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AN EXECUTIVE OVERVIEW
CPJPERRY JOHNSONC O N S U L T I N G , I N C .
www.pjcinc.com 1-888-248-0256•
Environmental Systems
ISO 14000, R2 AND RIOS
ENVIRONMENTAL
MANAGEMENT SYSTEMS
The Groundwork For
Environmental Management
ISO 14001:2004
R2-RIOS (With Additional Guidance on REACH and RoHS)
An Executive Overview
Revised 03/13
PERRY JOHNSON CONSULTING, INC.
Detroit
5000 Town Center, Suite 2002, Southfield, MI 48075
1-888-248-0256 or (248) 663-0253
Website: www.pjcinc.com • Email: pjc@pjcinc.com
© Copyright 2013 by PERRY JOHNSON CONSULTING, INC.
All rights reserved. No part of this book may be reproduced in any form or by
any means without permission, in writing, from Perry Johnson Consulting, Inc.
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EMS Executive Overview Page 1 3/13
ENVIRONMENTAL
MANAGEMENT SYSTEMS
The Groundwork For
Environmental Management
AN EXECUTIVE OVERVIEW
CONTENTS
FOREWORD..................................................................................................................................2
MANAGEMENT SYSTEMS ........................................................................................................3
THE USERS OF THIS GUIDE ....................................................................................................3
MANAGEMENT SYSTEM REGISTRATION ..........................................................................4
Key Steps to Completing Registration .................................................................................5
What to Look For in a Registrar ..........................................................................................6
What to Look For in an Auditor ..........................................................................................6
PART I – ISO 14001:2004
WHAT IS ISO 14000? ...................................................................................................................7
The Origin of ISO 14000 ........................................................................................................8
ISO 14000 Series Standards....................................................................................................9
ISO 14000 Components ........................................................................................................11
Implementing an Environmental Management System ........................................................15
Meeting Environmental Auditing Requirements ..................................................................16
THE BENEFITS OF ISO 14000 .................................................................................................18
ISO 14001 ENVIRONMENTAL MANAGEMENT SYSTEM REQUIREMENTS ..............20
PART II – RESPONSIBLE RECYCLING (R2).......................................................................28
The History of R2 .................................................................................................................29
Integration & Comparison with ISO 9001 and ISO 14001...................................................31
Additional Rules and Requirements .....................................................................................34
The R2 Practices ...................................................................................................................36
PART III - RIOS ..........................................................................................................................47
RIOS Certification ...............................................................................................................49
The RIOS Standard ...............................................................................................................51
PART IV – RoHS AND REACH ................................................................................................59
RoHS ....................................................................................................................................59
REACH .................................................................................................................................62
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FOREWARD
Management System standards define generic and/or industry specific requirements necessary to
ensure the consistency of management requirements for various organizations all over the world.
The ISO 14000 series and other standards covered in this executive overview have positive
impacts on companies in industrialized nations spanning our global community. These standards
ensure environmental, quality, health and safety management responsibilities are addressed by
top management. The people with the greatest influence over company policies and procedures
also have the flexibility and freedom to define methods for implementing management system
requirements. Once a company decides to control the processes related to the scope of activities
performed, it can establish targets and objectives for achieving identified management system
goals.
Management system standards have made a tremendous impact in the global community, as they
outline methods for companies to manage their various activities. While management system
requirements are intended to be voluntary, some government agencies may require registration to
various standards or other related requirements commensurate with those defined within
applicable standards. As a result, organizations that do not implement effective management
systems may diminish their ability to compete in various markets, such as the European Union
(EU), where registration to some standards is required by governing states or other entities.
Marketing advantages, government mandates, benefits derived from strategic planning and the
growing interest of other public entities represent a basis for justifying the implementation and
maintenance of an effective management system(s).
The adoption of management system requirements provides enumerative benefits to various
interested parties. Interested parties can be represented by customers, stake holders, employees,
suppliers and members of communities affected by the scope of activities performed as well as
products and services delivered by organizations.
This booklet was created to promote awareness necessary for organizations to provide superior
products and services to customers while embracing a philosophy of environmental
responsibility and the provision of a safe and healthy work environment for employees. This
manual provides an overview of the intent and content of management system and other
standards addressed, including detailed descriptions of the standards, related requirements,
objectives and the implementation process that assists organizations in accomplishing their goals
and objectives.
Because management system registration is a lengthy and detailed process, it is strongly
suggested that organizations seeking registration retain the services of a reputable consulting
firm.
PERRY JOHNSON CONSULTING, INC.
March 2013
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MANAGEMENT SYSTEMS
This executive overview manual was originally created to provide general information and
guidance to accommodate requirements for ISO 14001:2004 Environmental Management
Systems. Since the initial release of this manual, industry specific environmental and other
management system standards have been released to address a broader range of environmental,
occupational health and safety, quality and other requirements applicable to subscribing
industries.
This version of The Groundwork For Environmental Management Manual has been expanded to
include additional industry specific requirements included in the Recycling Industry Operating
(RIOS) Standard adopted by the recycling industry (ISRI) and the Responsible Recycling (R2)
Standard sponsored by the United States Environmental Protection Agency (EPA).
THE USERS OF THIS GUIDE
Because management system requirements are adopted to support universal applications, this
guide can be used by various organizations, and tailored to meet business or industry specific
requirements appropriate for the scope of work performed. The use of this guide and the
information contained herein is unlimited.
Information contained within this guide is not limited to environmental management, but also
places additional emphasis on health, safety, legal compliance and quality management
requirements.
Environmental Management Systems (EMS) and other standards affect almost everyone, from
companies that manufacture products or provide services to individuals who are concerned about
the environment. The principles of these standards extend well beyond business and industry,
and are applicable to the readers and producers of this guide.
Various challenges are associated with an organization’s activities, the processes it engages in,
and the products and services it produces. Each activity can have an impact on the environment,
health and safety and quality in varying degrees. An organization seeking to control
environmental aspects and impacts through its EMS must identify them and implement
procedures to deal with these situations.
Business suppliers should also take note of this guide. Some companies have mandated that their
suppliers become registered to applicable management system requirements is addition to
complying with other related requirements.
The Environmental Protection Agency (EPA) has contributed extensively to the development of
ISO 14000, and its representatives have suggested that ISO 14001 registration is likely to reduce
the need for multiple environmental audits in the future. The Recycling Industry Operating
Standard (RIOS) and the Responsible Recycling (R2) Standard have extended requirements
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beyond those of ISO 14001:2004 in order to integrate quality, health and safety and
environmental requirements into common standards intended to maximize the benefits for the
scrap metal and electronics recycling industries.
This manual also provides additional guidance on the Restriction of Hazardous Substance
Directive (RoHS) and Registration, Evaluation, Authorization and Restriction of Chemicals
(REACH) Standards for organizations that are required to comply with regulatory requirements
defined within and complimentary to these standards.
MANAGEMENT SYSTEM REGISTRATION
Management system registration is a tangible expression of an organization’s commitment to
satisfying the needs of customers and other interested parties applicable to the management
system requirements defined. ISO 14001 defines environmental requirements that are suitable
for industries of any type and size. RIOS applies to the scrap metal recycling industry while R2
is tailored to meet the needs of organizations involved in processing and recycling used
electronics. RoHS and REACH are compliance standards adopted by the European Union (EU)
to control and manage chemicals in different states to better manage the environment and ensure
the health and safety of persons or communities in which such chemicals are used or transported.
The process necessary to achieve registration is described below as applicable to ISO 14001 and
is outlined briefly for different management system requirements throughout the text of this
manual.
Management Systems provide formal requirements to help organizations manage environmental
aspects and impacts applicable to the scope of activities performed. ISO 14001 is understood
and accepted globally.
There are a variety of reasons for seeking ISO 14001 registration. These include customer
mandates, a competitive advantage through reduced energy costs and improved efficiency,
cutting liability and regulatory compliance costs, and increased community goodwill from
preventing pollution and reducing waste.
ISO 14001 registration is carried out by registrars, accredited organizations that review the
facility’s environmental policy and other documentation during the Stage 1 (desktop) audit to
ensure that they meet the standard, and examine the firm’s processes during the Stage 2
(registration) audit to ensure that the EMS described in the documentation is in place and is
effective. Once registration is obtained, the registrar conducts regular surveillance audits of the
facility to determine if its EMS continues to meet the standard’s requirements.
As it typically takes 6 to 18 months to complete the ISO 14000 registration process,
organizations are advised not to put off registration for too long.
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Key Steps to Completing Registration
Before an organization can be considered for registration, several preliminary steps must be
taken:
1) The first step is to implement an EMS that meets ISO 14001 requirements.
2) To qualify for registration, it’s not enough to just conform to the standard. An environmental
policy must be created which stipulates a facility’s environmental commitments, procedures
and practices. This document plays a vital role in the registration process. Because the
policy is the principal document used during an audit, it must be a true reflection of the
facility’s EMS. The policy must also address, point by point, all ISO 14001 requirements.
3) The facility’s EMS must be in operation for a minimum of three to six months so that
employees are familiar with it and an evidentiary trail of documents has been created for
auditors to review.
After successfully completing the preliminary steps, a relationship must be established with a
registrar. The registrar’s job is to verify whether an organization’s EMS has been properly
implemented and conforms to ISO 14001 and any other applicable requirements.
Once the services of an accredited registrar have been obtained, a formal application must be
filed. When all of the paperwork has been submitted, the registrar examines the facility’s
environmental policy and other documentation during the Stage 1 (desktop) audit. After the
registrar has verified that the policy and other documentation satisfactorily reflect the
organization’s EMS and meet all ISO 14001 requirements, and any nonconformities have been
corrected, the on-site Stage 2 (registration) audit of the organization’s facility is scheduled.
During the Stage 2 audit, the registrar’s auditor interviews employees, reviews records, and
performs a detailed inspection of the facility’s EMS and procedures. The purpose of the audit is
to ensure that the facility’s EMS is functioning adequately and conforms to all ISO 14001
requirements.
Afterward, the registrar reports its findings in an audit report. If any nonconformities were found,
the organization (or auditee) must take corrective action to remedy them within a set time frame,
determined by the registrar. Once the registrar has closed out all outstanding nonconformities, a
registration certificate is issued.
The standard validity of a registration certificate is three years, after which a full re-audit is done
for renewal. To ensure that organizations are following ISO 14001 requirements after
registration is obtained, the registrar conducts on-site surveillance audits two times a year.
Remember: In order to achieve registration to ISO 14001, the organization must completely
embrace the standard, which focuses on performance, documentation and objective evidence.
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What to Look For in a Registrar
In selecting a registrar, it is extremely important for every organization to be aware of the
relevant qualifications.
A registrar must:
• Be accredited by a national accreditation body, such as the ANSI-ASQ Accreditation Board
(ANAB), the Raad voor Accreditatie (RvA) of the Netherlands, the United Kingdom
Accreditation Service (UKAS), or the Japan Accreditation Board for Conformity Assessment
(JAB) among others.
• Maintain a listing of its ISO 14000 qualified auditors;
• Have personnel on its executive (registration) committee or governing board with
environmental experience and expertise; and,
• Conform to ISO/IEC 17021:2011, Conformity assessment – Requirements for bodies
providing audit and certification of management systems.
What to Look For in an Auditor
Requirements have been established for the auditors working for accredited ISO 14000
registrars. Before an auditor can evaluate an organization’s facility to verify whether its EMS
conforms to ISO 14001 requirements, the auditor must satisfy the following conditions:
1) Auditors working for or on behalf of registrars must have satisfactorily completed ISO 14000
training courses and demonstrated their knowledge of ISO 14001 by passing an exam. A
certificate is awarded to those auditors who have successfully completed this training;
2) Auditors must comply with ISO/IEC 17021:2011, Conformity Assessment – Requirements
for Bodies Providing Audit and Certification of Management Systems; and,
3) They must be recognized and qualified as ISO 14000 auditors under the registrar’s criteria.
Before hiring the services of a registrar, it’s a good idea to make sure the registrar and its
auditors have met the above qualifications.
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PART 1 – ISO 14001:2004
WHAT IS ISO 14000?
ISO 14000 is a series of generic environmental management systems (EMS) standards created by
the International Organization for Standardization (ISO), a federation of 132 national standards
bodies based in Geneva, Switzerland. The American National Standards Institute (ANSI) is the
member body representing the United States. The goal of these standards is to give top
management of any organization a framework for managing its environmental aspects and
impacts.
An environmental aspect is defined by ISO 14001 Section 3.6 as an “element of an
organization’s activities, products or services that can interact with the environment.” ISO
14001 Section 3.7 defines an environmental impact as “any change in the environment, whether
adverse or beneficial, wholly or partially resulting from an organization’s environmental
aspects.”
The ISO 14000 series of standards attempts to harmonize environmental management activities
for industries all over the world. The series promotes a common approach to environmental
management that can be used by any organization, of any size, anywhere in the world.
These standards are divided into two classifications:
• Organization Evaluation
• Product and Service Evaluation
Organization Evaluation, in turn, consists of three components:
• Environmental Management Systems (EMS)
• Environmental Auditing
• Environmental Performance Evaluations (EPE)
Product and Service Evaluation also consists of three components:
• Environmental Labeling
• Life-Cycle Assessment (LCA)
• Environmental Aspects in Product Standards (EAPS)
The most important ISO 14000 standard, and the key member of the EMS component, is ISO
14001:2004, Environmental Management Systems – Requirements with Guidance for Use. This
standard sets EMS requirements to which an organization must conform, and is the single
standard within the ISO 14000 series to which an organization may become registered.
