The document discusses responsible recycling (R2) practices for electronic waste. It provides background on the growth of electronics usage and challenges of managing end-of-life electronics. It describes the development of the R2 practices through a multi-stakeholder process to establish standards for certified recyclers. The R2 practices aim to promote the safe reuse and recycling of electronics while ensuring environmental and worker protection.

1. Responsible Recycling (R2):
A Different Approach
to a Different Waste Stream
Beth Pelland
Executive Committee
Perry Johnson Registrars, Inc.
PERRY JOHNSON
REGISTRARS, INC.
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2. Beth Pelland
Senior Member of the Executive Committee and Lead Auditor
• Conducting ISO 9001, ISO 14001, OHSAS 18001,
ISO/TS 16949, and R2 audits.
• Presenting numerous seminars and workshops on quality
management systems, organizational management, and
leadership and team building.
PERRY JOHNSON
REGISTRARS, INC.
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3. PERRY JOHNSON
REGISTRARS, INC.
PJR is one of the largest certification bodies in the world.
International presence:
– HQ - Southfield, MI
– Numerous offices throughout the United States
– Monterrey and Mexico City, Mexico
– Milan and Caserta, Italy
– 7 offices in Japan, including Tokyo
– Bangkok, Thailand
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REGISTRARS, INC.
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4. PERRY JOHNSON
REGISTRARS, INC.
Accredited by ANAB (United States), EMA (Mexico), INMETRO
(Brazil), UKAS (United Kingdom), RvA (Netherlands), SINCERT (Italy)
and JAB (Japan)
Accredited to grant certification for:
– ISO 9001:2008
– ISO 14001:2004, Responsible Care, RCMS
– OHSAS 18001:2007 (health safety)
– ISO/TS 16949:2009 (automotive)
– AS9100, AS9110, AS9120
– ISO 13485:2003 (medical devices)
– ISO 22000:2005 (food safety)
– ISO 27001:2005 (information security) PERRY JOHNSON
REGISTRARS, INC.
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5. PERRY JOHNSON
REGISTRARS, INC.
Responsible Recycling (R2)
PJR is one of two ANAB Accredited certification
bodies worldwide that is able to offer accredited
certification to R2.
PERRY JOHNSON
REGISTRARS, INC.
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6. PERRY JOHNSON
REGISTRARS, INC.
Accreditations are pending for:
– BS 25999-2 Business Continuity Management Systems
– RIOS - Recycling Industry Operating Standards
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7. Topics
Growth and management of Essential R2 Concepts
used electronics. – Understanding R2 Practices
Development of the R2 – R2 Checklist
practices
– Integration/comparison to
Export Rules/Regulations ISO standards
– Basel Convention R2 Certification
– OECD – Governing Rules
Domestic
– Stage 1
Rules/Regulations
– Stage 2
– State Laws
– Steps to Certification
– EPA Rules
Expectations for R2
Q&A
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8. Growth of Electronic Use
Last year, Americans purchased an
estimated 500 million new consumer
electronic products.
According to the Consumer Electronics
Association (CEA), the average
American household owns 15 separate
electronic products.
In 2010, the Federal Government is
expected to spend 75 billion for IT
goods and services.
PERRY JOHNSON
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9. U.S. Management of Used and
End-of-Life Electronics
Over the last decade, consumers doubled
the amount of electronics they discard
However, consumer electronics still only
comprise about 1.2% of the MSW stream
EPA’s Electronics Waste Management in
the US report, in 2007 tells us that:
– 82% (1.8 million tons) of TVs, cell
phones, and computer products were
disposed, primarily in landfills.
– 18% of TVs and computers were
collected for recycling
– 10% of cell phones were collected for PERRY JOHNSON
recycling REGISTRARS, INC.
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10. How Electronics Differ
from other Waste Streams
Electronics are complex devices
Consist of a wide variety of materials, many of
which would not be classified as hazardous
under EPA testing procedures
Contains hundreds of elements, compounds,
and alloys
– Include steel, plastic, glass, ceramics,
copper, aluminum, lead, nickel, zinc,
lithium, carbon, cadmium, mercury,
beryllium, gold, silver, palladium, flame
retardants, etc.
– Virtually all materials are used for
important functional or safety reasons
– Some of these materials pose risks if PERRY JOHNSON
improperly disposed of or recycled. REGISTRARS, INC.
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11. Environmental Benefits
of Reuse & Recycling
Reuse: extends the life of the
product; increasing use from the In 2007, the US recycled
energy & material inputs 414,000 tons of electronics
resulting in…
Recycling: recovers materials – Greenhouse Gas (GHG)
metals, glass, plastics – reducing Reductions: 974,000
the extraction and processing of MTCO2E, equivalent to the
virgin resources annual emissions from more
than 178,000 passenger
– In a gold mine, one ton of ore vehicles.
contains about only five to 10
Energy Savings: 18 trillion
grams of gold, one ton of cell
BTUs, equivalent to the energy
phones – equivalent to about
content of 140 million gallons of
10,000 cell phones – contains
gasoline.
300 to 400 grams of gold".
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12. Environmental Issues?
Increasing electronics discards raise numerous issues
– some legitimate, some not
– Disposal Danger?
• Some are concerned with toxics from
electronics leaching from landfills, we have no
evidence that land-filling electronics in the US
causes groundwater contamination
• But there is some improper disposal in some
developing countries – open burning
– Recycling Risks?
• EPA does not regulate how e-recyclers
recycle the material; some practices are
sound, some are not
• Primitive recycling processes in developing
countries have been shown to cause public
health and environmental impacts
– Lost Resources?
• Electronics discarded into landfills or
incinerators represent loss of important
resources – precious metal, plastics, usable PERRY JOHNSON
