet complimentary to the Responsible Recycling Standard

(R-2). While the two standards have many similarities and common requirements, separate

registrations are required. RIOS is recognized by the general recycling industry. R-2 is

recognized by recyclers of electronic products and is endorsed by the EPA.

Third party certification plays a critical role towards ensuring sustainable recycling. Perry

Johnson Consulting, Inc. provides consulting services intended to ensure that organizations

wishing to achieve RIOS certification are provided with the necessary guidance to assist in

successful registration to meet the requirements of the RIOS Standard outlined below.

ISRI’s commitment: e-recycling must be done right anywhere and everywhere in the world.

Institute of Scrap Recycling Industries (ISRI)

ISRI is opposed to “sham recycling” and illegal exports; places a strong emphasis on compliance

with both applicable laws and regulations locally and globally. ISRI is committed to ensuring e-

recycling adheres to standardized requirements everywhere in the world.

ISRI has adopted an export policy that is:

• Socially responsible,

• Protects worker health and safety, and

• Ensures environmentally friendly practices on a global scale.

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Benefits of RIOS

RIOS certification has a positive impact on organizational compliance, consumer and community

confidence and profitability. RIOS helps organizations to:

• Monitor, measure and improve product quality, thereby enhancing customer satisfaction,

• Comply with applicable environmental requirements by decreasing environmental risks and

managing costs,

• Improve process performance to ensure the provision of a safe and healthy work environment

at a reduced cost,

• Streamline processes to enhance efficiency and profitability,

• Motivate employees through participation by determining and meeting goals and objectives,

increasing productivity; and

• Promote the organization and enhance its reputation.

RIOS membership is comprised of organizations that perform scrap recycling activities.

Member companies are required to pay an initial materials fee and an annual maintenance fee per

enrolled facility. ISRI members are eligible for discounted fees. Recycling companies that are

not ISRI members are eligible to become RIOS members.

It is possible for organizations to obtain independent third-party certification by registrars

accredited by the ANSI-ASQ National Accreditation Board (ANAB). RIOS certification is more

applicable and cost effective than maintaining certification to several different standards.

RIOS is based on a "Plan-Do-Check-Act" philosophy to support continual improvement. RIOS

outlines the basic elements of the integrated QEH&S management system in six short sections:

1. General Requirements,

2. Policy,

3. Planning,

4. Implementation,

5. Checking and Corrective Action, and

6. Management Review.

The Need for RIOS

Before the inception of RIOS, there were no industry specific management system standards to

address comprehensive QEH&S management. ISRI recognized the value in developing an

integrated QEH&S management system standard for the scrap recycling industry. The ISRI

Services Corporation (ISC) was established to develop and administer the RIOS Program and

complimentary RIOS Implementation Guide.

RIOS members are authorized to use the RIOS Logo in accordance with the current version of

the RIOS Logo Usage Rules.

RIOS certification is based on a three-year cycle consisting of annual surveillance audits for the

first two years and a recertification audit at the end of the third year.

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After the release of The Responsible Recycling (R2) Practices for Use in Accredited Certification

Programs for Electronics Recyclers, in 2008, ISRI developed the R2/RIOS Certified Electronics

Recycler Program as to establish requirements for recycling electronics responsibly.

ISRI recognized the cohesive nature of R2 and RIOS and then combined them into a powerful

management system framework for electronics recyclers.

RIOS Certification

The time necessary to achieve RIOS certification varies from one organization to another

depending on the level of commitment, resources and competencies dedicated to

implementation.

RIOS certification requires RIOS membership. RIOS members are provided with a free copy of

the RIOS Standard.

To achieve RIOS certification, organizations must meet the following requirements:

• Determine, implement and maintain a QEHS management system in accordance with the

requirements of R2 and RIOS.

• Maintain the management system for a sufficient period of time necessary to accumulate

records of conformance to enable an audit team to verify the effectiveness of the EHSMS.

• Schedule an initial certification audit to be conducted by an ANAB-accredited R2/RIOS

Certification Body a few months before you intend to begin the certification process.

• Stage 1 audit (Readiness Review) – This is an audit conducted by the registrar to determine

the extent to which an organization is ready to proceed forward towards formal certification.