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All other ISO 14000 standards are guidance documents and technical reports, assisting an
organization in developing its EMS. These standards contain recommendations that
organizations may use to clarify or go beyond ISO 14001 requirements. Additional requirements
for R2/RIOS, RoHS and REACH are specified within applicable sections of this Executive
Overview document.
The Origin of ISO 14000
The international environmental movement that developed in the 1960s spurred environmental
legislation around the globe during the 1970s, with the strongest regulations in industrialized
nations. Regulatory compliance proved costly for many companies, with environmental
improvements sometimes falling short of expectations. Attempts by some industries to police
themselves failed to establish a viable and credible worldwide consensus.
ISO, which had released the ISO 9000 quality management systems standards in 1987, stepped
into the breach to create a voluntary global approach to environmental management. In 1991,
ISO established the Strategic Advisory Group on the Environment (SAGE) to research the need
for international environmental standardization. In addition to its ISO responsibilities, SAGE
was a major contributor to the 1992 United Nations Earth Summit in Rio de Janeiro, Brazil,
particularly in adopting a commitment to sustainable development.
At the same time, the British Standards Institution (BSI) released BS 7750, Environmental
Management Systems, the first EMS standard. BS 7750 stressed overall environmental systems
performance, with mandatory audits to confirm and maintain a company’s conformity and
registration to the standard. The European Union (EU) followed with its Eco-Management Audit
Scheme (EMAS), which contained similar requirements.
In light of these developments, SAGE recommended developing an international series of EMS
standards, and ISO established Technical Committee (TC) 207, Environmental Management, to
carry out this work. Both BS 7750 and EMAS were influential in developing the ISO 14000
standards.
In 1996, the first five ISO 14000 standards were released. They were ISO 14001; the guidance
document ISO 14004:1996, Environmental Management Systems – General Guidelines on
Principles, Systems and Supporting Techniques; and three auditing standards: ISO 14010:1996,
Guidelines for Environmental Auditing – General Principles, ISO 14011:1996, Guidelines for
Environmental Auditing – Audit Procedures – Auditing of Environmental Management Systems,
and ISO 14012:1996, Guidelines for Environmental Auditing – Qualification Criteria for
Environmental Auditors.
ISO/TC 207 has continued its work, releasing and revising ISO 14000 standards, guidance
documents and technical reports, some of which are still in draft status as of this writing.
The revised second edition of ISO 14001 was released in 2004, (ISO 14001:2004) and clarifies
various requirements specified within the first edition. Additional consideration has been given
to the requirements of ISO 9001:2000 (now ISO 9001:2008) to ensure consistency between the
standards to support a more uniform approach.
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The sub-clause numbers in Clause 4 and in Annex A now correspond to support ease of use.
Annex B now identifies broad technical relationships between ISO 14001:2004 and ISO
9001:2000(8). ISO 14001:2004 describes the requirements for an organization's environmental
management system that can be used to support certification/registration and/or self-declaration
of the organization’s environmental management system.
ISO 14004 was also revised to ISO 14001:2004 and is intended to serve as a non-certifiable
guideline intended to provide strategic assistance organizations wishing to establish, implement
or improve an existing environmental management system.
ISO 14000 Series Standards
Organization Evaluation Standards
ISO 14001:2004 Environmental Management Systems – Specification with Guidance for Use
ISO 14004:2004 Environmental Management Systems – General Guidelines on Principles, Systems
and Supporting Techniques
ISO 14015:2001 Environmental Management – Environmental Assessment of Sites and
Organizations (EASO)
ISO 14031:1999 Environmental Management – Environmental Performance Evaluation – Guidelines
ISO/TR 14033:2012 Environmental management – Quantitative environmental information –
Guidelines and examples
ISO 14050:2009, Environmental Management – Vocabulary
ISO 19011:2011 Guidelines for Auditing Management Systems
ISO/IEC Guide 66:1999 General Requirements for Bodies Operating Assessment and
Certification/Registration of Environmental Management Systems (EMS)
Product and Service Evaluation Standards
ISO 14020:2000 Environmental Labels and Declarations – General Principles
ISO 14021:1999, Amd 2011, Environmental Labels and Declarations – Self-Declared Environmental
Claims (Type II Environmental Labeling)
ISO 14024:1999 Environmental Labels and Declarations – Type I Environmental Labeling –
Principles and Procedures
ISO/TR 14025:2006 Environmental Labels and Declarations – Type III Environmental Declarations
ISO 14040:2006 Environmental Management – Life Cycle Assessment – Principles and Framework
ISO 14044:2006 Environmental management – Life cycle assessment – Requirements and guidelines
ISO 14045:2012, Environmental management – Eco-efficiency assessment of product
systems – Principles, requirements and guidelines
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ISO/TR 14047:2012 Environmental management – Life cycle assessment – Illustrative examples on
how to apply ISO 14044 to impact assessment situations
ISO/TS 14048:2002 Environmental Management – Life Cycle Assessment – Data Documentation
Format
ISO/TR 14049:2012 Environmental management – Life cycle assessment – Illustrative examples on
how to apply ISO 14044 to goal and scope definition and inventory analysis
ISO/TR 14062:2002 Environmental Management – Integrating Environmental Aspects Into Product
Design and Development
ISO 14063:2006 Environmental management – Environmental communication – Guidelines and
examples
ISO 14064-1:2006 Greenhouse gases – Part 1: Specification with guidance at the organization level
for quantification and reporting of greenhouse gas emissions and removals
ISO 14064-2:2006 Greenhouse gases – Part 2: Specification with guidance at the project level for
quantification, monitoring and reporting of greenhouse gas emission reductions or removal
enhancements
ISO 14064-3:2006 Greenhouse gases – Part 3: Specification with guidance for the validation and
verification of greenhouse gas assertions
ISO 14063:2006 Environmental management – Environmental communication – Guidelines and
examples
ISO Guide 64:2008 Guide for addressing environmental issues in product standards
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ISO 14000 Components
The ISO 14000 series of standards, organized into two classifications and six components.
Organization Evaluation Standards
Environmental Management Systems (EMS)
Environmental Management Systems (EMS) is the entire environmental program planned by an
organization. ISO 14001 Section 3.8 defines an EMS as “the part of an organization’s
management system used to develop and implement its environmental policy (3.11) and manage
environmental aspects (3.6).”
The overall intentions of an organization related to its environmental performance must be
documented in an environmental policy, along with other necessary documents, such as an
environmental manual. These documents must define the EMS in detail and clearly state the
organization’s environmental objectives and targets.
The environmental policy is defined by ISO 14001 Section 3.11 as an “overall intentions and
direction of an organization (3.16) related to its environmental performance (3.10) as formally
expressed by top management.” ISO 14001 Section 3.9 defines an environmental objective as an
“overall environmental goal, consistent with the environmental policy (3.11), that an
organization sets itself to achieve.” An environmental target is defined by ISO 14001 Section
3.12 as a “detailed performance requirement, applicable to the organization or parts thereof, that
arises from the environmental objectives and that needs to be set and met in order to achieve
those objectives.”
EMS standards are:
• ISO 14001:2004, Environmental Management Systems – Requirements with Guidance for
Use, which specifies EMS requirements that seek confirmation for self-declaration or
registration purposes.
• ISO 14004:2004, Environmental Management Systems – General Guidelines on Principles,
Systems and Support Techniques, which provides guidance to help an organization establish,
implement, maintain and improve an EMS, including guidance that goes beyond ISO 14001
requirements.
• ISO 14050:2009, Environmental Management – Vocabulary, which helps an organization
understand the terms and definitions used in the ISO 14000 series standards.
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Environmental Auditing
The ISO 14000 series relies heavily on auditing to ensure that ISO 14001 requirements are being
met. ISO 14001 mandates audits, with Element 4.5.4 stating, “The organization shall establish
and maintain (a) program(s) and procedures for periodic environmental management system
audits to be carried out.” Both internal and external audits are used to ensure conformity to ISO
14001, and can be of great benefit to a facility.
Environmental Auditing standards are:
• ISO 19011:2011, Guidelines for Auditing Management Systems, which provides guidance on
auditing principles, audit program management, the conduct of management system audits
and auditor competence. More detail on this support document appears in the section on
Meeting Environmental Auditing Requirements.
• ISO 14015:2001, Environmental Management – Environmental Assessment of Sites and
Organizations (EASO), which helps an organization to identify and assess the environmental
aspects and associated business consequences of sites and organizations to support the
transfer of properties, responsibilities and obligations from one party to another.
• ISO/IEC Guide 66:1999, General Requirements for Bodies Operating Assessment and
Certification/Registration of Environmental Management Systems (EMS), which sets
operational requirements for ISO 14000 registrars.
Environmental Performance Evaluation (EPE)
Once an EMS is implemented, its performance must be evaluated for effectiveness. The
Environmental Performance Evaluation (EPE) should be conducted by front-line employees who
continually monitor the production process to ensure that environmental requirements are being
met.
EPE standards are:
• ISO 14031:1999, Environmental Management – Environmental Performance Evaluation –
Guidelines, which provides guidance on selecting and using indicators to evaluate an
organization’s environmental performance.
• ISO/TR 14033:2012, Environmental Management – Quantitative Environmental Information
- Guidelines and Examples, which provides guidelines on how to acquire quantitative
environmental information and data and implement methodology.
• ISO 14063:2006, Environmental Management – Environmental Communications –
Guidelines and Examples, provides guidance on communication of an organization’s
environmental aspects and performance.
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Product and Service Evaluation Standards
Environmental Labeling
Many companies use environmental claims as a marketing tool for their products and services.
With ISO 14001 registration providing a similar labeling opportunity, these support documents
seek to prevent unwarranted claims, ensure that environmental claims are accurate and verifiable,
and set standards for the three types of environmental labels. These labeling categories are:
• Type I – Third-party certified labels
• Type II – Self-declared labels
• Type III – Product information claims based on life cycle inventory data
Environmental Labeling standards are:
• ISO 14020:2000, Environmental Labels and Declarations – General Principles, which
provides general principles for developing ISO guidelines and standards on environmental
claims and declarations.
• ISO 14021:1999, Amd 2011, Environmental Labels and Declarations – Self-Declared
Environmental Claims (Type II Environmental Labeling), which provides guidance on the
terminology, symbols, and testing and verification methodologies an organization should use
for self-declaring the environmental aspects of its products and services.
• ISO 14024:1999, Environmental Labels and Declarations – Type I Environmental Labeling –
Principles and Procedures, which provides the guiding principles and procedures for third-
party environmental labeling certification programs.
• ISO/TR 14025:2006, Environmental Labels and Declarations – Type III Environmental
Declarations, which identifies and describes elements and issues to be considered when
making quantified product information declarations based on life cycle inventory data.
Life Cycle Assessment (LCA)
Several support documents provide life cycle assessment study guidance. These standards
describe how to conduct a study of the environmental performance of a company’s products,
including inventory analysis, impact assessment and interpretation.
LCA standards are:
• ISO 14040:2006, Environmental Management – Life Cycle Assessment – Principles and
Framework, which provides the general principles, framework and methodological
requirements for the LCA of products and services.
• ISO 14044:2006, Environmental Management – Life cycle Assessment – Requirements and Guidelines, specifies requirements and provides guidelines for LCA.
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• ISO 14045:2012, Environmental management – Eco-efficiency assessment of product systems – Principles, requirements and guidelines.
• ISO/TR 14047:2012, Environmental Management – Life Cycle Assessment – Examples of
Application of ISO 14044, provides examples that illustrate current practice of life cycle impact assessment according to ISO 14044:2006.
• ISO/TS 14048:2002, Environmental Management – Life Cycle Assessment – Data
Documentation Format, which provides information regarding the formatting of data to support an LCA.
• ISO/TR 14049:2012, Environmental Management – Life Cycle Assessment – Illustrative
examples on how to apply ISO 14044 to impact assessment situations, which provides examples to illustrate how to apply the guidance in ISO 14044.
Environmental Aspects in Product Standards (EAPS)
Guidelines for environmental aspects in product standards recognize the potential effects of products on the environment, and recommend consideration of environmental aspects in developing future products and product standards. EAPS standards are: • ISO/TR 14062:2002, Environmental Management – Integrating Environmental Aspects Into
Product Design and Development, which provides concepts and current practices for integrating environmental aspects into product design and development.
• ISO Guide 64:1997, Guide for the Inclusion of Environmental Aspects in Product Standards,
which helps product standard writers address environmental aspects. • ISO 14064-1:2006, Greenhouse Gases – Part 1: Specification with Guidance at the
Organization Level for Quantification and Reporting of Greenhouse Gas Emissions and Removals, provides guidelines principles and requirements at the organization level for quantification and reporting of greenhouse gas (GHG) emissions and removals.
• ISO 14064-2:2006, Greenhouse Gases – Part 2: Specification with Guidance at the Project
Level for Quantification, Monitoring and Reporting of Greenhouse Gas Emission Reductions or Removal Enhancements, provides guidance at the project level for quantification, monitoring and reporting of activities intended to cause greenhouse gas (GHG) emission reductions or removal enhancements.
• ISO 14064-3:2006, Greenhouse Gases – Part 3: Specification with Guidance for the
Validation and Verification of Greenhouse Gas Assertions, provides guidance for those conducting or managing the validation and/or verification of greenhouse gas (GHG) assertions.
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Implementing an Environmental Management System
Implementing an EMS affects an entire organization and requires commitment across the board.