parts, etc. REGISTRARS, INC.
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13. Electronic Reuse and Recycling:
Not Just an Environmental Issue
Unlike more traditional waste streams, electronics can
provide social and economic benefits
– Social: Bridges the “digital divide”; reuse markets
overseas improve access to information technology
– Economic: Reuse and recycling provides jobs both
domestically and overseas
• Strong foreign demand for raw materials
• From a production view, it makes sense that these
materials go to overseas markets
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14. Increasing Safe Reuse and Recycling
To recognize these benefits and
promote greater electronics product
stewardship, EPA is working to:
Increase reuse and recycling of
used electronics; and
Ensure that management of used
electronics is safe and
environmentally sound
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REGISTRARS, INC.
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15. Responsible Recycling Practices
At a multi-stakeholder electronics summit in March 2005, participants asked EPA to lead
an effort to develop a set of sound recycling practices and a system for certifying
electronics recyclers who met them
EPA convened a multi-stakeholder group to develop a set of practices
– Stakeholders included: States (MN, WA, MD) electronic manufacturers (Dell, HP),
Recyclers/Refurbishers, trade associations (ISRI, Information Technology Institute
(ITI), Microsoft Authorized Refurbishers (MARs) and NGO’s (Basel Action Network,
Electronics Take-back Coalition)
R2 document process:
– Drafted by neutral facilitator (EPA funded) in a consensus-driven process
– Each version was discussed by working group and revised by facilitator
– Reviewed by 4 experienced auditors
– Field tested at 6 recyclers (included a range of sizes and processes)
– EPA’s role in helping to get documentation from foreign countries was tested (China,
Hong Kong, India)
– R2 represents efforts of multiple stakeholders over a 3-year process; NGOs
participated until the end, but left because of several key concerns. They have now
developed their own approach PERRY JOHNSON
REGISTRARS, INC.
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16. R2 Practices
Posted on EPA’s website at:
www.epa.gov/epawaste/conserve/materials/ecycli
ng/r2practices.htm
It is also found on the facilitators website at:
www.decideagree.com/TheR2Practices.html
– Includes the auditors check list
Developers are discussing how best to keep the
practices current and relevant
– Permanent home to be chosen
On July 27, 2009 ANAB announced the
availability of the accreditation rule for R2
– ANAB Rule #34
EPA is encouraging all refurbishers and recyclers
to be certified to R2
– Third-party Accredited Certification based on
ISO 17021:2006
– Currently, there are 2 Accredited Registrars
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17. Scope of R2 Practices
Sets a high bar for environmental and worker protection
Establishes environmental, worker safety, and public health practices
Includes 13 general principles, and specific practices for recyclers to follow
The practices largely go beyond what is required under regulation – recyclers are not
required to be certified to R2
Some States have, or are, developing standards in their electronics regulations based
on R2, e.g., Washington, Oregon
As R2 gains footing, an increasing amount of used electronics will be managed by
recyclers that adhere to sound practices – where ever the material is
Covers electronics equipment including: computers, peripherals, cell phones,
televisions, gaming systems…
Materials getting specific “focus” are equipment and components containing:
– Cathode ray tubes and glass
– Circuit boards
– Batteries
– Items containing mercury/PCBs
– While not a “focus” material, toner and toner cartridges have special on-site
requirements identified
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18. Features of R2 Approach
Signifies an upgrade of existing practices
– Due diligence requirements, documentation of legality from countries of
import
– Proper on-site practices are identified
– Requires clearing personal data from memory
Allows export of materials if shown to be legal and if goes to sound recyclers
Through field testing, R2 was found to be a practical approach that can be
integrated into existing ISO systems.
Smaller recyclers, refurbishers able to meet R2 if they have sound practices
– Requires EMS and safety, but does not specify full ISO requirements
R2 precludes landfill or incineration of focus materials
– But allows for landfill and incineration in extraordinary circumstances
R2 represents a sound and practical set of practices that if used will reduce
issues surrounding electronic recycling significantly
PERRY JOHNSON
REGISTRARS, INC.
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19. Details on Exports
R2 requires exports of focus materials to be
legal and responsible, by having:
Export Markets
Recycler’s responsibility extends to conducting
due diligence on “focus materials” to Reuse allows usable
international markets; and electronics to be used in
Recycler must show documentation that export developing countries
of any focus material to any non-OECD country
is legal e-Scrap exported to
countries can be used in
– Law or court ruling; manufacturing new
– Letter from the competent authority; or equipment
– Request documentation from EPA
• EPA website has information of who to US has no smelters or
contact with what information glass furnaces to refine
• Concept of Prior Informed Consent copper/precious metals
requires documentation prior to from circuit boards or
shipment produce new CRT glass
Future: EPA website with information on
PERRY JOHNSON
exports REGISTRARS, INC.
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20. International Rules: OECD Countries
Organization for Economic Cooperation and Development
30 OECD Countries – Mostly Developed
– North America, West & North Europe, Australia, Japan, S. Korea &
Mexico
Well-established system for hazardous waste recovery
– Covers recovery (recycling) only and facilitates trade
