Below is a blog post by Sarah Westervelt, the e-Waste Project Coordinator at the Basel Action Network (BAN) and the Recycling Coordinator for the Electronics TakeBack Coalition, in preparation for the PSI Networking Conference Call, “How to Choose a Reputable Recycler: Update on the R2 and e-Stewards Certification Programs,” on Thursday, November 18th (2:00-3:30 p.m. EST). Sarah’s work includes administering the Electronic Recycler’s Pledge of True Stewardship, educating the public about the global toxics and legal issues associated with exporting e-waste, as well as highlighting the worst-case scenarios. Sarah co-authored BAN exposés including films and reports documenting horrific “recycling” of the world’s e-waste in China and Nigeria. Sarah has a Master’s Degree in Organizational Systems Renewal from Antioch University, and worked for years as a consultant in organizational development before joining the Basel Action Network in 2001. Click here for more information on the PSI Networking Conference Calls.
For years, there has been little more than pilot programs, pledges and a great deal of concern about what electronics recyclers are actually doing with the e-waste they collect. While federal regulations exempt much of this waste stream, the relatively new electronics recycling industry has been plagued by unscrupulous companies that profit largely by exporting scrap or untested/non-working equipment to countries that cannot legally trade in hazardous waste with the US, as defined in a United Nations treaty called the Basel Convention.
As of this year there are not one, but two accredited certification programs for electronics recyclers in the US, both of which are recognized by the US EPA – the e-Stewards Certification program and the Responsible Recycling (R2) Certification program. The question is, what are the differences, and which one of them will best serve your needs? Having two programs requires some homework on the part of customers or officials.
To get to the bottom of this question, it is important to compare the standards themselves, as well as the rigor of the verification system (i.e. the certification bodies which certify that recyclers conform to a particular standard, and the accreditation bodies that oversee their work.)
Let’s start with comparing the verification systems. Both R2 and e-Stewards certification programs utilize the ANSI-ASQ National Accreditation Board as their accreditation body. ANAB is one of the top three accreditation bodies in the world, and is the largest, most respected in the United States.
Next, let’s look at the certification bodies (CBs) that are accredited by ANAB to certify to either R2 or the e-Stewards Standard. Each of the programs has three certification bodies that are accredited to certify to their respective standards. An important question is how rigorous and consistent the auditor training is for each program, with the goal of having a high level of confidence that the auditors across all the CBs consistently understand the standard they are auditing to and program requirements. Without an owner for the standard or host organization until this fall, the R2 program has not had a sole auditor training program since its inception, resulting in a variety of auditor trainings for the different CBs. The e-Stewards program requires that all auditors must successfully complete a 3-day training provided by SAI Global, one of the top professional training organizations.
Finally, and central to every certification program, are the standards that define requirements for the companies attaining certification. The R2 Practice document, which was finalized without support from the environmental community, is 13 pages long, with no guidance document, but it comes with an audit checklist. The e-Stewards Standard, created by the Basel Action Network in conjunction with leaders in the recycling and refurbishment industries, and supported by 70 organizations, is 49 pages long. It has a 67 page companion guidance document, but no auditor check list. Based on the shear length of the two standards, it is easy to understand that one spells out much more comprehensive requirements for the recyclers.
There are two basic types of requirements in each of the standards. One set of requirements is for the environmental management system (EMS), which involves a Plan-Do-Check-Act system for identifying, documenting, and reducing the environmental impacts of the business operations. The R2 Practices has one page of general requirements that an R2 recycler’s EMS must meet . The e-Stewards Standard has the 8-page global standard for environmental management systems, called ISO 14001, imbedded in it, so that all certified e-Stewards are also certified to ISO 14001.
Within this framework of an EMS, both standards require some minimum performance requirements, which are the second basic type of requirements in these two standards. Performance requirements are industry-specific restrictions of or prescriptions for certain activities. Along with the EMS requirements, this is where the two standards differ dramatically.
The chart below summaries some of these differences:
|Does the Standard…||R2 Practices||e-Stewards Standard for the Responsible Recycling and Reuse of Electronics|
|…Allow toxic materials in solid waste landfills & incinerators?||Yes. If circumstances beyond the control of the R2 recycler disrupt its normal management of the toxic materials, it may utilize solid waste disposal facilities, to the extent allowed under applicable law.||No, as it was deemed inappropriate for heavy metals and other hazardous materials to be disposed of in solid waste disposal facilities.|
|…Ban the export of toxic materials to developing countries?||No. R2, in principle, calls for only allowing the export of equipment and components containing ‘focus materials’ to countries that legally accept them, but does not ban them from rich to poorer countries.||Yes. Based on the international definitions found in the Basel Convention, toxic materials bound for recycling or disposal are not allowed to go from developed to developing countries, consistent with the Amendment to the Basel Convention, already ratified by 65 countries, including the European Union.|
|…Require accountability for toxics throughout final processing?||Limited.||Yes, with detailed performance requirements for downstream audits, documentation, and restrictions for initial and on-going accountability.|
|…Allow untested or non-working equipment to be exported to developing countries for refurbishment (which can transfer hazardous waste)?||Yes.||No.|
|…Have detailed minimum requirements for occupational health and safety?||Left to the R2 recycler to determine.||Yes, developed with a great deal of input from state occupational health and safety experts.|
|…Allows the shredding of mercury-containing devices?||Yes, “if they are too small to remove safely at reasonable cost, and workers are protected…”, and if the mercury-containing materials are sent to licensed facilities that utilize technology designed to manage it.||No. There are no safe levels of mercury, and currently no shredders that can capture all mercury vapors. Shredding mercury disperses it into the shredded mixed materials, the workplace, and the environment.|
|…Prohibit the use of prisoners to recycle toxic electronic waste?||No.||Yes.|
While having two certification programs requires some due diligence, most people welcome the arrival of new mechanisms for holding an industry accountable for managing a toxic waste stream.