The implementation process begins with top management identifying the appropriate resources,
and then creating a personnel structure to plan and oversee the process.
IS0 14001 places this initial task in the hands of top management to provide direction for the
program and convey the importance of the EMS to employees. It also requires top managers to
draft policies, allocate resources, establish support systems, mandate training, formulate
appraisal systems and provide necessary communication.
Executive management must also select the management representative (MR), who is
responsible for the EMS throughout implementation, maintains the day-to-day EMS operations,
and reports on EMS performance to top management. ISO 14001 Element 4.4.1 requires top
management to appoint a management representative with “ensuring that an environmental
management system is established, implemented and maintained.”
The MR must identify available resources and personnel, develop procedures, track costs and
benefits, and gather information from each department manager for EMS review and
improvement.
Every employee must play a role in EMS implementation. Department managers are involved to
the degree that their operations produce environmental aspects and impacts. Floor employees are
the backbone of the whole system, since they carry out most of the organization’s activities that
can affect the environment.
Environmental training plays a big role in ISO 14001 EMS implementation. Element 4.4.2
requires all employees whose job duties may significantly affect the environment to be
competent on the basis of appropriate education, training and/or experience.
To ensure that employees have the resources they need to meet EMS requirements, the
organization must identify training needs. Element 4.4.3 recommends that the organization
inform interested parties, such as subcontractors, regulators and customers, of its significant
environmental aspects.
Auditors who evaluate an organization’s EMS must also be trained, with these requirements set
forth in ISO 19011.
ISO 14001 requires documentation, which the MR is responsible for establishing and
maintaining. Element 4.2 mandates an environmental policy that provides the framework for
setting environmental objectives and targets. Other documents include a description of the scope
of the environmental management system, procedures, work instructions and records. While
ISO 14001 does not define explicit requirements for an Environmental Manual, it is good
practice to maintain EMS documentation in some structured format such as a manual.
Documents are controlled under procedures required by Element 4.4.5.
Documentation presents a clear picture of a facility’s EMS as it compares to ISO 14001
requirements, providing objective evidence of EMS status. It also establishes an archive of EMS
information that aids in both operations and audits.
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Meeting Environmental Auditing Requirements
ISO 14001 requires organizations to continually monitor their performance through a systematic
auditing approach that compares a company’s environmental achievements to its objectives and
targets.
Auditing requirements are found in ISO 19011:2011, Guidelines for Auditing Management
Systems, which contains definitions of auditing terms, sets forth auditing principles, describes
audit program management requirements, provides guidance for conducting management system
audits, and presents auditor competence and evaluation requirements.
Understanding the Audit Process
An audit is a systematic, independent and documented process for obtaining audit evidence and
evaluating it objectively to determine the extent to which the audit criteria are fulfilled. During
an audit, an auditor measures the adequacy of the EMS, its effectiveness, and its conformity to
ISO 14001.
ISO 14001 Element 4.5.5 requires periodic audits of an organization’s EMS, with the scope,
frequency and methodologies of these audits covered by procedures. In registering an
organization to ISO 14001, the environmental policy and other documentation are reviewed first
during the Stage 1 (desktop) audit. Following this process, the auditor then examines the
company’s on-site operations during the Stage 2 (registration) audit, to ensure that the EMS
requirements are met. Both stages are incorporated into an internal audit.
Upon completing the Stage 2 audit, it is the auditor’s job to identify areas of operation where the
EMS does not meet ISO 14001 requirements. The auditor will require the organization to take
corrective action to close out any nonconformities before a registration certificate can be issued.
In an internal audit, implementation of these actions must be verified during either a follow-up
audit or the next surveillance audit.
If corrective actions are required for the organization’s environmental policy, procedures or other
EMS components as a result of nonconformities, the ISO 14000 management representative,
together with the department manager of the affected area, should guide these activities. The
management representative is also responsible for updating documentation to reflect changes that
result from corrective and preventive actions.
Documentation Review
A thorough review of an organization’s EMS documentation is conducted during the Stage 1
audits. Documentation includes the environmental policy, procedures, work instructions and
records, which are reviewed for conformity to ISO 14001 requirements, along with other
applicable requirements, such as regulatory mandates. Documentation is an invaluable reference
source because it serves as the foundation of the EMS and provides objective evidence on its
status.
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In most organizations, documentation is structured in the following four-tier hierarchy:
• Tier 1 – Environmental Policy with optional EMS Manual
• Tier 2 – Procedures
• Tier 3 – Work Instructions
• Tier 4 – Records
The environmental policy defines the criteria against which the EMS measured. If this review shows that the organization’s documentation fails to meet ISO 14001 requirements, the Stage 2 audit cannot be scheduled until the situation is corrected.
Performing Internal Audits
An internal audit is performed by an organization’s personnel, and may be carried out by the management representative or any employee who has demonstrated competence based on education, training, skills and experience as referenced in ISO 19011 Section 7.2.4. The goal of an internal audit is to assess the adequacy and effectiveness of the management system and to determine where improvements can be made. In order to maintain impartiality, internal auditors are not allowed to audit their own work.
Auditor competence is a critical component for ISO 14001 registration. It is important for auditors, especially internal auditors, to receive training that is relevant and comprehensive with regard to the entire ISO 14000 series, and is conducted according to ISO 19011 requirements.
Taking Corrective Action
There are several reasons why an EMS might not meet ISO 14001 requirements. The program may have failed to keep up with environmental regulations during a period of rapid change. Perhaps employees have not been trained to new procedures or no provisions have been made to ensure that all employees have the resources needed to implement these procedures.
In any case, it is the responsibility of the management representative and top management to review the plan and correct it when necessary. The goal is to detect and then correct the root causes of deficiencies. This is another area in which an external auditor or consultant may prove invaluable.
If an audit reveals that your company needs to take corrective action for nonconformities, it is not a cause for alarm. If the nonconformity was identified as a minor, it is a problem that can be easily rectified and will not usually block the registration process
The corrective action process is more involved for a major nonconformity, a deficiency or break down in the EMS that is preventing the organization from achieving its environmental objectives and targets. When a major nonconformity is identified, it usually means that a significant change must be made to the EMS by adding a procedure or changing a practice to eliminate its root cause and prevent it from recurring.
Once the nonconformities are corrected, a follow-up audit specific to the areas of concern is usually required. This is done to confirm that the problem has been resolved. In the case of a Stage 2 audit, registration cannot be achieved until it is verified that all nonconformities have been corrected.
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THE BENEFITS OF ISO 14000
ISO 14001 registration creates innumerable advantages and unlimited benefits for organizations
within both the public and private sectors. Reasons for seeking registration include fulfilling
legal requirements, satisfying contractual requirements, achieving internal improvements,
reducing multiple audits, regulatory and legal concerns, and marketplace benefits.
In some countries, ISO 14001 registration may become a legal requirement to enter the
marketplace. This may occur in the European Union (EU) and Japan.
ISO 14001 registration enhances a company’s public image while offering safeguards against
lawsuits through reduced exposure to liabilities. Companies can face stiff fines and time-
consuming lawsuits for not adhering to environmental regulations. Furthermore, registration can
greatly improve a company’s competitive stance, especially when it comes to overseas trade.
In the business sector, ISO 14001 registration has become a contractual requirement of some
major companies in purchasing products and services. Additional mandates are expected in the
future.
To consumers, a company’s registration to ISO 14001 provides assurance that it is committed to
protecting the environment through proactive activities that can be objectively demonstrated.
Even if ISO 14001 registration is not a customer-mandated requirement, businesses may opt to
pursue it for such benefits as cost reduction, prestige, an assumed perception of environmental
responsibility, and a positive public response.
Most companies realize that self-improvement is imperative for business prosperity and growth.
Internal improvement is yet another reason for ISO 14001 registration. When environmental
management is a high priority of a company’s management team, this positive message is
reinforced throughout the workplace.
Organizations that have implemented ISO 14001 often see improvements in productivity, waste
reduction, energy efficiency and regulatory compliance costs.
We are all becoming increasingly aware of the costs of environmental damage: contaminated
ground water, polluted air, doubts and uncertainties about a sustainable future, and the expense
of remediation.
ISO 14000, by requiring organizations to plan, implement and maintain an EMS, can be used to
prevent and minimize environmental impacts through a common sense approach, allowing
companies to take charge of their environmental affairs while improving regulatory compliance.
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There are monetary benefits as well. Through the continual improvement process, an
organization can save money by preventing pollution, avoiding cleanup and liability costs, using
energy more efficiently and reducing waste.
ISO 14001 registration, besides easing regulatory compliance, can improve a company’s
competitiveness, as a growing number of major firms have set supplier registration mandates.
Registration can also aid companies seeking to enter the EU and Japanese markets.
There are many benefits to be derived from implementing a well-structured ISO 14001 EMS,
and the registration process is rigorous and timely. For this reason, not to mention the high rate
of failure that afflicts organizations seeking registration for the first time, it is a good idea to seek
the services of an outside professional consulting firm.
A competent environmental consultant can walk your organization through the ISO 14001
requirements, interpret and implement the standard to your specific situation, and identify any
problems that may halt the implementation and registration process.
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ISO 14001 ENVIRONMENTAL MANAGEMENT SYSTEM
REQUIREMENTS
NOTE: Requirements are paraphrased to avoid issues associated with potential copyright infringements.
4.1 General Requirements
The organization shall establish, document, implement, maintain and continually improve an
environmental management system in accordance with the requirements of ISO 14001:2004 and
determine these requirements will be fulfilled.
The organization shall define and document its environmental management system scope.
4.2 Environmental Policy
Top management shall define the organization's environmental policy and ensure that the scope
of its environmental management system:
a) Is appropriate to the nature, scale and environmental impacts of its activities, products or
services provided.
b) Includes a commitment to continual improvement and pollution prevention.
c) Includes a commitment to comply with applicable environmental legislation and regulations,
and with other requirements to which the organization subscribes that relate to its
environmental aspects.
d) Provides the framework for establishing and reviewing environmental objectives and targets.
e) Is documented, implemented and maintained.
f) Is communicated to employees and other persons working for or on behalf of the
organization.
g) Is available to the public.
4.3 Planning
4.3.1 Environmental Aspects.
The organization must establish and maintain (a) procedure(s):
a) To identify environmental aspects related to its activities, products and services within the
defined scope of the environmental management system that it can control and those that it
can influence giving consideration to planned or new developments, or new or modified
activities, products and services.
b) To determine aspects that have or can have significant impact(s) on the environment.
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The organization must keep this information up to date.
The organization shall ensure that the significant environmental aspects given consideration
when establishing, implementing and maintaining its environmental management system.
4.3.2 Legal and Other Requirements
The organization shall establish, implement and maintain a procedure:
a) To identify and have access to relevant legal and other requirements to which the
organization subscribes, that are applicable to its environmental aspects.
b) To determine how these requirements relate to its environmental aspects.
The organization shall ensure that these relevant legal and other requirements to which the
organization subscribes are given consideration when establishing, implementing and
maintaining its environmental management system.
4.3.3 Objectives and Targets
The organization shall establish, implement and maintain documented environmental objectives
and targets, at relevant functions and levels within the organization.
The objectives and targets shall be measurable and consistent with the environmental policy,
including the commitments to prevention of pollution, to compliance with applicable legal and
other requirements to which the organization subscribes, and to continual improvement.
When establishing and reviewing its objectives and targets, an organization shall give
consideration to the legal and other requirements to which the organization subscribes, and its
significant environmental aspects. It shall also consider its technological options, its financial,
operational and business requirements, and the views of interested parties.
The organization shall establish, implement and maintain a program(s) for achieving its
objectives and targets. Program(s) shall include:
a) Designation of responsibility for achieving objectives and targets at relevant functions and
levels throughout the organization.
b) The means and time-frame for achieving the objectives.
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4.4 Implementation and Operation
4.4.1 Resources, Roles, Responsibility and Authority
Management shall ensure the availability of resources necessary to establish, implement,
maintain and improve the environmental management system. Resources include human
resources and specialized skills, organizational infrastructure, technology and financial
resources.
Roles, responsibilities and authorities shall be determined, documented and communicated in
order to facilitate effective environmental management.
The organization's top management shall appoint a management representative(s) who,
irrespective of other responsibilities, shall have defined roles, responsibilities and authority for:
a) Ensuring that an environmental management system is established, implemented and
maintained in accordance with the requirements of ISO 14001:2004.
b) Reporting to top management on the performance of the environmental management system,
including recommendations for improvement, for review.
4.4.2 Competence, Training and Awareness
The organization shall ensure that any person(s) working under its control that have the potential
to cause a significant environmental impact(s) identified by the organization is (are) competent
on the basis of appropriate education, training or experience, and shall retain associated records.
The organization shall determine training requirements associated with its environmental aspects
and its environmental management system. It shall provide training or take other action to meet
these needs, and shall retain associated records.
The organization shall establish, implement and maintain a procedure(s) to make persons
working under its control aware of:
a) The importance of conforming to the environmental policy and procedures and with the
requirements of the environmental management system.
b) The significant environmental aspects and related impacts associated with their work, and the
environmental benefits of improved personal performance.
c) Their roles and responsibilities in conforming with the requirements of the environmental
management system.
d) The potential consequences of departing from specified procedures.
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4.4.3 Communication
With respect to its environmental aspects and EMS, the organization shall establish and maintain
procedures for:
a) Internal communication between the organizations various levels and functions.
b) Receiving, documenting and responding to pertinent communication from external interested
parties.