– Notice and consent system, but more stream lined then Basel
– Allows for tacit consent and pre-approved facilities
– Some differences in hazardous waste list from Basel – more risk based
• Basel looks at inherent toxicity – EPA rules consider risk
To date, only CRTs have moved as hazardous waste under OECD controls
— SLABs will be included in 2010
www.epa.gov/epawaste/hazard/international/oecd-slab-rule.htm
Requires notification and consent for export of SLABs—CFR 40 part 262,
subpart G and H
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21. For a list, go to: http://www.oecd.org
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22. International Rules: Basel Convention
U.S. is not a Party to the convention; however, over 170 countries are
– US signed the Convention in 1990; Senate provided its advice and consent to ratify in 1992
– EPA has not been given the necessary statutory authority to implement the Convention, enabling
us to ratify
– Every U.S. Administration has been in favor of ratification
Basel established a control system on the import and export of hazardous wastes to prevent dumping of
hazardous waste in developing countries
– Requires written notification and consent of countries of export, import and transit
– EPA assistance in getting documents.
– Waste list is based on presence of toxics, not risk
– U.S. perspective is based on risk
– Basel hazardous waste is treated the same if going for recycling or disposal
– U.S. has streamlined rules to encourage recycling
US can not recycle or dispose of hazardous waste in non-OECD countries without a bilateral agreement
– U.S. does not have such agreements with non-OECD countries;
– Countries can not legally accept hazardous waste for the purposes of recycling or disposal from us
• There are no Basel enforcement agencies
List of Basel Competent Authorities: www.basel.int; on left side click “country contacts”
US Competent Authority: For R2 Patti Whiting – whiting.patti@epa.gov PERRY JOHNSON
REGISTRARS, INC.
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23. Hazardous Waste Definition:
Basel versus U.S.
Countries interpret Basel Waste lists within their own domestic law, hence
waste definitions may vary between countries.
– Knowledge of the rules of importing and transit countries is important
Basel applicability is sometimes unclear for electronics
– Shipments for repair/refurbishment is under debate
Basel definition of “hazardous waste” differs from U.S. rules especially with
regards to non-traditional waste streams
– U.S. conditionally exempts hazardous waste from regulation or exclude a
material from being a waste to encourage recycling
– Basel treats material going to recycling and disposal as the same
– Most electronics waste in U.S. is either non-hazardous or non-waste
Basel convention supports the concept that hazardous waste should be
managed in an environmentally sound manner (ESM) and that transboundary
shipments should be reduced - treat waste where generated!
PERRY JOHNSON
REGISTRARS, INC.
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24. BAN & the BAN Amendments
to the Basel Convention
BAN (Basel Action Network): is an independent charitable organization with NO
direct ties to the Basel Convention.
– Promotes ratification of the Basel Convention
– Promotes ratification of the BAN Amendment to the Basel Convention
– Promotes e-stewards as the ONLY way to manage e-waste
– Charges a licensing fee for e-stewards certification in addition to the general
cost of certification, based on organization revenues
BAN Amendment: Proposed amendment to the Basel Convention that would
ban hazardous waste exports for final disposition or recycling from Annex VII
countries (Basel Convention parties that are members of the EU, OECD and
Liechtenstein) to non-Annex VII countries (all other parties to the convention).
– Requires ¾ vote of all parties
– Not in force
– E-stewards’ standard requires recyclers to act as if the BAN Amendment was
ratified and supported by the U.S.
PERRY JOHNSON
REGISTRARS, INC.
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25. State Electronics Laws
Currently 20 States and NYC (current lawsuit) have electronics take-back
laws — follow a “Producer Responsibility Approach”
– Most address TVs (e.g., Texas HB 2714 does not) and PCs; some also
address peripherals and cell phones
– Most require manufacturers to pay for collection/recycling through take-
back programs — OEM must label all equipment it sells
– Very few laws specify how the material should be handled by the recycler
• Kansas & Illinois use R2 language in their recycling law, Washington
State; WAC 173-900-650 gives preferred status for R2 certification
– 11 States and NYC also ban disposal of these electronics in landfills
• Most also require take-back
– Each law is slightly different from the other — California uses an “ARF”
approach — consumers pay “up-front”
Resources on State Laws
– www.ElectronicsRecycling.org
– www.electronicstakebac.com
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REGISTRARS, INC.
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26. EPA’s APPROACH TO WASTE
MANAGEMENT HAS EVOLVED TO
ENCOURAGE REUSE AND RECYCLING.
Universal Waste Rule:
– Mercury-containing devices are in this rule and are considered
hazardous waste, but have streamlined requirements when going for
recycling or disposal
CRT Rule:
– CRTs and CRT glass are not considered solid or hazardous waste when
reused or recycled if certain conditions are met (40 CFR, Subpart E,
261.39). Similar streamlined requirements as Universal Rule.
Responsible Recycling Practices (R2):
– Includes a broader spectrum of electronic materials; complements the
other traditional approaches; does not replace any of the electronics
recyclers legal obligations
PERRY JOHNSON
REGISTRARS, INC.
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27. CRT Rule
To encourage reuse, recycling, and better
management of this rapidly growing waste stream.
CRTs are the video display component of computers
and TV monitors. Many CRTs from color monitors
fail EPA’s testing requirement (TCLP) for lead.
Not Regulated:
Households: May send used CRT monitors to any