• Stage 2 audit – This audit is conducted to determine the extent to which an organization

meets the actual requirements of the standard and other applicable legal or other

requirements to which the organization subscribes.

• Any identified nonconformances have to be resolved by the organization and approved by

the certification body prior to granting full certification.

• R2/RIOS certification granted.

The RIOS Community is maintained on a secure area of ISRI’s website. RIOS members are

granted permission to download RIOS documents, share information, and ask questions. The

RIOS Community is accessible to authorized personnel of RIOS member companies.

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R2/RIOS Program – combines the benefits of RIOS and R2 and:

• Ensures compliance with applicable laws, including laws enacted by countries that have

signed/ratified Basel Convention,

• R2 prohibits exports except where legal and only under certain conditions required to protect

the environment and workers,

• Provides for strict management of focus materials from the time of receipt through final

disposition,

• Requires downstream due diligence,

• Combines, quality, environment and health and safety requirements.

Trends relating to Quality, EHS

The US scrap industry is committed to delivering high quality scrap in suitable volumes for

customers in an environmentally responsible manner.

• Technological developments have improved the quality of scrap over the last many years.

• Improvements in data-sanitization and various separation technologies and shredding have

contributed to enhanced data security.

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RECYCLING INDUSTRY OPERATING STANDARD (RIOS)

SECTION 1: GENERAL REQUIREMENTS

1.1 Scope and Application

ISRI Services Corporation’s (ISC) Recycling Industry Operating Standard (RIOS) has been

developed to establish a framework within which the recycling industry can control and improve

its quality, environmental, and health & safety (QEH&S) performance. ISC recognizes the

importance of sound management practices and the positive impact they have upon these areas of

concern. RIOS provides the scrap processing recycling industry with a structured approach for

implementation of management systems concerned with these issues. The management system

developed by RIOS member companies shall be documented and maintained and shall include a

description of the scope, core elements of the system including their sequence and interactions,

and provide direction to related documentation.

1.2 QEH&S Infrastructure

RIOS member companies shall provide necessary resources for the effective operation of the

QEH&S management system.

1.2.1 Management Structure

Top management shall define QEH&S roles and responsibilities. Roles and responsibilities shall

be documented.

Top management shall appoint (a) QEH&S management representative(s) who is (are)

responsible for:

• Ensuring the QEH&S management system is established, implemented and maintained in

order to meet RIOS requirements, and

• Reporting to top management on the performance of the QEH&S management system.

Top management shall designate a member of top management for ensuring that health and

safety are properly addressed and managed within the system.

1.2.2 Resources and Facilities

Top management shall ensure the necessary resources (including personnel and financial

resources) and infrastructure (including equipment and technology) for the effective operation of

the QEH&S management system.

1.2.3 Document and Recordkeeping Controls

RIOS member companies shall establish documented procedures to control all documents and

records required by the QEH&S management system.

_________________________________________________________________________________________________________


Procedures shall be implemented to ensure that documents are:

• Established and maintained,

• Subject to approval prior to use,

• Reviewed, revised, and amended as necessary, with changes identified,

• Current and accessible at points of use,

• Suitably identifiable, legible, dated with revision dates,

• Removed from use after they become obsolete and where retained for any purpose, clearly

identified as obsolete, and

• External documents are identified and their distribution controlled.

Procedures shall be established to ensure that records are documented and maintained, are

legible, identifiable and traceable to the relevant processes and are readily retrievable and stored

in a manner that protects them from damage or loss.

Record retention times shall be documented.

SECTION 2: POLICY

RIOS member companies’ top management shall establish (a) documented policy(ies) for

QEH&S. Top management shall ensure that the policy(ies) is (are) implemented.

Top management shall ensure that the policy(ies):

a) Is (are) appropriate to the scope of activities performed and potential environmental impacts

and health and safety risks,

b) Include(s) a commitment to comply with all relevant EH&S legal, customer and product

requirements, industry guidelines relevant to RIOS member company industries, and any

other QEH&S commitments made by the RIOS member company,

c) Include(s) a commitment to continual improvement,

d) Includes a commitment to preventing workplace injuries,

e) Provide(s) a mechanism for establishing QEH&S goals,

f) Demonstrate(s) top management’s commitment to customer satisfaction,

g) Include(s) a commitment to preventing pollution,

h) Is (are) communicated to and understood throughout the organization,

i) Is (are) made available to* the public, suppliers, customers, contractors and other interested

parties, and

j) Is (are) reviewed and revised, as necessary and appropriate.