The organization shall decide whether to communicate information regarding its significant
environmental aspects to external interested parties and shall document its decision. Where the
organization decides to communicate, the organization shall establish and implement a method(s)
to support external communication.
4.4.4 Documentation
Environmental management system documentation shall include:
a) The environmental policy, objectives and targets.
b) A description of the scope of the environmental management system.
c) A description of the main elements of the environmental management system including their sequence and interaction, and reference to related documents.
d) Documents, including records, required by ISO 14001:2004.
e) Documents, including records, determined to be necessary to ensure the effective planning, operation and control of processes that relate to the organization’s significant environmental aspects.
4.4.5 Control of Documents Documents required by the environmental management system and by ISO 14001:2004 shall be controlled. Records are a special type of document and shall be controlled in accordance with the requirements given in 4.5.4. The organization shall establish and maintain procedures for controlling EMS documents to ensure:
a) Documents are approved for adequacy prior to issue.
b) Documents are reviewed and updated as necessary and re-approved.
c) Changes and the current revision status of documents are identified.
d) Ensure that relevant versions of documents are available at points of use.
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e) Ensure that documents are maintained in a manner that preserves their legibility and availability.
f) Ensure that external documents required by the organization to support the planning and operation of the environmental management system are identified and their distribution controlled.
g) Prevent the unintended use of obsolete documents and ensure they are suitably identified if they are retained for any purpose.
4.4.6 Operational Control
The organization shall identify and plan those operations and activities that are associated with its significant environmental aspects in line with its policy, objectives and targets in order to ensure that they are carried out under specified conditions by:
a) Establishing, implementing and maintaining documented procedures to cover situations where their absence could lead to deviations from the environmental policy, objectives and targets.
b) Stipulating operating criteria in the procedures.
c) Establishing, implementing and maintaining procedures related to the identifiable significant environmental aspects of goods and services utilized by the organization, and communicating relevant procedures and requirements to suppliers and contractors.
4.4.7 Emergency Preparedness and Response
The organization shall establish, implement and maintain procedures to identify potential
emergency situations, and accidents that can impact(s) its environment and determine how it will
respond to them.
The organization shall respond to emergency situations and accidents in order to prevent or
mitigate associated adverse environmental impacts.
The organization shall periodically review and revise, its emergency preparedness and response
procedures, especially after the occurrence of accidents or emergency situations.
The organization shall periodically test such procedures where it is practical to do so.
4.5 Checking
4.5.1 Monitoring and Measurement
The organization shall establish, implement and maintain procedures to monitor and measure, on
at regular intervals, the key characteristics of its operations and activities that can have a
significant impact on the environment. The procedures shall include documenting information to
monitor performance, related to operational controls and conformity with the organization's
environmental objectives and targets.
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The organization shall ensure that monitoring and measurement equipment used is calibrated or
verified and maintained and shall retain associated records.
4.5.2 Evaluation of Compliance
4.5.2.1 Consistent with its commitment to comply with applicable legal requirements, the
organization shall establish, implement and maintain a procedure(s) for periodically
evaluating compliance.
The organization shall keep records of the results of the periodic evaluations.
4.5.2.2 The organization shall evaluate compliance with other requirements to which it
subscribes. The organization may choose to combine this evaluation with the evaluation
of legal compliance referred to in 4.5.2.1 or to establish a separate procedure.
The organization shall keep records of the results of the periodic evaluations.
4.5.3 Nonconformity, Corrective and Preventive Action
The organization shall establish, implement and maintain procedures for responding to and
investigating nonconformity(ies) and for taking corrective and preventive action. The
procedure(s) shall define requirements for:
a) Identifying and correcting nonconformity(ies) and taking necessary action(s) to mitigate their
environmental impacts.
b) Investigating nonconformity(ies), performing cause analysis and taking actions to prevent
their recurrence.
c) Evaluating the need for action(s) to prevent nonconformity(ies) and implementing
appropriate actions needed to prevent their occurrence.
d) Documenting and maintaining the results of corrective action(s) and preventive action(s)
taken.
e) Reviewing the effectiveness of action(s) taken.
Actions taken shall be appropriate for identified problems and the environmental impacts
encountered.
The organization shall ensure that necessary changes are made to relevant environmental
management system documentation.
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4.5.4 Control of Records
The organization shall establish and maintain records required to demonstrate conformity to the
requirements of its environmental management system and ISO 14001:2004, and the results
achieved.
The organization shall establish, implement and maintain a procedure(s) for the identification,
storage, protection, retrieval, retention and disposal of records.
Records shall be maintained in a manner that ensures they are legible, identifiable and traceable.
4.5.5 Internal Audit
The organization shall ensure that internal audits of the environmental management system are
conducted in accordance with planned arrangements to:
a) Determine the extent to which the environmental management system:
1. Conforms to the arrangements determined for environmental management including the
requirements of ISO 14001:2004.
2. Has been implemented and maintained as planned.
b) Provide information on audit results to management.
Audit program(s) shall be planned, established, implemented and maintained by the organization,
based on the environmental importance of the operation(s) concerned and previous audit results.
Audit procedure(s) shall be established, implemented and maintained that address:
• The responsibilities and requirements for planning and conducting audits, reporting results
and retaining related records.
• The planning of the audit criteria, scope, frequency and methods.
Selection of auditors and conduct of audits shall ensure that auditors are objective impartial.
Auditors shall not audit their own work.
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4.6 Management Review
Top management shall review the organization's environmental management system, at regular
intervals, to ensure its continuing suitability, adequacy and effectiveness. Management reviews
shall include assessing opportunities for improvement and the need for changes to the
environmental management system, including the environmental policy and environmental
objectives and targets. Records of the management reviews shall be retained.
Input to management reviews shall include:
a) Results of internal audits and compliance evaluations related to legal requirements and other
requirements to which the organization subscribes.
b) Communication(s) to and from external interested parties, including complaints.
c) The performance of the organization’s environmental management system.
d) Performance related to environmental objectives and targets.
e) The status of corrective and preventive actions.
f) Follow-up actions from prior management reviews.
g) Changes related to the environmental management system including developments in legal
and other requirements related to its environmental aspects.
h) Recommendations for improvement.
The outputs from management reviews shall include any decisions and actions related to
potential changes to the environmental policy, objectives, targets and other elements of the
environmental management system, commensurate with the organization’s commitment to
continual improvement.
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PART II – RESPONSIBLE RECYCLING (R2)
Introduction
The responsible recycling (“R2”) standard is applicable to organizations engaged in electronic
recycling and related activities. R2 defines practices supported by accredited certification
programs that assess the effectiveness of electronics recyclers’ environmental, health and safety,
and security practices.
The standard gives consideration to the needs of various interested parties. Customers benefit
from confidence that due diligence is practiced when processing and handling used and end-of-
life electronic equipment. Participating recyclers and refurbishers benefit through adherence to
value-added practices. Employees benefit through enhanced safety. Local and global
communities benefit by knowing that used and end of life electronics are processed in a manner
consistent with environmental responsibility and stewardship.
R2 requirements are conformance requirements and are not intended to replace legal or other
requirements to which participating organizations subscribe. Adherence to this set of R2
practices are determined and implemented on a voluntary basis. Where conflicts exist, legal
requirements take precedence over R2 or other requirements in all cases.
Electronics possess unique properties that differ from other Waste Streams. Most electronics
dispositioned for recycling are not classified as hazardous waste. Electronics are complex
devices that consist of a wide variety of materials, many of which would not be classified as
hazardous under EPA testing procedures.
Electronics contain hundreds of elements, compounds, and alloys including steel, plastic, glass,
ceramics, copper, aluminum, lead, nickel, zinc, lithium, carbon, cadmium, mercury, beryllium,
gold, silver, palladium, flame retardants, etc. Many of these materials possess residual value and
may pose risks if improperly disposed of or recycled.
Challenges related to the disposal of electronics have given rise to numerous environmental
concerns over the past many years including concerns about toxics from electronics leaching
from landfills and improper disposal methods such as open burning utilized in some developing
countries. Electronics that end up in landfills or incinerators represent lost resources.
Fact: In a gold mine, one ton of ore contains about only five to 10 grams of gold. One ton of
cell phones (about 10,000 cell phones) contains 300 to 400 grams of gold".
Focus Materials (FMs)
Some of the primary materials contained in electronic products represent hazards to the
environment or possess latent value that makes them prime candidates for reuse and/or recycling.
These materials are referred to as Focus Materials (FMs).
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Focus Materials include equipment and components containing:
• Cathode ray tubes and glass;
• Circuit boards;
• Batteries;
• Items containing mercury/PCBs; and
• While not a Focus Material, toner and toner cartridges are generally managed as FMs.
The History of R2
The EPA Recognized the need for a certification program that addressed the operational and
environmental needs of the electronics recycling industry and utilized a multi-disciplinary
process to develop the R2 Standard,“Responsible Recycling practices for Use in Accredited
Certifications Programs”.
A multi-stakeholder electronics summit was convened in March 2005. The objective was to
create a voluntary, market-based mechanism for ensuring best practices, that also provides
prospective customers with an enhanced sense of confidence by knowing that their used
electronics are processed in a safe, secure manner that is consistent with applicable
environmental requirements.
The R2 standard was developed through these collaborative efforts. It took 3 years to develop
the R2 standard. The R2 Standard was released on October 30, 2008.
Participants in the multi-stakeholder group included representatives from:
• The U.S. EPA,
• Regulators from state agencies,
• Electronics recyclers, refurbishers, and their trade associations,
• OEMs and customers of electronics recycling services,
• Non-Governmental Organizations (NGOs).
Representatives from environmental justice organizations participated throughout much of the
R2 development process, but withdrew participation prior to inception of the standard.
The Responsible Recycling (R2) Standard was developed as an output of this meeting. The R2
standard was issued as an authorized document after it was reviewed and approved by ANAB.
Development of the R2 standard included the following steps:
• R2 was drafted by an EPA funded neutral facilitator in a consensus-driven process,
• Each version was discussed by the quorum and revised by the facilitator,
• All versions were reviewed by 4 experienced auditors,
• Each version was 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).
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The R2 Technical Advisory Committee (TAC) develops and recommends changes to the R2
Standard. The TAC is comprised of representatives from the stakeholder group.
Essential R2 Concepts
• Reuse and Recycling Required,
• Focus materials can be disposed of only under exceptional circumstances,
• Provides for on-site worker and environmental protection,
• Requires downstream due diligence when handling and processing Focus Materials,
• Requires written programs based on a “Plan-Do-Check-Act” model for continual
improvement,
• Requires compliance with applicable legal requirements,
• Complimentary to ISO 14001 and OHSAS 18001 requirements,
• Ensures facility security and the security of data during storage and disposal of hard drives
and other equipment,
• Recyclers and refurbishers are required to track throughput and maintain records, and
• Requires a written policy based on a hierarchy of Reuse-Recover-Dispose.
R2 Certification provides additional value by demonstrating that your organization:
• Cares about the environment,
• Has implemented and maintains an effective environmental, health and safety management
system,
• Assumes accountability for electronic products, components and materials,
• Places a strong emphasis on controls necessary to ensure data security,
• Adheres to the highest industry standards and best practices, and
• Is committed to safety.
Electronics Use and Recycling Facts
• Americans purchase over 500 million new consumer electronic products annually.
• Over 15 separate electronic products can be found in the average American household.
• In 2010, the Federal Government spent approximately 75 billion for IT goods and services.
• Approximately 3-5 million tons of electronics are processed by the electronics recycling
industry annually.
• Electronic recycling volumes have more than doubled in past 5 years. This rate of growth is
expected to expand in the future.
• Consumer electronics comprise less than 5% of the electronics waste stream.
• Developing countries are on the fast track to generate more than double the developed
world’s used and end-of-life computers
The R2 standard is currently undergoing revision and a 2013 draft version of the Standard
has been documented and was recently going through the review and approval process.
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Integration & Comparison with ISO 9001 and ISO 14001 Requirements
There are many situations where R2 requirements do not specifically align with requirements of
ISO 9001 and 14001. Additional requirements that are distributed throughout the standard serve
to meet corresponding requirements of ISO 9001 and 14001 but are not clearly aligned with the
requirements of the other standards. These requirements include but are not limited to
requirements for:
• An R2 manual,
• Objectives and Targets,
• Internal Audits,
• Maintenance and Calibration,
• Nonconformance, Corrective and Preventive Actions,
• Training,
• Document and Record Control.
R2 Manual
There is no specific requirement for an R2 manual. There is a requirement to document a written
EHSMS that includes additional requirements for a policy in addition to written goals and
procedures. The scope of the management system should also be identified within the
documented EHSMS.
Objectives and Targets
There are no R2 Practices that address requirements for establishing and/or monitoring goals,
objectives and targets. R2 does require participating organizations establish objectives and
targets for tracking performance and planning activities that work toward achieving identified
goals. Additional requirements address the creation and implementation of an action plan for
continual improvement.
Internal Audit
There is no R2 Practice for internal auditing. There are requirements for a recycler to use an
EHSMS to plan and monitor its processes and activities to conform to R2 Practices. Additional
requirements mandate that a recycler confirm “through audits or other similarly effective means”
that downstream vendors comply with FM controls. There are also requirements for tracking
throughput. The R2 checklist used by recyclers also meets requirements for “internal auditing”.
Maintenance/Calibration
There is no R2 Practice that addresses equipment maintenance or calibration of test equipment
but there are implied requirements throughout the standard.