collector for recycling or disposal.
– Recyclers need to show 100% of material from
households to be exempt
Small Quantity Generators: Non-residential
(businesses) generators of less than 100 kg. per
month (about 7 or 8 monitors) are not subject to
most Subtitle C standards.
Customers: May send any CRTs to a recycler for
potential reuse, repair or recycling. PERRY JOHNSON
REGISTRARS, INC.
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28. CRT Rule:
Domestic Recycling Requirements
Requirements for Recyclers:
Used Intact CRTs sent for recycling within the U.S:
– Labeling
– No speculative accumulation.
• 1 year- CFR 261.1 (e) (8)
Used broken CRTs sent for recycling within the U.S.
– Packaging and labeling for storage and shipment,
– No speculative accumulation.
Requirements for Glass Processors:
Store CRTs indoors, or package and label them.
No speculative accumulation.
No temperatures high enough to volatilize lead.
CRT Labeling:
“used cathode ray tubes- contains leaded glass” OR “leaded glass from televisions or
computers”, AND “do not mix with other glass materials”.
Must also follow any specific state rules e.g. PERRY JOHNSON
Maine “Waste Cathode Ray Tubes” REGISTRARS, INC.
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29. CRT Rule Definitions
CRT Glass Processer:
Must do all three:
– Receive broken or intact CRTs;
– Intentionally break or separate;
– Sort or otherwise manage (e.g., clean) glass
removed from CRT monitors.
Processed Glass:
If sent to a glass manufacturer or a lead smelter,
not regulated.
If sent to other kinds of recycling, may be
excluded on a case-by-case basis.
No speculative accumulation.
No CRT glass manufacturers currently in U.S.
– Glass to Glass furnaces located in Asia PERRY JOHNSON
REGISTRARS, INC.
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30. CRT Smelters – Glass to Lead Recovery
DOE Run – St. Louis
Xstrata – Canada (New Brunswick and Rouen)
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31. CRT Furnaces- Glass to Glass
Videocon – Poland and India
Samtel – India
Samsung – Malaysia
Hankuk Electric – S. Korea
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32. Export Requirements:
Used CRTs and CRT Glass Export for Recycling:
Exporter must send notice to EPA 60 days before
shipment. May cover export activities extending
over a 12 month or lesser period.
EPA forwards notice to the receiving country, then
forwards response to the exporter.
– Export may take place only when consent has
been received.
No speculative accumulation.
Used Intact CRTs Export for Reuse:
Exporters must send a one-time notification to
state or EPA with contact info and a statement that
the exporter plans to export the CRTs for reuse.
Must keep normal business records demonstrating
reuse for three years. PERRY JOHNSON
REGISTRARS, INC.
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33. CRT Rule Notices
List of facilities approved to export CRTs and CRT glass for
recycling on EPA website at:
www.epa.gov/osw/hazard/international/crts/recycling.htm
– Facilities approved to export CRTs for recycling – about 32.
– Table lists the US exporter name, site address, and end date
for CRT shipments.
– If exporting processed CRT glass – no export notifications.
List of facilities that have filed the one time notice for export of
CRTs for reuse can be found on EPA’s website at:
www.epa.gov/osw/hazard/international/crts/reuse.htm
– Facilities filing one-time notices on exporting CRTs for reuse –
about 60.
Data on both lists are updated periodically.
PERRY JOHNSON
REGISTRARS, INC.
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34. CRT Rule Enforcement
EPA has initiated over thirty civil
investigations in eight out of ten EPA
Regions
Plan to conduct additional inspections and
information gathering efforts in FY 2010.
– EPA has settled violations with two
companies and filed three civil
administrative complaints.
– EPA has determined that seven
companies did not have any violations.
PERRY JOHNSON
REGISTRARS, INC.
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35. Other Electronic Materials
Most electronics sent for recycling are not
classified as hazardous wastes.
Whole used and shredded circuit boards are
exempted from regulation if they meet
certain requirements (i.e., mercury and
batteries have been removed)
Unclear whether devices have enough Hg
(switches, backlighting) to test hazardous
under RCRA.
– Some states include this material under
universal waste rules.
PERRY JOHNSON
REGISTRARS, INC.
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36. Contacts
Karen Pollard (R2)
703-308-3948
Pollard.karen@epa.gov
Patti Whiting (Export Issues)
703-308-8421
Whiting.patti@epa.gov
Marilyn Goode (CRT Rule)
703-308-8800
Goode.marilyn@epa.gov
PERRY JOHNSON
REGISTRARS, INC.
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37. Essential “R2” Concepts
Reuse and Recycling Required
– Disposal of focus materials only in
exceptional circumstances
On-site Worker & Environmental Protection
– Federal OSHA consulted for section
– On-going hazard identification & assessment
of risks
– Special handling for focus materials
Downstream Due-Diligence for Focus Materials
– Throughout the recycling stream
– Includes international vendors
– Written focus material management plan for
recyclers & downstream vendors; posses &
PERRY JOHNSON
have documentation on downstream controls REGISTRARS, INC.
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38. Essential “R2” Continued
Evidence of Legality of Export
– Documentation must be from the Government
Comprehensive Management System
– Includes, environmental, health and safety
concepts
– Includes requirements of many of the
practices
– Written programs using “Plan-Do-Check-Act”
model for continual improvement
Compliance with all Laws and Rules
– An R2 certification audit is NOT a compliance
audit (ANAB Accreditation Rule #9)
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39. R2 Continued…
Destroy, purge or sanitize data from all memory;
– NIST Guidelines for Media Sanitation - 800-
88, or other standard or certification program
(i.e., NAID)
Track throughput and recordkeeping;