RIOS member companies seeking certification to ISO 14001 requirements will need to extend

this requirement to ensure the environmental portion of the policy is communicated to all

personnel working on their behalf.

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SECTION 3: PLANNING

3.1 Identifying the QEH&S Footprint

RIOS member companies shall identify and document their QEH&S footprint to enable them to

set goals and implement suitable controls and monitoring consistent with their policy(ies). This

footprint shall be kept current. The footprint shall include:

3.1.1 Important Environmental Impacts and Health & Safety Risks*

Participating organizations shall establish (a) process(es) to identify the actual and potential

environmental impacts and health & safety risks of their activities, products, and services, giving

consideration to routine and non-routine activities (including emergencies). RIOS member

companies shall include activities, products and services they perform or provide and those that

are performed on their behalf or provided to them by contractors and suppliers.

RIOS member companies shall establish processes to determine and identify those

environmental impacts and health & safety risks that are most relevant to their operations.

3.1.2 Legal, Product, and Other Relevant Requirements

RIOS member companies shall establish (a) process(es) to identify and have access to applicable

legal, product and customer requirements, and other QEH&S requirements associated with other

requirements to which they subscribe.

*RIOS member companies seeking certification to ISO 14001 and/or the OHSAS 18001 will

need to expand this commitment to include the identification of environmental aspects that cause

environmental impacts and health & safety hazards that cause health & safety risks. The

Standards should be consulted for additional information.

3.2 Improvement Planning

In order to achieve QEH&S improvement, top management shall establish documented QEH&S

goals.

RIOS member companies shall give consideration to their QEH&S policy(ies) and QEH&S

footprint when setting goals. Goals may be applicable to the entire RIOS member company or

may apply to a particular function or responsibility.

RIOS member companies shall give consideration to technological options, financial, operational

and business requirements, and the views of interested parties when setting goals.

QEH&S goals shall be supported by designated responsibilities and time frames for

achievement.

Goals shall be measurable and quantitative where appropriate, and revised as necessary when

changes occur within the organization.

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SECTION 4: IMPLEMENTATION

4.1 Training

RIOS member companies shall ensure that personnel with responsibility for work activities that

can affect quality performance, have important environmental impacts, or have important health

& safety risks are competent based upon education, training, skills and/or experience and are

aware of their role within the QEH&S management system.

RIOS member companies shall establish processes to:

a) Determine QEH&S competency requirements and identify and provide training to enhance

competency taking into consideration different levels of responsibility, ability, literacy and

required work activities, and

b) Determine awareness training requirements QEH&S related to the management system and

identify and implement awareness training to ensure employee awareness of:

• Their roles and responsibilities in relation to the QEH&S management system,

• The manner in which they contribute to the achievement of the policy and QEH&S goals,

• The importance of conforming to (the) QEH&S policy(ies), processes, and procedures,

• Relevant environmental impacts and health & safety risks associated with the scope of

work they perform,

• The potential consequences of departing from QEH&S operating procedures, processes,

and requirements, and

• The benefits of personal improvement to quality, environment, and health & safety

performance.

RIOS member companies shall ensure any training provided is effective.

Records of education, training, skills and experience shall be maintained.

4.2 Communication

Top management shall ensure that communication processes take place within the company and

with customers and external interested parties.

_________________________________________________________________________________________________________


4.2.1 Internal Communication*

Internal communication processes shall include communications regarding:

• The structure of the QEH&S management system,

• Relevant environmental impacts and health & safety risks and related environmental and

health & safety information,

• Effectiveness of the management system, and

• The importance of meeting customer, legal and other requirements.

Provisions for employee feedback and consultation shall be included in health & safety

communication processes.

*RIOS member companies seeking certification to the ISO 14001 will need to extend this effort

to include the communication of environmental aspects. The Standard should be consulted for

additional guidance.

