USEPA Stakeholder Group
In January 2006, a large group of stakeholders met
in Washington, DC to discuss developing voluntary national standards for electronics recyclers.
At the meeting, a smaller group of stakeholders, of which Hesstech is a member, was asked to work
with a facilitator to develop guidelines establishing "best management practices (BMPs)." Since the group's
inception, the small group has held conference calls on average a weekly basis which has resulted in many
versions of a draft straw proposal document. The document is intended to "level the playing field"
among recyclers requiring they operate consistently in accordance to higher operational, health,
and environmental standards that do not typically exist in the current market place. More specifically,
most of the group wants this document to be used as part of a certification process that ensures
recyclers won't be able to do things like pass off exporting of untested equipment to overseas operations
that cause harm to workers or the environment as proper recycling. As of the end of November 2007 there are
17 revisions. A summary of the changes from v.16.1 verses v.17.1 was provided in an email by the group facilitator.
Facilitator's comment:
"Almost all of these most recent edits are in Provisions 5 and 12
which address the on-site and downstream management of materials of concern. Without these edits,
these provisions were confused and missed some key points.
"You will note that the scope of the due diligence requirements is
narrower in v.17/17.1 than in v.16.2 and prior versions; it does not call for downstream
vendors to conform to the EMS, legal requirements, and some other R2 provisions.
Many people in Atlanta commented that v.16.2 set almost the same standard/bar for
downstream vendors as for R2 recyclers. They suggested this is unrealistic, pointing
as an example to the fact that many--perhaps most-- potential downstream vendors will
not have an EMS (and that if we require EMSs of these entities, one effect will be to
promote worthless EMSs developed only to obtain R2 recyclers' business). They emphasized
that our primary concern is the appropriate management and disposition of the materials of concern.
"We may want to add back in some of these due diligence requirements,
including perhaps conformity to the legal requirements provision (which was taken out
because of the challenges and burden relating to auditing downstream conformity to the provision).
We can discuss all this in upcoming Tues calls."
Although, there are several issues where the small group has yet to
reach a consensus, some of these issues, such as a small company’s ability to comply
with the guidelines, have been tabled while the group moves into a field testing phase
with the hope that many of these concerns will be addressed. Over the past few months
the group has solicited information from professional auditors and has devised the framework
for an audit checklist. Several test facilities have been identified who are willing to
participate in the trial audit or field testing phase on a voluntary basis. The volunteer
companies range from large to small recyclers, some of who focus on metals recovery and some
on resale of equipment. A non-profit is also being considered. Below you will find a links
to the latest version of the BMPs and a copy of the draft audit checklist. Upcoming discussions
are scheduled to address:
- what Provisions 5 and 12 should say about on-site and downstream management of CRT glass, toner, circuit boards, etc.,
- what additional factors (if any)downstream due diligence should cover in Provision 12 (e.g. EMS, legal requirements, EHS),
- what mechanisms should be used in the due diligence (e.g. contractual language, documentation, audits, ???),
- what the document should state about accredited certification programs and where it should state it.
Please click to view:
Facilitator’s Draft Straw Proposal v.16.1 [48 KB PDF]
Facilitator’s Draft Straw Proposal v.17.1 [235 KB PDF]
12/5/07 Draft Field-Testing Auditor Checklist for v.17.1 [116 KB PDF]
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