Nonconformance/Corrective/Preventive Action
There is no R2 Practice specifying requirements for nonconformances, corrective or preventive
actions. The PDCA structure of the standard tends to be complimentary to the use of corrective
and/or preventive actions. Other requirements implied within the standard can easily be
accommodated through the use of a formal corrective and preventive action process.
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Training
Training requirements are not called out in explicit terms within the standard but training issues
are addressed. There are requirements that recyclers possess expertise and technical capability to
process each type of equipment, component and material in order to protect employees, public
and the environment. The standard also requires regular, documented health and safety training
as well as refresher training.
Additional training requirements apply to volunteer and temporary workers. There are also
requirements for the assignment of an individual (consultant or employee) to coordinate and
promote worker health and safety and requirements for employees involved in data destruction to
be trained on a regular basis.
Document/Records Control
There is no R2 Practice for the control of internal external documents and obsolete documents,
records retention times, etc. These requirements however are clearly implied. There are
requirements for record maintenance included within the standard.
The EHSMS has to be documented implying some level of document control must be
implemented. There are additional requirements for written procedures, a list of the
documentation and multiple other references to requirements for documents requiring at least
minimal control interspersed throughout the standard.
R2 Certification
On July 27, 2009 ANAB announced the availability of the accreditation rule for R2 ANAB Rule
#34.
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 and must reference ISO 17021,
• Registrars certificates must have ANAB seal to be valid,
• Registrars are required to maintain a publicly available list of clients,
• Only single-site certification is possible.
ISO 17021:2006 requirements for bodies providing management system certifications
• 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 (annually or more frequently as required,
• Establishes requirements for recertification (3 year intervals), and
• Establishes what the requirements for activities to be conducted during the course of audits.
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R2 Certification Requirements
Stage 1 Requirements:
• Documents needed to address R2 requirements,
• Client understanding and awareness of requirements and of the of the organization’s
significant environmental/safety risks,
• Site-specific conditions/profiles,
• The scope of the ESHMS must be defined,
• Compliance evaluations need to completed and findings addressed,
• Evaluate internal audit planning and performance processes and annual (management)
reviews.
Stage 2 Requirements:
• Conformity to requirements – Implementation,
• Performance monitoring against key performance indicators (KPIs),
• Evidence of ongoing legal compliance,
• Provision of operational controls,
• Internal audits and annual reviews are carried out as required, and
• Determining responsibility and authority for policies.
Certification Steps:
In addition to Stage 1 and 2 requirements, the following steps need to be followed:
• Contract with an accredited certification body,
• Address any nonconformities determined during the Stage 1 and 2 audits,
• Certification granted.
R2 Solutions
R2 Solutions is an independent non-profit organization tasked with managing and overseeing
implementation of the R2 Practices standard. R2 Solutions promotes environmental protection,
human health and safety, and a financially stable global electronics recycling industry through
the responsible management of used electronic equipment. R2 Solutions possesses a highly
regarded Board of Directors representing stakeholder interests, has an open and transparent
governance structure, and provides a long-term sustainable quality control mechanism.
R2 Solutions provides the following benefits to R2 certified processors:
• Increased awareness of R2 Practices amongst industry and government sectors,
• Listing of certified facilities in the directory on the R2 Solutions website,
• Continues to works with key stakeholders to ensure the standard meets current and future
needs,
• Represents R2 certified processors in national and international forums, and
• Creates a transparent methodology for managing the R2 standard.
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Security Benefits
Data breach from discarded computers is ranked as the number one concern when disposing of
IT equipment. Establishing environmental practices, ensuring proper e-waste disposal, and
finding asset disposition support for remarketing or reusing equipment are also high priorities.
The R2 Standard addresses all of these areas of concern. Certified R2 recyclers are subject to
independent, third party audits to assess the effectiveness of the management system and
conformance to related requirements.
Additional Rules and Requirements
International and Governing Rules
The Organization for Economic Cooperation and Development (OECD Countries) has developed
additional controls for hazardous waste recovery. Only CRTs have been exported as hazardous
waste under OECD controls.
Basel Convention
Basel established a control system for importing and exporting hazardous wastes to prevent
unauthorized processing or dumping in developing countries. Hazardous waste cannot be
remanded to non-OECD countries without a bilateral agreement. The U.S. is not a Party to the
Basel Convention but is in favor of ratification.
Hazardous Waste Definitions
Basel Waste definitions vary between different countries. The Basel definition of “hazardous
waste” is not the same as the U.S. Definition. The U.S. conditionally exempts hazardous waste
from regulation or excludes certain materials from being defined as waste to encourage recycling
Basel treats material dispositioned for recycling and disposal in the same manner.
Basel convention requirements state that transboundary shipments should be reduced. The waste
should be treated where it is generated.
BAN and the BAN Amendments to the Basel Convention
The BAN (Basel Action Network) is an independent charitable organization with NO direct
relationship with the Basel Convention. BAN charges licensing fees for e-stewards certification
as well as a general cost for certification.
Many states have adopted electronics take back laws. For a list of participating states, see
www.ElectronicsRecycling.org or www.electronicstakebac.com.
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Universal Waste Rule
The Universal Waste Rule applies to mercury-containing devices considered to be hazardous
waste. Additional requirements have been stream lined to accommodate materials designated for
recycling or disposal.
CRT Rule
The CRT Rule and related requirements have been established to address Cathode Ray Tube
(CRT) processing. CRTs and CRT glass are not considered solid or hazardous waste when
reused or recycled if certain conditions are met (i.e., mercury and batteries have been removed)
(see 40 CFR, Subpart E, 261.39).
Whole used and shredded circuit boards are exempted from regulation if they meet certain
requirements.
R2 Practices
R2 Practices are posted on EPA’s website at:
www.epa.gov/epawaste/conserve/materials/ecycling/r2practices.htm
They are also found on the facilitator’s website at:
www.decideagree.com/TheR2Practices.html
The auditors checklist can also be obtained from decide agree.
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THE R2 PRACTICES
NOTE: Requirements are paraphrased to avoid issues associated with potential copyright infringements.
1. Environmental, Health, and Safety Management System
General Principle – An R2 electronics recycler shall develop and maintain an Environmental,
Health, and Safety Management System (EHSMS) to plan and monitor the performance of its
environmental, health, and safety practices, including the activities it undertakes to conform to
these R2 Practices.
R2 Practices:
(a) An R2 electronics recycler shall develop, document implement, maintain, review and
update annually or more frequently as required (e.g., as products and/or technologies
change) a written EHSMS that:
(1) Includes written objectives and procedures that require organizations to
systematically manage their environmental, health, and safety matters, and
(2) Uses a “Plan-Do-Check-Act”* model for continual improvement, and
(3) Includes sections that include the following:
(A) A policy governing used and end-of-life electronics equipment that is based on
a “reuse, recover, dispose” hierarchy of responsible management strategies and
addresses materials management on site and throughout the Recycling Chain (as
described in Provision 2),
(B) A plan for compliance to environmental, health, and safety legal requirements
relating to its operations, and for ensuring it only exports items containing
Focus Materials to countries that legally accept them (as described in Provision
3),
(C) A “FM Management Plan” – addressing the manner in which R2 Focus
Materials (FMs) that pass through the R2 recycler’s facility or control should be
properly managed, on site and throughout the Recycling Chain (as described in
Provision 5) – this can be a subsection of the section described in (A) above,
(D) An EHS hazards assessment identifying on-site occupational and environmental
risks (as described in Section (c) of Provision 4),
(E) A plan for responding to and reporting exceptional releases, accidents, spills,
fires, explosions, and other out-of-the-ordinary events that represent risks to
worker safety, public health, or the environment – this section should be
provided to local emergency responders as needed, and
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(F) A list of the activities necessary to conform to R2 Practices and a list of the
documents required to demonstrate evidence conformity with these
requirements.
(b) An R2 electronics recycler shall be certified by an Accredited Certification Body stating
that:
(1) Its EHSMS conforms to the requirements of this practice, and
(2) Its practices conform to requirements related to the EHSMS and of these R2
Practices.
*Elements of this model include:
Plan – (a) Identify environmental and worker health/safety, and legal and regulatory
requirements; (b) Determine and implement environmental goals, objectives and targets; (c) Plan
actions that work toward achieving goals, objectives and targets; (d) Plan for emergencies and
response; and (e) Identify management commitment.
Do – (a) Establish roles and responsibilities for the EHSMS and provide necessary resources; (b)
Ensure that staff associates are trained and competent for functions performed; and (c) Establish
a process for communicating information related to the EHSMS.
Check – (a) Monitor key activities and measure performance; (b) Identify and correct problems
to prevent recurrence; and (c) Provide a system for measuring performance.
Act – (a) Conduct annual performance reviews; (b) Make necessary changes to the EHSMS; (c)
Determine and adopt an action plan for continual improvement.
2. “Reuse, Recover, ...” Hierarchy of Responsible Management Strategies
General Principle – An R2 electronics recycler shall develop and abide by a policy for managing
used and end-of-life electronic equipment that is based on a “reuse, recover, dispose” hierarchy
of responsible management strategies.
R2 Practices:
(a) An R2 electronics recycler shall develop and adhere to a written policy stating how it
manages used and end-of-life electronics equipment, components, and materials –
governing both onsite activities and the selection of downstream vendors – which is based
on prioritized responsible management strategies:
(1) Reuse – An R2 electronics recycler shall disposition properly functioning equipment
and components for reuse unless a customer directs otherwise,
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(2) Materials Recovery – An R2 electronics recycler shall separate materials in
equipment and components that are not dispositioned for reuse and direct them to
properly-equipped materials recovery facilities when technically and economically
feasible.
(3) Energy Recovery or Disposal – An R2 electronics recycler shall direct remaining
materials to approved energy recovery and/or disposal facilities in conformity with
Provision 5.
(b) This policy shall correspond with the Focus Material Management Plan that the R2
electronics recycler develops in accordance with Provision 5.
3. Legal Requirements
General Principle – An R2 electronics recycler shall comply with all applicable environmental,
health, and safety legal requirements and regulations and shall only export equipment and
components containing FMs to countries that legally accept them.
R2 Practices:
(a) In order to maintain its compliance with all applicable environmental, health, and safety
legal requirements and to assure it only exports equipment and components containing FMs
to countries that legally accept them, an R2 electronics recycler shall determine and
implement a plan addressing these matters to be included as a section of its EHSMS.
(1) The plan shall identify and document the environmental, health, and safety legal
requirements that cover the recycler’s scope of activities. The recycler shall ensure
the plan is current, identify and implement the steps necessary to comply with
applicable requirements, document the implementation of these steps, periodically
evaluate its compliance with the requirements and take corrective actions to address
any issues resulting from non-compliance.
(2) The plan shall identify and document the applicable legal compliance – under the
laws of the importing countries – of all international shipments of equipment,
components, or materials containing FMs that have passed through the R2 recycler’s
facility or control*. The recycler shall identify the countries that receive these
shipments, obtain documentation showing that each non-OECD** country legally
accepts such shipments, and only make shipments to countries for which it has such
documentation***. The documentation shall be comprised of one of the following:
(A) A copy of the applicable information from the United States Environmental
Protection Agency, or
(B) Documentation**** from the country’s Competent Authority stating that such
imports are legally accepted, or
(C) A copy of a law or court ruling from the importing country that provides
evidence of the legality of the import.
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* This includes materials handled by downstream vendors.
** The R2 Document implies that these shipments are legal to import into OECD countries.
*** Recyclers that export used CRTs for reuse and CRT or mixed CRT glass for recycling
also have to meet export requirements under USEPA's CRT rule (FR: July 28, 2006
Volume 71, Number 145).
**** The documentation must be in a language consistent with the language of the R2
recycler’s third-party R2 auditor to enable easy interpretation.
4. On-Site Environment, Health, and Safety
General Principle – R2 electronics recycler shall adhere to practices at their facilities that
ensure worker health and safety and environmental protection.
R2 Practices:
General
(a) An R2 electronics recycler shall be competent and possess the technical capability to
process each type of equipment, component, and material it accepts in a manner that
protects worker safety, public health, and the environment.
(b) An R2 electronics recycler adheres to good housekeeping practices, including maintaining
work and storage areas clean and orderly manner. Clean up procedures for all areas of the
facility should be planned, regularly implemented, and evaluated.
Workforce and Environmental Protection
(c) An R2 electronics recycler shall conduct hazards identification and assessment of
occupational and environmental risks on an ongoing basis addressing existing risks or risks
that could reasonably be expected to develop at the facility.
Such risks could result from various sources, including but not limited to emissions of
and/or exposure to substances*, noise, ergonomic factors, thermal stress, substandard
machine guarding, cuts and abrasions, etc. The hazards identification and assessment shall
be documented and included as a component of the recycler’s EHSMS.
(d) An R2 electronics recycler shall control hazards and minimize the releases it identifies
using an appropriate combination of strategies, including but not limited to (1-3 below are
in order of priority, per OSHA regulations):
(1) Engineering controls such as (A-C below are prioritized in accordance with OSHA
regulations):
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(A) Substitution (e.g., replacing a hazardous material with one that is less hazardous
and more environmentally friendly);
(B) Isolation (e.g., automating a process to avoid exposure), or
(C) Ventilation and if appropriate, retention (e.g., fume hood),
(D) Dust control, retention, and clean up,
(E) Emergency shut-off controls and
(F) Fire suppression equipment.