– Business records of all transfers of equipment
and materials into and out of facility
Store and transport materials securely and safely;
and
Possess insurance, closure plans and financial
mechanisms to cover the potential risks of the
facility. PERRY JOHNSON
REGISTRARS, INC.
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40. R2 Practice #1
Environmental, Health & Safety
Management System
R2 electronic recycler shall develop and use an EHSMS
– Define scope of the system (e.g. part of a larger complex with some shared activity).
Based on PDCA model for continual improvement
– Policy supporting a “reuse, recover”, dispose hierarchy throughout the recycling
chain.
– Documented goals to support the policy: goals that reflect R2, not “reduction of
paper”
– Policy and goals understood by all employees
– Identification of all site activities (e.g. process flow)
– Identification and monitoring of on-site occupational & environmental risks
– Focus materials plan
– Emergency response
Important to understand the component parts of the PDCA model per note 2
– Includes international monitoring (auditing) and system review to ensure
effectiveness of the EHSMS.
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41. R2 Practice #2
“Reuse, Recover…” Hierarchy of
Responsible Management Strategies
Reuse, Recover, Dispose - Written Policy
– Communicated to employees and downstream vendors
Consistent with FM Plan
– Apply hierarchy to focus materials
Includes control of vendors
– Expect downstream hierarchy to address
reuse/recovery.
PERRY JOHNSON
REGISTRARS, INC.
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42. R2 Practice #3
Legal Requirements
Compliance with all environmental, health, and safety legal requirements
– R2 certification audit is NOT a compliance audit- ANAB Accreditation Rule #9
Export FM components to countries that legally accept them
– Documentation from EPA or Competent Authority: Documents sent with each
shipment
Periodic compliance evaluation
– Identity and document all legal requirements applicable to the facility (e.g. CFR
40, CFR 29, local, state, county regulations, International regulations, etc.)
• Keep in mind that a regulation can have several components or
requirements - a title is not enough!
– Document the steps necessary to comply (e.g. work instruction that shows how
to label CRT’s)
– Take Corrective Action (NOT just correction) for any identified non-compliance
• Fix so it doesn’t happen again
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REGISTRARS, INC.
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43. R2 Practice #4
On-Site Environmental,
Health & Safety
Expertise and capability for processes
Ongoing hazards identification of occupational and environmental risks - e.g.
new processes or materials
– Regular, documented training/refreshers - includes entire workforce (any
volunteers)
Manage risks on priority basis: Engineering controls, Administrative controls,
PPE
Monitor/sample for risk management - e.g. PELS
– Two-way communication encouraged
Designated site coordinator for promotion of health/safety
Respond/report releases/accidents
– Emergency planning, drills, training
This section essentially addresses the major portion of OSHA 18001 and
ISO 14001 PERRY JOHNSON
REGISTRARS, INC.
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44. R2 Practice #4
Environmental & Safety hazards
include but are not limited to:
High traffic areas – heavy equipment traffic
Trips and falls
Cuts from glass or sharp metals
Burns in facilities that do assaying
Eye injuries from debris
Head injury from falling objects
Improper outside storage resulting in impacts to storm water.
Exposure to high decibel noise levels for a short time
Improper labeling resulting in diminished equipment reuse opportunity
Particulate or metals dust exposure from cleaning CRT’s, crushing,
washing CRT’s, shredding metals
Improper evaluation & sorting resulting in diminished equipment ruse
opportunity.
Chemical exposure from processing areas PERRY JOHNSON
Transportation spills REGISTRARS, INC.
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45. R2 Practice #5
R2 Focus Materials
Items containing polychlorinated biphenyls (PCB’s)
– Ballasts, capacitors, medical equipment - need training to
identify/manage - hazwaste
Items containing mercury
– Switches, bulbs, flat-panel tubes
CRT’s and CRT glass
Batteries
– Handle as universal waste; many U.S. facilities for final destination
Whole and shredded circuit boards except for whole
and shredded circuit boards which do not contain solder
and have undergone safe and effective mechanical
processing or manual dismantling to remove mercury and batteries
– Toner and toner cartridges, while not FM’s, should be reused,
recovered as possible.
PERRY JOHNSON
REGISTRARS, INC.
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46. R2 Practice #5
R2 Focus Materials
Develop FM Plan: downstream vendors
Removal of FM’s
Exceptions: mercury if too small to safely remove, and, CRT’s, batteries and
circuit boards prior to shredding/recovery when sent to properly licensed
facilities.
Facilities properly licensed
FM strategy should not utilize energy recovery, incineration or land disposal
– May consider when normal system is disrupted as allowed by law.
Due diligence of downstream vendors
– Conformance to 5e (1-7)
– Audit/monitor recycling chain
• On-site or self review, or combination
• Needs to be a robust process
PERRY JOHNSON
REGISTRARS, INC.
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47. R2 Practice #5
R2 Focus Materials
FM Plan should include, as a minimum
– Identification of site FM’s
– Responsibility for specific activities
– How/which FM’s will be removed
• Decisions on deminimus levels
– Statement on use of energy recover, incineration, land disposal
– Transportation issues - export requirements
– Selection and due diligence of downstream vendors
• Method of risk assessment
• Audits/monitoring
• Contractual requirements - communication of R2 expectations
• How material will be tracked
– Reference to supporting documents
Matrix is a good way to show FM’s and their movement though the
vendor chain PERRY JOHNSON
REGISTRARS, INC.
47