4.2.2 Customer Communication

Customer communication processes shall include communications related to:

• Product information,

• Customer inquiries, contracts, and order handling, including changes,

• Customer feedback, including complaints, and

• Assessments of customer perception.

4.2.3 Supplier Communication

Supplier communication processes shall include communications related to QEH&S

requirements. This shall include communicating purchase requirements to suppliers prior to

purchase.

4.2.4 Contractor Communication

Contractor communication processes shall include communications related to QEH&S

requirements.

4.2.5 Interested Party Communication*

External interested parties communication processes shall include requirements for receiving,

documenting, and responding to QEH&S related communications from external interested

parties.

_________________________________________________________________________________________________________


*RIOS member companies seeking certification to the ISO 14001 will need to extend this effort

to include a decision as to whether and how significant environmental aspects are to be

communicated. The Standard should be consulted for additional guidance.

4.3 Operational Controls

RIOS member companies shall give consideration to their operations and activities associated

with their QEH&S footprint and goals and establish processes and documented procedures to

ensure they are performed in a controlled manner and that suitable production equipment is

available.

Documented procedures and work instructions shall be established where their absence might

lead to a deviation from the QEH&S policy or goals. Procedures shall define the operating

criteria.

4.3.1 Customers

RIOS member companies shall establish requirements, processes and written procedures

necessary for production and distribution to ensure customer and product requirements and goals

are met and that consuming facilities are authorized to receive product. This shall include

ensuring product traceability, control of customer property, and shipping and delivery

requirements when this is the responsibility of RIOS member companies.

4.3.2 Suppliers

Participating organizations shall establish requirements, processes and documented procedures to

ensure source control of raw materials. This shall include processes to qualify and select

suppliers and ensure raw materials received from suppliers meet requirements. Records shall be

maintained.

4.3.3 Contractors

RIOS member companies shall establish requirements, processes, and written procedures

necessary to ensure contractors comply with QEH&S management system requirements.

4.4 Emergency Preparedness

RIOS member companies shall determine and implement processes to identify the potential for

and respond to incidents, accidents and emergency situations. These processes shall include the

prevention and mitigation of adverse environmental impacts and injuries and illnesses that may

be associated with them. The RIOS member company shall test these processes to whatever

extent necessary on a periodic basis. Prior to tests, incidents, accidents or emergency situations,

the company shall review and where necessary, revise its emergency preparedness and response

processes as required in 5.2 Nonconformance and Corrective and Preventive Action.

_________________________________________________________________________________________________________


SECTION 5: CHECKING AND CORRECTIVE ACTION

5.1 Monitoring and Measurement

Participating organizations shall establish processes to monitor, measure, validate, and record

characteristics of their operations that are vital to ensuring effective QEH&S performance,

achievement of goals, and product conformity to product requirements. This shall include

monitoring the management system and supporting goals. Measures may be quantitative and

qualitative. Monitoring data shall be analyzed to provide evidence of the effectiveness of the

management system and assess continual improvement.

5.1.1 Supplier Qualification and Verification of Raw Materials

RIOS member companies shall establish processes to verify raw materials to ensure source

control. Verification results shall be given consideration during supplier qualification and

selection.

5.1.2 EH&S Compliance

RIOS member companies shall determine and implement processes to monitor compliance to

applicable EH&S legal and other requirements to which the RIOS member company subscribes.

5.1.3 Maintenance and Calibration of Monitoring Equipment

RIOS member companies shall determine, maintain and ensure the necessary QEH&S

monitoring and measurement equipment is calibrated to ensure it functions properly.

Maintenance and calibration records shall be maintained.

5.2 Nonconformance and Corrective and Preventive Action

RIOS member companies shall establish documented procedures to address and eliminate the

causes of nonconformances and potential nonconformances. The process shall:

• Assign responsibilities,

• Ensure cause analysis is performed,

• Ensure actions to address nonconformance and prevent recurrence that are appropriate to the

affects of the nonconformance, and

• Include a review of corrective and preventive actions for effectiveness.

Records shall be maintained of nonconformances and preventive and corrective actions.

