Author Archives: John Lingelbach

Offering Responsible Electronics Recycling Practices For Everyone, Everywhere

Protecting vulnerable populations from environmental, health, and safety risks is a critical goal shared by many in the electronics recycling industry.  It is a cornerstone of the R2 Practices, one of the new certification standards for the electronics recycling industry.

Some have asked why, then, doesn’t R2 establish outright bans on exports of electronic scrap to developing countries and on the use of prison labor?

The answer has to do with economic opportunity.  The stakeholders that developed R2 designed a set of requirements that call for equal environmental, health and safety protections no matter the location or situation.  Importantly, the R2 requirements do so in a manner that does not curb the business opportunities of law-abiding, state-of-the-art companies and their workers in developing countries.  And, with respect to prison labor, they do so in a manner that does not diminish the vocational training opportunities of people that are incarcerated.

The R2 Practices

During the multi-stakeholder development of The Responsible Recycling “R2” Practices for use in Accredited Certification Programs for Electronics Recyclers, aka the “R2 Practices”, stakeholders addressed critically important issues relating to the environmental, health, safety (EHS), and security performance of electronics recyclers and their downstream vendors.  The comprehensive standard contains provisions for best practices in a number of operational areas including:  an EHS management system, downstream due diligence, adherence to legal requirements including those covering exports, and reuse and refurbishing activities.

The resulting document—the R2 Practices—serves as the basis for the R2 Certification Program.  Electronics recyclers can contract with one of a handful of registrars (certification bodies or CBs) to become certified to R2.  This rigorous, two-phase audit process requires the recycler to exhibit conformity to each of the R2 Practices’ many performance and management system requirements.

R2 and Exports of End-of-Life Electronics Equipment to Developing Countries

Developing countries can be home to both atrocious, and “state-of-the-art”, electronics recycling and refurbishing operations.  In these countries, as well as internationally, there is a desire to shift electronics recycling and refurbishing away from the former and into the latter types of operations.  This accomplishes environmental, health and safety goals while also promoting good jobs in some of the areas of the world most in need of economic opportunity.

To ensure exported electronic scrap ends up at state-of-the-art facilities, three key criteria need to be met.  First, shipments of exported electronic scrap must be sent and received in accordance with the laws of the exporting and importing countries.  Illegal shipments all too often end up causing serious harm to health and the environment in the worst of recycling and refurbishing operations.

Second, all receiving facilities must be evaluated on a regular basis to ensure that they are employing best technologies and practices. In Asia and other parts of the world, there are a number of state-of-the-art electronics recycling and refurbishing facilities that rival those in the U.S. in terms of technology and materials management.

Third, all equipment must be accurately characterized on the shipping manifest.  Too often, e-scrap exports are characterized as “reusable” to avoid the added scrutiny and legal requirements that apply to “waste”.  This creates a loophole which can allow scrap to be inappropriately sent to a facility that is not capable of safely handling it.

R2 effectively addresses each of these criteria.  It prohibits the shipment of end-of-life electronic equipment containing toxic materials to developing countries unless the shipment is legal under the laws of both the exporting and importing countries. It requires that the receiving facility conforms to key R2 requirements and employs technologies appropriate for the materials it processes.  Furthermore, “reusable” electronics equipment containing toxic materials is subject to these same requirements unless it has been tested and its key functions are working properly.  Finally, all shipments must be accurately labeled.

Through these requirements, the stakeholders that developed R2 achieve the goal of protecting vulnerable populations while supporting legal, safe, environmentally-sustainable, economic development in developing countries.

R2 and Prison Labor

UNICOR (also known as Federal Prison Industries) maintains operations in a number of manufacturing industries, including:  textiles, office furniture, industrial products, commercial fleet asset services (commercial vehicle remanufacturing), electronics manufacturing and electronics recycling.  The company was established by Congress “to create a voluntary real-world work program to train federal inmates” – thereby helping them obtain employment upon release from prison.  To this end, the UNICOR electronics recycling program has been successful, as electronics recycling firms have experience hiring formerly incarcerated people from the UNICOR program.

A few years ago, some prisoners at UNICOR worked in unsafe settings in electronics recycling facilities.  Unfortunately, employees of less sophisticated recycling operations in the private sector have, and may continue to be,  exposed to similar dangers.  More recently, in December, 2009, The National Institute of Occupational Safety and Health issued a report that found no health problems linked to electronics recycling operations at the four UNICOR facilities it investigated.

Regarding the issue of prison labor, the stakeholder group that drafted the R2 Practices decided not to develop different requirements for different categories of workers.  Rather, the R2 Practices set forth extensive requirements covering on-site environmental, health, and safety; and they apply to all workers in a facility, be they employees, consultants, volunteers, or prisoners.  As a result, R2 does not prevent prisoners from safely learning new skills that will help them find employment upon their return to society.

The future of R2

R2 offers a practical and equitable approach to addressing the areas of exports and prison labor.  And as the industry continues to evolve, so too will the R2 Practices.  Similar to the spirit of the standards development process, R2 Solutions is inviting stakeholders from all industry sectors, including NGOs, to shape the future of the standard so it can continue to effectively address the needs and concerns of the industry.

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