48. R2 Practice #6
Reusable Equipment & Components
Comply with commercial agreements
Label and sort to allow tracking (R2 #7)
Transport/handle in conformance with R2 #12
Confirm key functions
Confirm recipient vendor certified R2 electronics recycler
(Or)
Key functions
– Vendor manages all residual FM’s in conformance with R2
• Exceptions for number of units
– Less than 15 for evaluation
• New in original packaging
– Need not comply if satisfy R2 3 or 5
PERRY JOHNSON
REGISTRARS, INC.
48

49. R2 Practice #7
Tracking Throughput
3 year retention of records for transfer of
equipment, components and materials, and
brokerage transactions.
Should be consistent with FM plan
Link to R2 #13 for overall records management
and document controls
PERRY JOHNSON
REGISTRARS, INC.
49

50. R2 Practice #8
DATA Destruction
R2 recycler shall follow NIST special publication
800-88 or generally accepted standard, or be
certified (e.g. NAID)
Documented destruction practices
– Trained employees: Refreshers
– Process reviewed and validated by
independent, third-party on periodic basis
PERRY JOHNSON
REGISTRARS, INC.
50

51. R2 Practice #8
DATA Destruction
Steps to consider: per NIST guideline 800-88
– Sanitization decisions based on security needs of the information on the media-
on-site or outsourced, cost, training, volume
– Decision on “clearing, purging, destroying” - based on security
• Clearing: software overwriting
• Purging: degaussing (suggests NSA/CSS approved equipment)
• Destroying: disintegration, incineration, pulverization, melting - best way
If outsourced
– Contract for confidentiality control
– Review and validate the process by R2 trained individual
– Controlled shipments
– Tier 1 vendor
Equipment Maintenance & Calibration
Competency of personnel - hiring/screening
Records of sanitization to document what media were sanitized
Insurance? PERRY JOHNSON
REGISTRARS, INC.
51

52. R2 Practice #9
Storage
FM’s, equipment, and components
– Protect from atmospheric conditions/floods
– Access controlled/security
– Container labeling and storage area identification
• Pay attention to any legal requirements
(e.g. CRT’s, batteries)
• Consider inclusion in ongoing monitoring activities to
ensure any compliance issues, and container integrity
to eliminate leakage (dust, liquids)
PERRY JOHNSON
REGISTRARS, INC.
52

53. R2 Practice #10
Facility Security
Controlled access
– Consider equipment and customer needs
– Consideration of shared resources (e.g. part of
a MRF), or responsibility by a corporate entity
not in the scope of R2 certification
PERRY JOHNSON
REGISTRARS, INC.
53

54. R2 Practice #11
Insurance, Closure Plan and
Financial Responsibility
Comprehensive or Commercial General Liability
Insurance
– Bodily injury, property damage, pollutant releases,
accidents - need evidence for all categories
Written and funded closure plan
– May be state minimums
Need to address as part of downstream vendor
controls
PERRY JOHNSON
REGISTRARS, INC.
54