_________________________________________________________________________________________________________


5.2.1 Control of Nonconforming Product

RIOS member companies shall ensure that product, which does not conform to product

requirements, is identified and segregated to prevent its unintended use or delivery.

Nonconforming product may be reworked, released to the customer with concessions or used for

other purposes. Nonconforming product shall be identified and any actions taken recorded.

5.3 QEH&S Management System Audits

RIOS member companies shall establish written (a) procedure(s) to periodically evaluate:

• The QEH&S management system’s conformance to RIOS; and

• The suitable implementation and maintenance of the QEH&S management system.

The procedure(s) shall define the audit scope, considering the status and importance of QEH&S

processes and results from previous audits, schedule, responsibilities, and reporting of results.

Auditors shall not audit their own work.

SECTION 6: MANAGEMENT REVIEW

Top management shall review the QEH&S management system annually at minimum, to ensure

its adequacy and effectiveness. Records of management review shall be maintained.

Input to management review shall include:

• Audit results,

• Feedback from customers and other interested parties,

• Progress towards goals,

• Status of preventive and corrective actions,

• Follow-up actions from previous management reviews,

• Changes that could affect the QEH&S management system, and

• Recommendations for improvement.

Management review outputs shall include:

• Decisions and actions related to the future direction of the QEH&S management system such

as changes to the policy and goals,

• Resource needs, and

• Improvements to products.

_________________________________________________________________________________________________________


PART IV – RoHS and REACH

Restriction of Hazardous Substances Directive (RoHS)

The directive on the restriction of the use of hazardous substances in electrical and electronic

equipment 2002/95/EC (commonly referred to as the Restriction of Hazardous Substances

Directive or RoHS) was adopted in February 2003 by the European Union. The RoHS directive

took effect on 1 July 2006, and is required to be enacted as law in member states within the

European Union. RoHS, sometimes known as the lead-free directive restricts the use of six

hazardous materials in the manufacture of electronics and electrical equipment. The RoHS

directive is aligned with the Waste Electrical and Electronic Equipment Directive (WEEE)

2002/96/EC that defines requirements for the collection, recycling and recovery targets for

electrical products. The RoHS directive is part of a legislative action to address challenges

represented by of substantial quantities of toxic ewaste.

Each European Union member state is required to adopt enforcement and implementation

policies referencing the RoHS directive for guidance. RoHS imposes restrictions on the use of

the following six substances:

1. Lead (Pb)

2. Mercury (Hg)

3. Cadmium (Cd)

4. Hexavalent chromium (Cr6+)

5. Polybrominated biphenyls (PBB)

6. Polybrominated diphenyl ether (PBDE)

PBB and PBDE are flame retardants used in many types of plastics. Hexavalent chromium is

utilized in various chrome plating processes. Maximum permitted concentrations and guidelines

are provided within the directive for determining quantities of hazardous materials within

different types of electronics and electronic products.

The European Commission changes to the RoHS directive.

Batteries are not covered under RoHS. The European Commission's Battery Directive originally

released in 1991 and revised in 2003, which will be official when submitted to and published in

the EU's Official Journal. The initial release of the Battery Directive addressed possible trade

barriers stemming from ambiguous requirements implemented by various European member

states. The new directive more explicitly defines requirements for protecting the environment

from the negative effects of waste streams associated with battery disposal. It also contains

requirements for additional recycling of industrial, automotive, and consumer batteries. It also

sets threshold limits for mercury and cadmium to batteries. Additional restrictions are placed on

lead, lead-acid, nickel and nickel-cadmium in batteries. There are additional requirements for

marking batteries with symbols describing metal content and recycling collection information.

_________________________________________________________________________________________________________


The directive applies to equipment defined within the WEEE directive. The following categories

apply:

1. Large household appliances,

2. Small household appliances,

3. IT & Telecommunications equipment,

4. Consumer equipment,

5. Lighting equipment – including light bulbs,

6. Electronic and electrical tools,

7. Toys, leisure, and sports equipment,

8. Medical devices (exemption removed in July, 2011),

9. Monitoring and control instruments (exemption removed in July, 2011),

10. Automatic dispensers,

11. Semiconductor devices.

Examples of products or components containing restricted substances include:

Leaded components:

• Paints and pigments,

• PVC cables,

• Solders,

• Printed circuit boards and related products,

• Leaded Glass from televisions and computers – Cathode Ray Tubes (CRTs),

• Metal parts,

• Lamps and bulbs, and

• Batteries.