(2) Administrative and work practice strategies, including appropriate combinations of:
(A) Documented health and safety training that covers information from the
hazards assessment, as well as safe management handling, spill prevention,
engineering controls, equipment safety, and use and care of personal
protection equipment conducted on a regular basis. Training shall be provided
to new associates and refresher training provided to all employees in a
language that is easy to understand and is appropriate for their educational
background.
(B) Cross training as feasible given workforce size,
(C) Safe work practices,
(D) Medical oversight,
(E) Safety meetings,
(3) Personal protective equipment, including respirators, protective eyewear, cut-resistant
gloves, etc., as needed for the risks associated with the work performed.
(e) An R2 electronics recycler shall utilize monitoring and sampling procedures to provide
confidence that the practices it employs are effectively and continuously managing the
risks it has identified. This includes complying with all applicable Federal or State
regulations, OSHA standards and PELs for sampling and/or monitoring.
(f) An R2 electronics recycler shall treat all workers, including volunteer workers, temporary
workers, and anyone else performing activities for or on its behalf, using the standard of
care established pursuant to Section (d) of this provision.
(g) An R2 electronics recycler shall designate a qualified employee or consultant to coordinate
its efforts to ensure worker health and safety. This individual shall be identified to all
employees and two-way communication shall be encouraged between employees and this
individual regarding potential hazards and how best to manage them.
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Exceptional Releases
(h) An R2 electronics recycler shall be able to at all times, implement the plan set forth in its
EHSMS for responding to and reporting exceptional releases, accidents, spills, fires,
explosions, and other out-of-the-ordinary events that pose risks to worker safety, public
health, or the environment.
*Risks posed by exposure to substances may arise from various situations – sometimes involving
substances that do not normally pose a risk to worker safety or the environment. Such substances
may include mercury, lead, beryllium, cadmium, PCBs, some phosphor compounds, certain
brominated flame retardants (i.e. polybrominated biphenyls, pentabrominated diphenyl ether, and
octabrominated diphenyl ether), silica dust, chlorinated or brominated dibenzodioxins and
dibenzofurans, and hexavalent chromium. Special attention should be given to potential lead and
cadmium exposures during the processing and handling of broken CRT glass, as well as where
lead solder is melted during chip recovery.
5. R2 Focus Materials
General Principle – An R2 electronics recycler shall manage – on site and during the selection of
downstream vendors – the R2 Focus Materials that pass through its facility or control in a
manner that ensures worker health and safety, public health, and the environment; and shall
require due diligence from downstream vendors to which it ships these materials.
R2 Practices:
Development and compliance with a FM Management Plan
(a) An R2 electronics recycler shall analyze and determine how the R2 Focus Materials (FMs)
that pass through its facility or control will be properly managed both on site and
throughout the Recycling Chain (and include this analysis and plan within the “FM
Management Plan” section of its EHSMS). The FM Management Plan shall define how
the recycler and its downstream vendors shall meet the requirements set forth in the rest of
this Provision 5.
Removal of FMs
(b) Prior to shredding, materials or energy recovery, incineration, or land disposal of
equipment or components, FMs (including toner and toner cartridges) shall be removed
using safe and effective mechanical processing or manual dismantling, with two
exceptions:
(1) Items containing mercury, if they are too small to safely remove at reasonable cost
and workers are protected from the risks posed by the mercury during and prior
processing any equipment containing it, and the equipment and components
containing such items are sent to materials recovery facilities that are suitably
licensed to receive, and that use technology designed to safely and effectively
manage, equipment or components containing such mercury-containing items.
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(2) CRTs, batteries, and circuit boards contained in equipment or items destined for
materials recovery need not be removed prior to shredding and/or materials recovery
if the processing occurs in facilities that are properly licensed to receive, and that
utilize technology designed to safely and effectively manage, equipment or items
containing these FMs.
Processing, Recovery, and Treatment of FMs
(c) An R2 electronics recycler shall send removed FMs to processing, recovery, or treatment
facilities that are suitably licensed to receive, and that employ technology designed to
safely and effectively manage, the FMs. This shall include:
(1) For equipment or components containing mercury – mercury retorting,
(2) For circuit boards – removal of batteries and mercury containing items and then
smelting for metals recovery, and
(3) For items containing PCBs – technology developed for PCB destruction and licensed
under the Toxic Substances Control Act and/or any other applicable law.
(4) Toner and toner cartridges, though not an FM, shall be recycled through the OEM or
other qualified toner recycling facility except where it is not economically feasible to
do so.
Energy Recovery, Incineration, and Land Disposal of FMs
(d) An R2 electronics recycler shall not utilize energy recovery, incineration, or land disposal
as a methodology for FMs or equipment and components containing FMs*. However, if
circumstances beyond the control of the R2 recycler affect its normal management of an
FM, it may consider these technologies to whatever extent allowed under applicable law.
Selection and Ongoing Due Diligence of Downstream Vendors for FMs
(e) For shipments of removed FMs, equipment and components containing FMs, an R2
electronics recycler shall determine downstream vendors that possess and conform to:
(1) The R2 recycler’s FM Management Plan (developed in accordance with and
including the requirements defined in Sections (b) - (d) above),
(2) A documented environmental, health, and safety management system,
(3) A roster of its environmental permits and copies of each,
(4) This Section (e) of Provision 5, thereby establishing that each vendor in the Recycling
Chain meets the requirements established in these subsections (1) – (7),
(5) Provision 6 (Reuse),
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(6) The exporting requirements set forth in Provision 3 (a) (2), and
(7) Provision 7 (Tracking Throughput).
(f) An R2 electronics recycler shall verify, through audits or other similarly effective means
that each downstream vendor in the Recycling Chain to which Section (e) applies continues
to meet the requirements of Section (e) for as long as it receives FMs directly or indirectly
from the R2 recycler.
*Unless applicable law requires the use of one of these technologies (e.g., thermal destruction of
PCBs)
6. Reusable Equipment and Components
General Principle – An R2 electronics recycler shall refurbish as necessary, properly test,
and\suitably package equipment and components going to reuse.
R2 Practices:
(a) An R2 electronics recycler shall not allow equipment or components to be sold or donated
for reuse if this is conflict with any commercial agreements.
(b) An R2 electronics recycler shall, with respect to equipment and items it ships downstream:
(1) Label and sort shipments in a manner sufficient to track throughput in conformity
with Provision 7.
(2) Handle and package shipments in accordance with Provision 12.
(c) An R2 electronics recycler, prior to shipping equipment and other items (except equipment
and items that are new and in their original packaging) that contain FMs and that will be
reused as is or repaired, refurbished, or remanufactured, shall:
(1) Apply effective testing methods to confirm that the Key Functions of the equipment
or components are in good working order, or
(2) Determine that the receiving facility is a certified R2 electronics recycler, or
(3) Confirm through a combination of contractual agreements, comprehensive materials
tracking, record keeping, and auditing that:
(A) The equipment or items meet the requirements of the recipient vendor, and
(B) The receiving vendor sells the equipment or items for reuse, with their Key
Functions working properly, and
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(C) The recipient vendor controls all residual FMs resulting from refurbishing
operations in a manner consistent with the R2 Practices.
(d) An R2 electronics recycler is not required to conform to Section (c) for shipments of less
than 15 items that either are going to a new vendor as a representative sample for purposes
of evaluation of whether to purchase larger quantities for refurbishment or that are being
sold with an equitable return policy to an end user. This Section (d) does not apply to
multiple sales or shipments within a given timeframe to the same entity.
(e) An R2 electronics recycler does not need to conform to the downstream requirements of
Provision 5 for shipments that satisfy the requirements of Section (c) or (d), or are new and
in their original packaging.
(f) An R2 electronics recycler does not need to conform to the exporting requirements of
Provision 3 (a) (2) for shipments that meet either the functionality requirement of Section
(c) (1) or Section (d), or are new and in their original packaging.
7. Tracking Throughput
General Principle – An R2 electronics recycler shall maintain business records sufficient to
demonstrate the material flow of equipment, components, and materials that pass through its
facility.
R2 Practices:
(a) An R2 electronics recycler shall maintain commercial contracts, bills of lading, or other
commercially accepted documents for all transfers of equipment, components, and
materials into and out of its facility, including brokering transactions for at least three
years.
8. Data Destruction
General Principle – An R2 electronics recycler shall employ generally accepted data destruction
procedures.
R2 Practices:
(a) An R2 electronics recycler shall sanitize, purge, degauss or destroy data on hard drives and
other data storage devices (the National Institute of Standards and Technology’s (NIST’s)
Guidelines for Media Sanitation – Special Publication 800-88 88 9 lists categories of
devices which need sanitization consideration), unless otherwise requested in writing by
the customer. The R2 electronics recycler shall comply to the data sanitization, purging, or
destruction practices described in the NIST Guidelines for Media Sanitation: Special
Publication 800-88* or another current generally-accepted standard, or be certified by a
recognized certification program.
(b) An R2 electronics recycler shall maintain procedures describing their data destruction
methods.
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(c) Employees involved in data destruction shall receive suitable training on a regular basis.
(d) Data destruction processes shall be reviewed and validated at planned intervals by an
independent party.
*See - http://csrc.nist.gov/publications/nistpubs/800-88/NISTSP800-88_rev1.pdf
9. Storage
General Principle – An R2 electronics recycler shall store items and materials that may result in
risk to worker health or safety or the environment if inappropriately stored, and equipment and
components going to reuse, in a suitable manner.
(a) An R2 electronics recycler shall store items removed in accordance with Provision 5, and
equipment and items destined for reuse, in a manner that:
(1) Protects them from adverse environmental conditions and floods and, as warranted,
includes a containment system, and
(2) Prohibits unauthorized entrance, and
(3) Is in clearly labeled containers, bins and/or storage areas.
10. Facility Security
General Principle – An R2 electronics recycler shall employ facility security measures suitable
for the equipment they handle and customers they serve.
R2 Practices:
(a) An R2 electronics recycler shall maintain a security program that controls access to all or
parts of the facility in a manner and to a degree appropriate for the type of equipment
handled and the needs of the customers served.
11. Insurance, Closure Plan, and Financial Responsibility
General Principle – An R2 electronics recycler shall possess insurance that is adequate to cover
the potential risks and liabilities associated with the scope of work performed and size of the
company’s operations, and shall have necessary legal and financial assurances in place for the
proper closure of its facilities.
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R2 Practices:
(a) An R2 electronics recycler shall possess suitable Comprehensive or Commercial General
Liability Insurance including coverage for bodily injury, property damage, pollutant
releases, accidents and other emergencies.
(b) An R2 electronics recycler shall determine and keep current a written plan and a sufficient
financial instrument that assures proper closure of the facility and protects against
abandonment of any electronics recycling products, components, or materials.
12. Transport
General Principle – An R2 electronics recycler shall transport all equipment, components, and
materials using vendors that possess the necessary regulatory authorizations and in a manner
protective of public health and the environment.
R2 Practices:
(a) An R2 electronics recycler ensures that all equipment, components, and materials to be
transported are packaged appropriately to mitigate the risk they could pose during
transportation to public health or the environment and the level of care warranted by their
intended use.
(b) An R2 electronics recycler obtains documented evidence or a third-party certification
indicating that their transporters possess all the necessary regulatory authorizations and
have had no significant violations of legal requirements during the past 3 years.
13. Record Keeping
General Principle – An R2 electronics recycler shall maintain documents necessary for an
auditor to assess its conformity to the requirements of this standard.
R2 Practices:
(a) An R2 electronics recycler shall maintain applicable records in a single location to show
conformity to each requirement of this standard.
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PART III –
RECYCLING INDUSTRY OPERATING STANDARD (RIOS)
Introduction to RIOS
The intent of the Recycling Industry Operating Standard (RIOS) is to establish a common
standard that integrates the benefits of ISO 9001:2008 (Quality Management System), ISO
14001:2008 (Environmental Management System) and BS/OHSAS 18001:2007 (Occupational
Health and Safety Management System) requirements combined in one Quality, Environmental,
Health and Safety (QEH&S) management system. The Institute of Scrap Recycling Industries,
Inc. (ISRI) recognized the benefits of ISO 9001, ISO 14001 and BS/OHSAS 18001 and decided
to combine all of the pertinent requirements into one common standard that affords organizations
the opportunity to realize the benefits of all of the standards under one scope of registration.
The RIOS Standard is independent of yet complimentary to the Responsible Recycling Standard
(R-2). While the two standards have many similarities and common requirements, separate
registrations are required. RIOS is recognized by the general recycling industry. R-2 is
recognized by recyclers of electronic products and is endorsed by the EPA.
Third party certification plays a critical role towards ensuring sustainable recycling. Perry
Johnson Consulting, Inc. provides consulting services intended to ensure that organizations
wishing to achieve RIOS certification are provided with the necessary guidance to assist in
successful registration to meet the requirements of the RIOS Standard outlined below.
ISRI’s commitment: e-recycling must be done right anywhere and everywhere in the world.
Institute of Scrap Recycling Industries (ISRI)
ISRI is opposed to “sham recycling” and illegal exports; places a strong emphasis on compliance
with both applicable laws and regulations locally and globally. ISRI is committed to ensuring e-
recycling adheres to standardized requirements everywhere in the world.
ISRI has adopted an export policy that is:
• Socially responsible,
• Protects worker health and safety, and
• Ensures environmentally friendly practices on a global scale.