55. R2 Practice #12
Transport
Package to minimize risk
– CRT rules
Transporters have/met regulatory authorization
– No significant violations during past 3 years
• Need documentation
– If using trucking brokerage firm, verify requirements
of their contracts
– Be sure to include transport as part of environmental
and health/safety risk assessment
PERRY JOHNSON
REGISTRARS, INC.
55

56. Recordkeeping
Maintained in a single site location
– Show conformity to R2 requirements
– Linkage to R2 practice #7
PERRY JOHNSON
REGISTRARS, INC.
56

57. Integration/Comparison with
ISO 9001 and ISO 14001
Implementation/Auditing Implications
R2 manual
Objectives and Targets
Internal Audit
Maintenance / Calibration
Nonconformance / Corrective / Preventive Action
Training
Document/Records Control
PERRY JOHNSON
REGISTRARS, INC.
57

58. Integration/Comparison with
ISO 9001 and ISO 14001
R2 Manual: There is no requirement for an R2 manual. However, there is a
requirement to document a written EHSMS that includes written goals and
procedures.
1a1 requires written goals (continual improvement) and procedures
1a3A requires a policy for managing end of life electronic – it is expected that
this POLICY is understood by all employees and communicated to
downstream vendors
1a3C requires a FM plan
1a3F requires a list of activities necessary to conform to R2- NOT an
interaction of processes, but identification of ALL activities/processes (perhaps
as a simple electronics flow chart) needed to meet requirements for R2
SCOPE of the organization should be identified within the documented
EHSMS to conform with ISO 17021 requirements
While organizations may indeed have a variety of documents that integrate their
activities, a MANUAL is not required.
PERRY JOHNSON
REGISTRARS, INC.
58

59. Integration/Comparison with
ISO 9001 and ISO 14001
Objectives and targets: Again, no specific R2 Practice
addresses how to establish and/or monitor goals,
objectives and targets.
1a2, note 2, requires establishing goals, objectives
and targets, tracking performance, plan activities
that work toward achieving identified goals, create
and implement an action plan for continual
improvement.
PERRY JOHNSON
REGISTRARS, INC.
59

60. Integration/Comparison with
ISO 9001 and ISO 14001
Internal Audit: there is no R2 Practice specific to internal auditing. The R2 General
Principle 1, requires a recycler to use EHSMS to plan and monitor its processes and
activities to conform to R2 Practices. Monitor is the key terms as it suggests some
methodology equivalent to an internal audit to verify effectiveness of the EHSMS. ISO
17021 requires CB’s to verify effectiveness of the internal audit/monitoring program.
1a2, note 2, requires monitoring of key activities and tracking performance of the
EHSMS
5f requires recycler to confirm “through audits or other similarly effective means”
that downstream vendors comply with FM controls
6c3 requires “an appropriate combination of…materials tracking…and auditing”
for reusable equipment and components.
Use of the R2 checklist by recyclers could meet the requirements for “internal
auditing”. We should expect that a “monitoring (auditing) plan/schedule” is
established and followed, and that people using the checklist are competent. We
should expect that this information is submitted for review (input) of the EHSMS.
We could logically expect that the audit/monitoring program covers all key
activities of the recycler show “effectiveness” - however a “process approach” is
not required. PERRY JOHNSON
REGISTRARS, INC.
60

61. Integration/Comparison with
ISO 9001 and ISO 14001
Maintenance/Calibration: There is no R2 Practice specific to equipment
maintenance or calibration of test equipment to ensure meeting any OSHA PEL
testing, e.g. test for noise or lead dust. However, the activities are implied, or
would be required by CFR 29 or CFR 40.
3 (general principle) requires conformance to applicable health and safety
requirements - this would imply all of CFR 29 applicable to equipment
maintenance expectations (e.g. LOTO, hand tool inspections, etc.)
4b recycler adheres to Good Housekeeping Practices- equipment, tools,
infrastructure (e.g. 29 CFR 1910.22, 1910.76, 1910.178, 1910.242) -
virtually any maintenance issue could be written against clause 4b.
4e requires recycler to use sampling protocols that are effective - and to
comply with all PEL’s for sampling monitoring - calibration of sampling or
test equipment is necessary to assure effectiveness.
6c1 requires “use of effective testing methods”, confirms reusable
equipment is working properly.
PERRY JOHNSON
REGISTRARS, INC.
61

62. Integration/Comparison with
ISO 9001 and ISO 14001
Nonconformance/Corrective/Preventive Action: There is no R2
Practice specific to nonconformance, corrective or preventive action.
However, it is implied by 1a2 that bases the EHSMS on the PDCA
model.
1a2 note requires identification and correcting of problems to
prevent recurrence. It is important to remember that Karen Pollard
of the EPA included this note to help recyclers understand the
elements of an EHSMS that should be in place, based on the
PDCA - it is expected to be adhered to in order to meet
expectation of R2 effectiveness.
3a1 requires recycler to “take corrective action to address any
issues of non-compliance”. This would be driven by compliance
evaluations or daily observance of noncompliance, e.g. improper
use of PPE, failure to follow the reuse/recover policy, etc.
PERRY JOHNSON
REGISTRARS, INC.
62