Cadmium is found in many products and materials including batteries, photocells and plastic

pigmentation.

Mercury is used in lighting and various types of switches.

Hexavalent chromium is used for metal finishing.

Polybrominated biphenyls and diphenyl Ethers/Oxides are used as flame retardants in plastic

products.

_________________________________________________________________________________________________________


Hazardous Materials and Electronic Waste

RoHS was developed to reduce the presence of hazardous materials used in electronics and

electronic products to mitigate the impact of electronics waste. Electronics waste often ends up

in landfills in undeveloped countries.

American electronics are often “recycled” in undeveloped African nations or other parts of the

world where environmental and safety practices are minimal or nonexistent. Workers, young

and old experience adverse health affects due to exposure to heavy metals. Many of these same

heavy metals are returning to the U.S. in contaminated products.

RoHS Applicability

In addition to challenges related to the proper disposal of used or end-of-life electronics

products, RoHS gives additional consideration to the effects of long term exposure to various

materials and related impacts on human health. The EPA has conducted Life Cycle Assessments

(LCAs) on various materials to determine the extent to which they adversely affect the

environment as well as human health and safety.

Various types of items are excluded from RoHS requirements giving consideration to costs,

benefits and risks associated with their use. Such items include solar panels, some medical

devices (category 8) and some measuring equipment (category 9). The EU realizes that many of

these products are produced in small quantities and possess an extended life span. Many of these

products are used in critical applications where their failure can be adverse or catastrophic.

The EU has established a temporary moratorium on RoHS enforcement for Category 8 and 9

products.

With few exemptions, RoHS covers most types of electrical equipment including some medical

devices and monitoring and control equipment which have been previously exempted due to

various constraints. Exemptions to product from categories 8 and 9 will be gradually phased out

over time.

Labeling

RoHS does not imply labeling requirements. Many manufacturers have developed compliance

marks to reduce confusion. Visual indicators include "RoHS compliant" and other similar labels.

Other standards

RoHS is not the only environmental standard governing electronics. Various industries are

developing their own standards the include requirements that are far more stringent than those

required for compliance purposes to ensure that requirements are met or exceeded for all cities,

states and countries.

_________________________________________________________________________________________________________


Challenges

The drawbacks associated with RoHS compliance include adverse effects on overall product

quality and the cost of compliance. RoHS also comes under fire for restricting lead and

cadmium in electronic products and components but does not address other more common

applications.

RoHS mandates the use of lead-free solder giving rise to concerns about the long-term reliability

of electronic equipment and components, especially in equipment used for critical operations.

Some of the critical issues resulting from the use of "lead-free" solder includes issues, such as:

1. Warping or delamination of circuit boards,

2. Damage to internal features on circuit boards,

3. Potential “Tin Whisker” growth, and

4. Added sensitivity to moisture.

Health Benefits

RoHS helps mitigate adverse effects to people and the environment in developing countries

where materials are sent for processing or disposal. The use of lead-free solders and other

products reduces health and environmental risks to workers in the electronics industry.

Reliability

Concerns related to product capability have not been realized as many of the innovations

necessary to meet RoHS requirements have resulted in the use of more user friendly and

effective materials. Innovations and technological advances continue to be the norm for printed

circuit boards and other electronics equipment and components.

Some exempt products achieve compliance. New alloys and technologies are currently exempt

from compliance to RoHS requirements until they are suitably assessed and characterized.

Registration, Evaluation, Authorization and Restriction of

Chemicals (REACH)

Registration, Evaluation, Authorization and Restriction of Chemicals (REACH) is a European

Union Regulation established on December 18, 2006. REACH addresses the production and use

of chemical substances, and their potential impacts on both human health and the environment.

REACH is 849 pages long and took seven years to pass. REACH is considered by many to be

the most complex legislation in the history of the European Union and maybe the most

important. REACH was developed to manage chemical substances and will have a far reaching

impact on industries all over the world.

