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Industry Rules & Certifications

Don't be Fooled by Frauds!
A few states have passed laws governing the disposal of electronics, however, neither the federal government nor any state government has passed rules that govern how an electronics processing facility shall operate beyond OSHA and other generic EH&S laws.  Point blank, there is no such thing as an "EPA-Certified Electronics Processing Facility." Although an ISO certification or compliance with another accredited standard offers benefits to both supplier and customer, neither sufficiently address the loopholes available to processors who irresponsibly export to nations where worker safety or environmental rules are not enforced or lack existence. The U.S. does not condone such activities, however, does not prohibit it from occurring. Currently, it is simply up to the generator to interpret U.S. and international laws.

There is hope!
Soon, a set of Best Management Practices (BMPs) endorsed by the USEPA and a Multi-Stakeholder Group representing a wide range of national organizations and global companies will come into existence. Hesstech has held a seat on the steering committee reporting to the larger stakeholder group organized by the USEPA.

"We are optimistic that by the end of this year, customers will have a means to qualify legitimate processors without exhausting extensive time and resources," said Hesstech President David Zimet.

Industry Certifications
Currently there are two associations who have developed certification programs for electronics recycling organizations: The Institute of Scrap Recycling Industries (ISRI - www.ISRI.org), and the International Association of Electronic Recyclers (IAER - www.iaer.org), both of whom have engaged in developing a certification for electronics recyclers.

The IAER was established in 1998 by a group of founding recyclers, OEMs, and other trade associations and lists approximately 160 members on its web site. The association was probably the first of its kind in that it was formed to serve the electronics recycling industry only.

The IAER certification has been available for a few years and it appears it is not attracting many recyclers. Hesstech believes much of the concern is that many of the controversial issues surrounding export and the use of prison labor are not sufficiently addressed.

Further the IAER certification is not issued by an accredited registrar. The auditors may be accredited and have industry experience, however, without an accredited Registrar (the "certifying body"), Registrars will not be examining certification criteria pursuant to an ANAB approved process. This means compliance with the industry specific Best Management Practices (BMPs), such as those developed by the USEPAs Multi-Stakeholder Group, will be up to the discretion of the Registrar.

The concern is that the BMPs could be applied inconsistently while issuing identical certifications. Operating consistent with an ANAB approved process, Registrars will be required to evaluate certification applicants in a fair and equal manner. This is critical to close loopholes which often result in price gouging typically associated with the export of materials to illegal or unsafe facilities.

To their credit, the IAER has provided the community with valuable industry information and has sponsored conferences and hosted a myriad of instructional seminars geared toward educating recyclers, governmental officials and others about environmental issues, operational practices, and market information.

As a member of the USEPA's Multi-Stakeholder Group, Hesstech has expressed its concerns to the IAER about their certification program. As of June 2007, it appears the IAER is considering a change in position where they would agree to only use accredited Registrars after the appropriate standard in developed or modified.

Having 21 chapters nationwide and headquarters in Washington, D.C., the Institute of Scrap Recycling Industries, Inc. (ISRI) represents more than 1,400 companies, most of which are not in the electronics recycling industry. Their members process, broker, and consume scrap commodities, including metals, paper, plastics, glass, rubber, electronics, and textiles.

ISRI was formed in 1987 as a result of the merger of the National Association of Recycling Industries (NARI), formed in 1913, and The Institute of Scrap Iron and Steel (ISIS), founded in 1928. The Institute provides education, advocacy, and compliance training, and promotes public awareness of the value and importance of recycling to the production of the world's goods and services.

ISRI is in the process of launching its certification program as part of the Recycling Industry Operating Standards (RIOS) program. This will better address the certification inconsistencies since the ISRI program is supported by a fully accredited process, meaning the Registrar must follow ANAB approved guidelines when issuing certifications.

One concern is that an electronics recycler can become RIOS certified while it will be optional for the recycler to comply with industry BMPs specific to the electronics recycling industry. If it is not conspicuous and transparent that one recycler is compliant with the BMPs and the other has not, customers comparing one recycler with another will have great difficulty determining if one organization is properly addressing data security and operating in an environmentally responsible manner.

More information will be available soon as they release the results of the first certifications issued under the guidelines set forth by the RIOS program. Hesstech is an ISRI member.

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