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Benefits of RIOS
RIOS certification has a positive impact on organizational compliance, consumer and community
confidence and profitability. RIOS helps organizations to:
• Monitor, measure and improve product quality, thereby enhancing customer satisfaction,
• Comply with applicable environmental requirements by decreasing environmental risks and
managing costs,
• Improve process performance to ensure the provision of a safe and healthy work environment
at a reduced cost,
• Streamline processes to enhance efficiency and profitability,
• Motivate employees through participation by determining and meeting goals and objectives,
increasing productivity; and
• Promote the organization and enhance its reputation.
RIOS membership is comprised of organizations that perform scrap recycling activities.
Member companies are required to pay an initial materials fee and an annual maintenance fee per
enrolled facility. ISRI members are eligible for discounted fees. Recycling companies that are
not ISRI members are eligible to become RIOS members.
It is possible for organizations to obtain independent third-party certification by registrars
accredited by the ANSI-ASQ National Accreditation Board (ANAB). RIOS certification is more
applicable and cost effective than maintaining certification to several different standards.
RIOS is based on a "Plan-Do-Check-Act" philosophy to support continual improvement. RIOS
outlines the basic elements of the integrated QEH&S management system in six short sections:
1. General Requirements,
2. Policy,
3. Planning,
4. Implementation,
5. Checking and Corrective Action, and
6. Management Review.
The Need for RIOS
Before the inception of RIOS, there were no industry specific management system standards to
address comprehensive QEH&S management. ISRI recognized the value in developing an
integrated QEH&S management system standard for the scrap recycling industry. The ISRI
Services Corporation (ISC) was established to develop and administer the RIOS Program and
complimentary RIOS Implementation Guide.
RIOS members are authorized to use the RIOS Logo in accordance with the current version of
the RIOS Logo Usage Rules.
RIOS certification is based on a three-year cycle consisting of annual surveillance audits for the
first two years and a recertification audit at the end of the third year.
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After the release of The Responsible Recycling (R2) Practices for Use in Accredited Certification
Programs for Electronics Recyclers, in 2008, ISRI developed the R2/RIOS Certified Electronics
Recycler Program as to establish requirements for recycling electronics responsibly.
ISRI recognized the cohesive nature of R2 and RIOS and then combined them into a powerful
management system framework for electronics recyclers.
RIOS Certification
The time necessary to achieve RIOS certification varies from one organization to another
depending on the level of commitment, resources and competencies dedicated to
implementation.
RIOS certification requires RIOS membership. RIOS members are provided with a free copy of
the RIOS Standard.
To achieve RIOS certification, organizations must meet the following requirements:
• Determine, implement and maintain a QEHS management system in accordance with the
requirements of R2 and RIOS.
• Maintain the management system for a sufficient period of time necessary to accumulate
records of conformance to enable an audit team to verify the effectiveness of the EHSMS.
• Schedule an initial certification audit to be conducted by an ANAB-accredited R2/RIOS
Certification Body a few months before you intend to begin the certification process.
• Stage 1 audit (Readiness Review) – This is an audit conducted by the registrar to determine
the extent to which an organization is ready to proceed forward towards formal certification.
• Stage 2 audit – This audit is conducted to determine the extent to which an organization
meets the actual requirements of the standard and other applicable legal or other
requirements to which the organization subscribes.
• Any identified nonconformances have to be resolved by the organization and approved by
the certification body prior to granting full certification.
• R2/RIOS certification granted.
The RIOS Community is maintained on a secure area of ISRI’s website. RIOS members are
granted permission to download RIOS documents, share information, and ask questions. The
RIOS Community is accessible to authorized personnel of RIOS member companies.
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R2/RIOS Program – combines the benefits of RIOS and R2 and:
• Ensures compliance with applicable laws, including laws enacted by countries that have
signed/ratified Basel Convention,
• R2 prohibits exports except where legal and only under certain conditions required to protect
the environment and workers,
• Provides for strict management of focus materials from the time of receipt through final
disposition,
• Requires downstream due diligence,
• Combines, quality, environment and health and safety requirements.
Trends relating to Quality, EHS
The US scrap industry is committed to delivering high quality scrap in suitable volumes for
customers in an environmentally responsible manner.
• Technological developments have improved the quality of scrap over the last many years.
• Improvements in data-sanitization and various separation technologies and shredding have
contributed to enhanced data security.
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RECYCLING INDUSTRY OPERATING STANDARD (RIOS)
SECTION 1: GENERAL REQUIREMENTS
1.1 Scope and Application
ISRI Services Corporation’s (ISC) Recycling Industry Operating Standard (RIOS) has been
developed to establish a framework within which the recycling industry can control and improve
its quality, environmental, and health & safety (QEH&S) performance. ISC recognizes the
importance of sound management practices and the positive impact they have upon these areas of
concern. RIOS provides the scrap processing recycling industry with a structured approach for
implementation of management systems concerned with these issues. The management system
developed by RIOS member companies shall be documented and maintained and shall include a
description of the scope, core elements of the system including their sequence and interactions,
and provide direction to related documentation.
1.2 QEH&S Infrastructure
RIOS member companies shall provide necessary resources for the effective operation of the
QEH&S management system.
1.2.1 Management Structure
Top management shall define QEH&S roles and responsibilities. Roles and responsibilities shall
be documented.
Top management shall appoint (a) QEH&S management representative(s) who is (are)
responsible for:
• Ensuring the QEH&S management system is established, implemented and maintained in
order to meet RIOS requirements, and
• Reporting to top management on the performance of the QEH&S management system.
Top management shall designate a member of top management for ensuring that health and
safety are properly addressed and managed within the system.
1.2.2 Resources and Facilities
Top management shall ensure the necessary resources (including personnel and financial
resources) and infrastructure (including equipment and technology) for the effective operation of
the QEH&S management system.
1.2.3 Document and Recordkeeping Controls
RIOS member companies shall establish documented procedures to control all documents and
records required by the QEH&S management system.
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Procedures shall be implemented to ensure that documents are:
• Established and maintained,
• Subject to approval prior to use,
• Reviewed, revised, and amended as necessary, with changes identified,
• Current and accessible at points of use,
• Suitably identifiable, legible, dated with revision dates,
• Removed from use after they become obsolete and where retained for any purpose, clearly
identified as obsolete, and
• External documents are identified and their distribution controlled.
Procedures shall be established to ensure that records are documented and maintained, are
legible, identifiable and traceable to the relevant processes and are readily retrievable and stored
in a manner that protects them from damage or loss.
Record retention times shall be documented.
SECTION 2: POLICY
RIOS member companies’ top management shall establish (a) documented policy(ies) for
QEH&S. Top management shall ensure that the policy(ies) is (are) implemented.
Top management shall ensure that the policy(ies):
a) Is (are) appropriate to the scope of activities performed and potential environmental impacts
and health and safety risks,
b) Include(s) a commitment to comply with all relevant EH&S legal, customer and product
requirements, industry guidelines relevant to RIOS member company industries, and any
other QEH&S commitments made by the RIOS member company,
c) Include(s) a commitment to continual improvement,
d) Includes a commitment to preventing workplace injuries,
e) Provide(s) a mechanism for establishing QEH&S goals,
f) Demonstrate(s) top management’s commitment to customer satisfaction,
g) Include(s) a commitment to preventing pollution,
h) Is (are) communicated to and understood throughout the organization,
i) Is (are) made available to* the public, suppliers, customers, contractors and other interested
parties, and
j) Is (are) reviewed and revised, as necessary and appropriate.
RIOS member companies seeking certification to ISO 14001 requirements will need to extend
this requirement to ensure the environmental portion of the policy is communicated to all
personnel working on their behalf.
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SECTION 3: PLANNING
3.1 Identifying the QEH&S Footprint
RIOS member companies shall identify and document their QEH&S footprint to enable them to
set goals and implement suitable controls and monitoring consistent with their policy(ies). This
footprint shall be kept current. The footprint shall include:
3.1.1 Important Environmental Impacts and Health & Safety Risks*
Participating organizations shall establish (a) process(es) to identify the actual and potential
environmental impacts and health & safety risks of their activities, products, and services, giving
consideration to routine and non-routine activities (including emergencies). RIOS member
companies shall include activities, products and services they perform or provide and those that
are performed on their behalf or provided to them by contractors and suppliers.
RIOS member companies shall establish processes to determine and identify those
environmental impacts and health & safety risks that are most relevant to their operations.
3.1.2 Legal, Product, and Other Relevant Requirements
RIOS member companies shall establish (a) process(es) to identify and have access to applicable
legal, product and customer requirements, and other QEH&S requirements associated with other
requirements to which they subscribe.
*RIOS member companies seeking certification to ISO 14001 and/or the OHSAS 18001 will
need to expand this commitment to include the identification of environmental aspects that cause
environmental impacts and health & safety hazards that cause health & safety risks. The
Standards should be consulted for additional information.
3.2 Improvement Planning
In order to achieve QEH&S improvement, top management shall establish documented QEH&S
goals.
RIOS member companies shall give consideration to their QEH&S policy(ies) and QEH&S
footprint when setting goals. Goals may be applicable to the entire RIOS member company or
may apply to a particular function or responsibility.
RIOS member companies shall give consideration to technological options, financial, operational
and business requirements, and the views of interested parties when setting goals.
QEH&S goals shall be supported by designated responsibilities and time frames for
achievement.
Goals shall be measurable and quantitative where appropriate, and revised as necessary when
changes occur within the organization.
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SECTION 4: IMPLEMENTATION
4.1 Training
RIOS member companies shall ensure that personnel with responsibility for work activities that
can affect quality performance, have important environmental impacts, or have important health
& safety risks are competent based upon education, training, skills and/or experience and are
aware of their role within the QEH&S management system.
RIOS member companies shall establish processes to:
a) Determine QEH&S competency requirements and identify and provide training to enhance
competency taking into consideration different levels of responsibility, ability, literacy and
required work activities, and
b) Determine awareness training requirements QEH&S related to the management system and
identify and implement awareness training to ensure employee awareness of:
• Their roles and responsibilities in relation to the QEH&S management system,
• The manner in which they contribute to the achievement of the policy and QEH&S goals,
• The importance of conforming to (the) QEH&S policy(ies), processes, and procedures,
• Relevant environmental impacts and health & safety risks associated with the scope of
work they perform,
• The potential consequences of departing from QEH&S operating procedures, processes,
and requirements, and
• The benefits of personal improvement to quality, environment, and health & safety
performance.
RIOS member companies shall ensure any training provided is effective.
Records of education, training, skills and experience shall be maintained.
4.2 Communication
Top management shall ensure that communication processes take place within the company and
with customers and external interested parties.
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4.2.1 Internal Communication*
Internal communication processes shall include communications regarding:
• The structure of the QEH&S management system,
• Relevant environmental impacts and health & safety risks and related environmental and
health & safety information,
• Effectiveness of the management system, and
• The importance of meeting customer, legal and other requirements.
Provisions for employee feedback and consultation shall be included in health & safety
communication processes.
*RIOS member companies seeking certification to the ISO 14001 will need to extend this effort
to include the communication of environmental aspects. The Standard should be consulted for
additional guidance.
4.2.2 Customer Communication
Customer communication processes shall include communications related to:
• Product information,
• Customer inquiries, contracts, and order handling, including changes,
• Customer feedback, including complaints, and
• Assessments of customer perception.
4.2.3 Supplier Communication
Supplier communication processes shall include communications related to QEH&S
requirements. This shall include communicating purchase requirements to suppliers prior to
purchase.
4.2.4 Contractor Communication
Contractor communication processes shall include communications related to QEH&S
requirements.
4.2.5 Interested Party Communication*
External interested parties communication processes shall include requirements for receiving,
documenting, and responding to QEH&S related communications from external interested
parties.
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*RIOS member companies seeking certification to the ISO 14001 will need to extend this effort
to include a decision as to whether and how significant environmental aspects are to be
communicated. The Standard should be consulted for additional guidance.
4.3 Operational Controls
RIOS member companies shall give consideration to their operations and activities associated
with their QEH&S footprint and goals and establish processes and documented procedures to
ensure they are performed in a controlled manner and that suitable production equipment is
available.
Documented procedures and work instructions shall be established where their absence might
lead to a deviation from the QEH&S policy or goals. Procedures shall define the operating
criteria.
4.3.1 Customers
RIOS member companies shall establish requirements, processes and written procedures
necessary for production and distribution to ensure customer and product requirements and goals
are met and that consuming facilities are authorized to receive product. This shall include
ensuring product traceability, control of customer property, and shipping and delivery
requirements when this is the responsibility of RIOS member companies.
4.3.2 Suppliers
Participating organizations shall establish requirements, processes and documented procedures to
ensure source control of raw materials. This shall include processes to qualify and select
suppliers and ensure raw materials received from suppliers meet requirements. Records shall be
maintained.
4.3.3 Contractors
RIOS member companies shall establish requirements, processes, and written procedures
necessary to ensure contractors comply with QEH&S management system requirements.
4.4 Emergency Preparedness
RIOS member companies shall determine and implement processes to identify the potential for
and respond to incidents, accidents and emergency situations. These processes shall include the
prevention and mitigation of adverse environmental impacts and injuries and illnesses that may
be associated with them. The RIOS member company shall test these processes to whatever
extent necessary on a periodic basis. Prior to tests, incidents, accidents or emergency situations,
the company shall review and where necessary, revise its emergency preparedness and response
processes as required in 5.2 Nonconformance and Corrective and Preventive Action.