_________________________________________________________________________________________________________


REACH became active on June 1, 2007. Phased implementation is scheduled over the next

decade.

When REACH becomes fully active, all organizations manufacturing or importing chemical

substances into the European Union in quantities of one ton or more per year will be required to

register these substances with the European Chemicals Agency (ECHA) in Helsinki, Finland.

Because REACH some of the substances REACH applies to are contained in articles, any

company importing goods or materials into Europe may be affected. The European Chemicals

Agency has determined three major deadlines for registering chemicals based on the quantity

manufactured or imported. REACH registration requirements are to be phased in progressively

over a given period of time. Thresholds and dates necessary for registration are as follows:

• December 1, 2010 – 1,000 tons,

• June 1, 2013 – 100 tons, and

• 1 June 1, 2018 – 1 ton.

Roughly 143,000 chemical substances were pre-registered in the European Union by the

December 1, 2008 deadline. Although pre-registration is not mandatory, it allows potential

registrants to register materials at their own pace. It is illegal to supply substances to the

European Union that have not been registered (known in REACH as “no data, no market”).

REACH requirements also address the continued use of chemical substances of very high

concern (SVHC) because of the potential for adverse impacts on human health or the

environment.

REACH applies to all chemicals imported or produced in the EU. The European Chemicals

Agency oversees the technical, scientific and administrative aspects of the REACH system.

To simplify the registration of the 143,000 substances and to limit vertebrate animal testing,

Substance Information Exchange Forums (SIEFs) are formed amongst organizations dealing

with the same or similar substances. This allows them to participate in a collaborative manner to

produce and maintain one registration dossier. This also creates new challenges because a SIEF

represents the cooperation between enumerative legal entities that must:

• Locate each other and start communicating in a manner that is open and honest,

• Share meaningful data and costs in a fair and transparent manner, and

• Participate in a democratic manner and achieve consensus to make complex decisions

necessary to complete a dossier with several thousand end points within a given time frame.

The European Commission provides free (IUCLID) software to businesses affected by REACH

which simplifies the process of accumulating, storing and submitting data for chemical

properties and effects. The submission of chemical data is a mandatory component of the

registration process. Chemical Safety Assessment (CSA) may be required and a Chemical

Safety Report (CSR) assuring the safe use any applicable substances has to be submitted with the

dossier. Dossier submission is accomplished using the web-based software REACH-IT.

_________________________________________________________________________________________________________


History of REACH

REACH represents a comprehensive revision of EU chemical policy. REACH passed the first

reading in the European Parliament on November 17, 2005. The Council of Ministers endorsed

REACH on December 13, 2005. The European Parliament approved REACH on December 13,

2006 and the Council of Ministers formally adopted it on December 18, 2006. There have been

various costs and benefits studies associated with REACH yielding a wide diversity of results.

REACH came into force on January 20, 2009, and will be fully implemented by 2015. A related

regulation – the CLP Regulation (for “Classification, Labeling, Packaging”) – utilizes the United

Nations Globally Harmonized System of Classification and Labeling of Chemicals (GHS) and

will supersede the previous Dangerous Substances Directive and Dangerous Preparations

Directive.

Philosophy

The legislation was proposed to address the protection of human health and the environment.

The use of potentially toxic substances is not desirable. REACH will ensure the use of certain of

substances will be phased out over time. Using potentially toxic substances can lead to excessive

exposure by direct or indirect means.

There was very little safety information available for 99 percent of the chemicals on the market

prior to 1981. Many substances have the potential to bioaccumulate in the human body, thus

reaching dangerous concentrations or react with each other, producing new substances with new

risks.

Controversy and Challenges

In addition to the potential costs and the complexity of the new law, REACH has also attracted

concerns because it is linked to animal testing. Animal tests on vertebrates are allowed only

once per one substance, and where suitable alternatives cannot be used. Companies that pay for

tests must sell the rights to the results for a "reasonable" price. There are concerns that gaining

access to necessary information may be very costly for potential registrants wishing to purchase

this information. While costs may go up, the number of animals required to support testing will

go down.

There are additional concerns that REACH could potentially diminish global trade and that some

"pre-registrants" may be consultants hoping for work while others may profit by charging

exorbitant rates for data in their possession.