63. Integration/Comparison with
ISO 9001 and ISO 14001
Training: There is no R2 Practice that specifically addresses recycler/
employee training. However, specific training issues are addressed.
4a requires recyclers to possess expertise and technical capability to
process each type of equipment, component and material in order to
protect employees, public and the environment- implementation would
require a training program with associated records maintained
4d2A requires regular, documented health and safety training, and
refreshers for all employees
4f requires training of volunteer and temporary workers per 4d2A
4g requires assignment of an individual (consultant or employee) to
coordinate and promote worker health and safety
8c requires employees involved in data destruction to be trained on a
regular basis.
PERRY JOHNSON
REGISTRARS, INC.
63

64. Integration/Comparison with
ISO 9001 and ISO 14001
Document/Records Control: There is no R2 Practice that specifically addresses document
control, external documents, control of obsolete documents, records retention times, etc.
However, document control and records maintenance activity and effectiveness is clearly
implied. R2 practice 13 (recordkeeping) addresses records for showing conformity - it is
likely the catch-all clause to write against if there is a records issue.
1a requires a “documented, fully implemented, update as needed, written
EHSMS”. – this is likely the catch-all clause implying some method of document
control and availability of most current revision of an EHSMS document.
1a1 requires “written procedures”.
1aF requires a “list of the documentation necessary…”
3a2 (ABC) requires documentation that allows transboundary shipments
4d2A requires documented health and safety training
7a requires maintenance of commercial contracts, bills of lading, etc. for 3 years
minimum
8b requires “documenting” data destruction practices
12b requires recycler to obtain documentation of transporter certification and
performance
13a requires maintaining “documentation necessary to show conformity to each
requirement” maintained in a single location - the main clause to support records
management. PERRY JOHNSON
REGISTRARS, INC.
64

65. R2 Certification
Governing Rules:
ANAB: ANSI-ASQ National Accreditation Board
– Rule 34
• References R2 Standard/checklist and ISO 17021:2006
• No unaccredited R2 certificates may be issued
– Registrars certificate MUST have ANAB seal to be VALID
• Certificate must reference ISO 17021
• Registrar maintains publicly available list of clients
• Only single-site certification is possible
ISO 17021:2006 - requirements for bodies providing audit and certification of
management systems
– Rules of engagement for the Registrar (certification body)
– Establishes how R2 audits will be conducted (Stage 1 and Stage 2)
– Establishes timing for surveillance audits - annual at minimum
– Establishes requirements for recertification - 3 years
– Establishes what the Registrar should review during specific audit cycles.
PERRY JOHNSON
REGISTRARS, INC.
65

66. R2 Certification
Stage 1 Requirements:
Documentation reflecting R2 requirements
Client understanding of requirements: training
Site-specific conditions
Scope of the ESHMS
Compliance evaluation completed and issues being addressed
Understanding of organizations’ significant
environmental/safety risks
Evaluate internal audit planning and performance or equivalent
monitoring of processes
Evaluate management review- called annual review in R2
PERRY JOHNSON
REGISTRARS, INC.
66

67. R2 Certification
Stage 2 Requirements:
Conformity to requirements - Implementation
Performance monitoring against key performance objectives
Ongoing legal compliance
Operational process controls
Internal auditing and management review
Responsibility and authority for policies
PERRY JOHNSON
REGISTRARS, INC.
67

68. R2 Certification
Certification Steps:
Training to R2 requirements
– Staff
– Internal Audits by “competent auditors”
Create R2 documents or integrate with existing systems
(e.g. ISO 9001, 14001 or OSHAS 18001)
Implement R2 requirements
– Conduct internal audits of system
– Conduct compliance evaluation
– Conduct review of system based on input from internal audit
Contract with a certification body
Complete S1 and S2 audits
– Address any nonconformities ☺ Certification!
PERRY JOHNSON
REGISTRARS, INC.
68

69. Expectations for R2
Widespread Use
EPA was asked for a way for refurbishers/recyclers to highlight
their sound recycling practices and a way for customers to
easily find recyclers that are sound
Members of the stakeholder group that support R2:
– States and local governments
• Some have R2 elements in law
• Some have added R2 requirements to procurement
contracts
– ISRI (recyclers trade assoc)
• Is offering RIOS/R2 training to recyclers
– ITI (OEMs trade assoc)
• Encouraging OEMs to get their recyclers certified
• Many state laws require the OEMS to provide take
back
– MARs (Microsoft Authorized Refurbishers) - 500 +
members
• Looking to find a way to get their members certified
Federal Government
– Currently must use recyclers that meet the Plug-In To
eCycling Guide & must do their own diligence
– When there are R2 certified recyclers, EPA will replace
the Plug-In To eCycling guide with R2 practices PERRY JOHNSON
– Plug-In To eCycling Partners- OEMs REGISTRARS, INC.
69

70. QUESTION & ANSWER
SESSION
PERRY JOHNSON
REGISTRARS, INC.
70