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SECTION 5: CHECKING AND CORRECTIVE ACTION
5.1 Monitoring and Measurement
Participating organizations shall establish processes to monitor, measure, validate, and record
characteristics of their operations that are vital to ensuring effective QEH&S performance,
achievement of goals, and product conformity to product requirements. This shall include
monitoring the management system and supporting goals. Measures may be quantitative and
qualitative. Monitoring data shall be analyzed to provide evidence of the effectiveness of the
management system and assess continual improvement.
5.1.1 Supplier Qualification and Verification of Raw Materials
RIOS member companies shall establish processes to verify raw materials to ensure source
control. Verification results shall be given consideration during supplier qualification and
selection.
5.1.2 EH&S Compliance
RIOS member companies shall determine and implement processes to monitor compliance to
applicable EH&S legal and other requirements to which the RIOS member company subscribes.
5.1.3 Maintenance and Calibration of Monitoring Equipment
RIOS member companies shall determine, maintain and ensure the necessary QEH&S
monitoring and measurement equipment is calibrated to ensure it functions properly.
Maintenance and calibration records shall be maintained.
5.2 Nonconformance and Corrective and Preventive Action
RIOS member companies shall establish documented procedures to address and eliminate the
causes of nonconformances and potential nonconformances. The process shall:
• Assign responsibilities,
• Ensure cause analysis is performed,
• Ensure actions to address nonconformance and prevent recurrence that are appropriate to the
affects of the nonconformance, and
• Include a review of corrective and preventive actions for effectiveness.
Records shall be maintained of nonconformances and preventive and corrective actions.
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5.2.1 Control of Nonconforming Product
RIOS member companies shall ensure that product, which does not conform to product
requirements, is identified and segregated to prevent its unintended use or delivery.
Nonconforming product may be reworked, released to the customer with concessions or used for
other purposes. Nonconforming product shall be identified and any actions taken recorded.
5.3 QEH&S Management System Audits
RIOS member companies shall establish written (a) procedure(s) to periodically evaluate:
• The QEH&S management system’s conformance to RIOS; and
• The suitable implementation and maintenance of the QEH&S management system.
The procedure(s) shall define the audit scope, considering the status and importance of QEH&S
processes and results from previous audits, schedule, responsibilities, and reporting of results.
Auditors shall not audit their own work.
SECTION 6: MANAGEMENT REVIEW
Top management shall review the QEH&S management system annually at minimum, to ensure
its adequacy and effectiveness. Records of management review shall be maintained.
Input to management review shall include:
• Audit results,
• Feedback from customers and other interested parties,
• Progress towards goals,
• Status of preventive and corrective actions,
• Follow-up actions from previous management reviews,
• Changes that could affect the QEH&S management system, and
• Recommendations for improvement.
Management review outputs shall include:
• Decisions and actions related to the future direction of the QEH&S management system such
as changes to the policy and goals,
• Resource needs, and
• Improvements to products.
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PART IV – RoHS and REACH
Restriction of Hazardous Substances Directive (RoHS)
The directive on the restriction of the use of hazardous substances in electrical and electronic
equipment 2002/95/EC (commonly referred to as the Restriction of Hazardous Substances
Directive or RoHS) was adopted in February 2003 by the European Union. The RoHS directive
took effect on 1 July 2006, and is required to be enacted as law in member states within the
European Union. RoHS, sometimes known as the lead-free directive restricts the use of six
hazardous materials in the manufacture of electronics and electrical equipment. The RoHS
directive is aligned with the Waste Electrical and Electronic Equipment Directive (WEEE)
2002/96/EC that defines requirements for the collection, recycling and recovery targets for
electrical products. The RoHS directive is part of a legislative action to address challenges
represented by of substantial quantities of toxic ewaste.
Each European Union member state is required to adopt enforcement and implementation
policies referencing the RoHS directive for guidance. RoHS imposes restrictions on the use of
the following six substances:
1. Lead (Pb)
2. Mercury (Hg)
3. Cadmium (Cd)
4. Hexavalent chromium (Cr6+)
5. Polybrominated biphenyls (PBB)
6. Polybrominated diphenyl ether (PBDE)
PBB and PBDE are flame retardants used in many types of plastics. Hexavalent chromium is
utilized in various chrome plating processes. Maximum permitted concentrations and guidelines
are provided within the directive for determining quantities of hazardous materials within
different types of electronics and electronic products.
The European Commission changes to the RoHS directive.
Batteries are not covered under RoHS. The European Commission's Battery Directive originally
released in 1991 and revised in 2003, which will be official when submitted to and published in
the EU's Official Journal. The initial release of the Battery Directive addressed possible trade
barriers stemming from ambiguous requirements implemented by various European member
states. The new directive more explicitly defines requirements for protecting the environment
from the negative effects of waste streams associated with battery disposal. It also contains
requirements for additional recycling of industrial, automotive, and consumer batteries. It also
sets threshold limits for mercury and cadmium to batteries. Additional restrictions are placed on
lead, lead-acid, nickel and nickel-cadmium in batteries. There are additional requirements for
marking batteries with symbols describing metal content and recycling collection information.
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The directive applies to equipment defined within the WEEE directive. The following categories
apply:
1. Large household appliances,
2. Small household appliances,
3. IT & Telecommunications equipment,
4. Consumer equipment,
5. Lighting equipment – including light bulbs,
6. Electronic and electrical tools,
7. Toys, leisure, and sports equipment,
8. Medical devices (exemption removed in July, 2011),
9. Monitoring and control instruments (exemption removed in July, 2011),
10. Automatic dispensers,
11. Semiconductor devices.
Examples of products or components containing restricted substances include:
Leaded components:
• Paints and pigments,
• PVC cables,
• Solders,
• Printed circuit boards and related products,
• Leaded Glass from televisions and computers – Cathode Ray Tubes (CRTs),
• Metal parts,
• Lamps and bulbs, and
• Batteries.
Cadmium is found in many products and materials including batteries, photocells and plastic
pigmentation.
Mercury is used in lighting and various types of switches.
Hexavalent chromium is used for metal finishing.
Polybrominated biphenyls and diphenyl Ethers/Oxides are used as flame retardants in plastic
products.
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Hazardous Materials and Electronic Waste
RoHS was developed to reduce the presence of hazardous materials used in electronics and
electronic products to mitigate the impact of electronics waste. Electronics waste often ends up
in landfills in undeveloped countries.
American electronics are often “recycled” in undeveloped African nations or other parts of the
world where environmental and safety practices are minimal or nonexistent. Workers, young
and old experience adverse health affects due to exposure to heavy metals. Many of these same
heavy metals are returning to the U.S. in contaminated products.
RoHS Applicability
In addition to challenges related to the proper disposal of used or end-of-life electronics
products, RoHS gives additional consideration to the effects of long term exposure to various
materials and related impacts on human health. The EPA has conducted Life Cycle Assessments
(LCAs) on various materials to determine the extent to which they adversely affect the
environment as well as human health and safety.
Various types of items are excluded from RoHS requirements giving consideration to costs,
benefits and risks associated with their use. Such items include solar panels, some medical
devices (category 8) and some measuring equipment (category 9). The EU realizes that many of
these products are produced in small quantities and possess an extended life span. Many of these
products are used in critical applications where their failure can be adverse or catastrophic.
The EU has established a temporary moratorium on RoHS enforcement for Category 8 and 9
products.
With few exemptions, RoHS covers most types of electrical equipment including some medical
devices and monitoring and control equipment which have been previously exempted due to
various constraints. Exemptions to product from categories 8 and 9 will be gradually phased out
over time.
Labeling
RoHS does not imply labeling requirements. Many manufacturers have developed compliance
marks to reduce confusion. Visual indicators include "RoHS compliant" and other similar labels.
Other standards
RoHS is not the only environmental standard governing electronics. Various industries are
developing their own standards the include requirements that are far more stringent than those
required for compliance purposes to ensure that requirements are met or exceeded for all cities,
states and countries.
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Challenges
The drawbacks associated with RoHS compliance include adverse effects on overall product
quality and the cost of compliance. RoHS also comes under fire for restricting lead and
cadmium in electronic products and components but does not address other more common
applications.
RoHS mandates the use of lead-free solder giving rise to concerns about the long-term reliability
of electronic equipment and components, especially in equipment used for critical operations.
Some of the critical issues resulting from the use of "lead-free" solder includes issues, such as:
1. Warping or delamination of circuit boards,
2. Damage to internal features on circuit boards,
3. Potential “Tin Whisker” growth, and
4. Added sensitivity to moisture.
Health Benefits
RoHS helps mitigate adverse effects to people and the environment in developing countries
where materials are sent for processing or disposal. The use of lead-free solders and other
products reduces health and environmental risks to workers in the electronics industry.
Reliability
Concerns related to product capability have not been realized as many of the innovations
necessary to meet RoHS requirements have resulted in the use of more user friendly and
effective materials. Innovations and technological advances continue to be the norm for printed
circuit boards and other electronics equipment and components.
Some exempt products achieve compliance. New alloys and technologies are currently exempt
from compliance to RoHS requirements until they are suitably assessed and characterized.
Registration, Evaluation, Authorization and Restriction of
Chemicals (REACH)
Registration, Evaluation, Authorization and Restriction of Chemicals (REACH) is a European
Union Regulation established on December 18, 2006. REACH addresses the production and use
of chemical substances, and their potential impacts on both human health and the environment.
REACH is 849 pages long and took seven years to pass. REACH is considered by many to be
the most complex legislation in the history of the European Union and maybe the most
important. REACH was developed to manage chemical substances and will have a far reaching
impact on industries all over the world.
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REACH became active on June 1, 2007. Phased implementation is scheduled over the next
decade.
When REACH becomes fully active, all organizations manufacturing or importing chemical
substances into the European Union in quantities of one ton or more per year will be required to
register these substances with the European Chemicals Agency (ECHA) in Helsinki, Finland.
Because REACH some of the substances REACH applies to are contained in articles, any
company importing goods or materials into Europe may be affected. The European Chemicals
Agency has determined three major deadlines for registering chemicals based on the quantity
manufactured or imported. REACH registration requirements are to be phased in progressively
over a given period of time. Thresholds and dates necessary for registration are as follows:
• December 1, 2010 – 1,000 tons,
• June 1, 2013 – 100 tons, and
• 1 June 1, 2018 – 1 ton.
Roughly 143,000 chemical substances were pre-registered in the European Union by the
December 1, 2008 deadline. Although pre-registration is not mandatory, it allows potential
registrants to register materials at their own pace. It is illegal to supply substances to the
European Union that have not been registered (known in REACH as “no data, no market”).
REACH requirements also address the continued use of chemical substances of very high
concern (SVHC) because of the potential for adverse impacts on human health or the
environment.
REACH applies to all chemicals imported or produced in the EU. The European Chemicals
Agency oversees the technical, scientific and administrative aspects of the REACH system.
To simplify the registration of the 143,000 substances and to limit vertebrate animal testing,
Substance Information Exchange Forums (SIEFs) are formed amongst organizations dealing
with the same or similar substances. This allows them to participate in a collaborative manner to
produce and maintain one registration dossier. This also creates new challenges because a SIEF
represents the cooperation between enumerative legal entities that must:
• Locate each other and start communicating in a manner that is open and honest,
• Share meaningful data and costs in a fair and transparent manner, and
• Participate in a democratic manner and achieve consensus to make complex decisions
necessary to complete a dossier with several thousand end points within a given time frame.
The European Commission provides free (IUCLID) software to businesses affected by REACH
which simplifies the process of accumulating, storing and submitting data for chemical
properties and effects. The submission of chemical data is a mandatory component of the
registration process. Chemical Safety Assessment (CSA) may be required and a Chemical
Safety Report (CSR) assuring the safe use any applicable substances has to be submitted with the
dossier. Dossier submission is accomplished using the web-based software REACH-IT.
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History of REACH
REACH represents a comprehensive revision of EU chemical policy. REACH passed the first
reading in the European Parliament on November 17, 2005. The Council of Ministers endorsed
REACH on December 13, 2005. The European Parliament approved REACH on December 13,
2006 and the Council of Ministers formally adopted it on December 18, 2006. There have been
various costs and benefits studies associated with REACH yielding a wide diversity of results.
REACH came into force on January 20, 2009, and will be fully implemented by 2015. A related
regulation – the CLP Regulation (for “Classification, Labeling, Packaging”) – utilizes the United
Nations Globally Harmonized System of Classification and Labeling of Chemicals (GHS) and
will supersede the previous Dangerous Substances Directive and Dangerous Preparations
Directive.
Philosophy
The legislation was proposed to address the protection of human health and the environment.
The use of potentially toxic substances is not desirable. REACH will ensure the use of certain of
substances will be phased out over time. Using potentially toxic substances can lead to excessive
exposure by direct or indirect means.
There was very little safety information available for 99 percent of the chemicals on the market
prior to 1981. Many substances have the potential to bioaccumulate in the human body, thus
reaching dangerous concentrations or react with each other, producing new substances with new
risks.
Controversy and Challenges
In addition to the potential costs and the complexity of the new law, REACH has also attracted
concerns because it is linked to animal testing. Animal tests on vertebrates are allowed only
once per one substance, and where suitable alternatives cannot be used. Companies that pay for
tests must sell the rights to the results for a "reasonable" price. There are concerns that gaining
access to necessary information may be very costly for potential registrants wishing to purchase
this information. While costs may go up, the number of animals required to support testing will
go down.
There are additional concerns that REACH could potentially diminish global trade and that some
"pre-registrants" may be consultants hoping for work while others may profit by charging
exorbitant rates for data in their possession.
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