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Export Regulations Think Tank: Certification for Paper Recyclers

By Rachel H. Pollack
Three recyclers of paper—plus other commodities—with facilities that have achieved RIOS, R2/RIOS, and ISO 9001 certification talk about their reasons for pursuing it, the time and costs involved, and whether the results justified their investment.

What would convince paper recyclers to certify their operations? That’s easy, says Johnny Gold, president of The Gold Group Recycling Consultants (Swampscott, Mass.). “If it could ease shipping and reduce rejections, both domestically and internationally; if mills would see it as a sign of quality when choosing suppliers; if it would result in [recyclers] securing a few more dollars per ton; if it would ensure their safe operations; and if it would work as a marketing tool to help them sell their product in good times and bad,” it would be an easy sell, he says. That’s a tall—and unrealistic—set of expectations, however.

The certifications available to recovered paper processing facilities are designed to ensure a company has systems in place to track and improve quality, ensure environmental compliance, and improve safety and health outcomes. They address elements a business can control or anticipate. They can’t guarantee high prices, smooth shipping, or material accepted with open arms.

A few recyclers that historically have specialized in recovered fiber have looked at the costs and benefits of certification and taken the plunge. Each of the certified companies interviewed for this article had a specific set of reasons for seeking certification. Some of these reasons—and their results—might resonate with other paper processors looking at improving their operations and preparing for this sector’s future.

Diverse Goals

Allan Co. certified its headquarters and affiliated processing facility in Baldwin Park, Calif., to the Recycling Industry Operating Standard™, or RIOS™, primarily to ease the renewal of its license for exporting scrap to China. Exports are about 70 percent of the company’s business, and China is its largest consuming country, says CEO Jason Young. “We’re self-inspected, and [RIOS] helps you maintain your self-inspection permit,” he explains. The facility handles paper, plastic, ferrous and nonferrous metal, electronics, and glass. ISRI developed RIOS, an integrated quality, environmental, health, and safety management system standard, for the recycling industry by combining elements of the ISO 9001 quality standard, ISO 14001 environmental compliance standard, and OHSAS 18001 standard for occupational health and safety management. It’s now managed by the Global Recycling Standards Organization (Washington, D.C.).

Certification also was something Allan Co.’s customers were starting to look for, Young says. It’s an assurance to suppliers who must conduct downstream due diligence for their own certification requirements, explains Kara Bouton, real estate manager for Allan Co., who led its RIOS certification process. “Buying materials from companies that have ISO certification, we can say, ‘We are meeting these standards that are in line with yours,’” she says.

For Far West Recycling (Portland, Ore.), diversification was its goal. Even though paper recycling is still 65 percent of its business—down from 98 percent in 2000—it’s rapidly expanding its metals and electronics processing operations. It went through the process of R2/RIOS certification for its Southeast Portland location, which handles those two commodity types. In electronics recycling, “a lot of companies need to know you’re certified in order to do business with you,” says Operations Manager Vinod Singh. This certification combines RIOS with the Responsible Recycling Practices for Use in Accredited Certification Programs, or R2, a standard that ISRI helped develop and that Sustainable Electronics Recycling International (Boulder, Colo.) administers. The effort was worthwhile, says CEO Keith Ristau. “We have started to get a lot more material since we were certified. Volume is probably up in electronics and certain metals 25 to 30 percent.”

Another reason Far West chose to get certified is “to walk the walk, shore up our practices, polish everything up,” Singh says. Especially when it comes to handling electronics focus materials, R2/RIOS is “a method to show we are doing the right thing.”

RIOS and R2/RIOS are not the only certifications available to paper recyclers. In 2009, when RIOS was just getting started, Great Lakes Recycling (Roseville, Mich.) achieved ISO 9001 certification of what was then its flagship facility in Roseville, says Sandy Rosen, GLR’s CEO. “We were seeking improved quality; to eliminate rejections, downgrades, and errors in paperwork; and [to implement] a whole system of step-by-step instructions of how to deal with everything,” Rosen says. The company recently sold that facility, which handled paper and metal scrap. It also has achieved R2 certification of a facility that processes electronics.

Put It in Writing

The greatest benefit—but also the greatest challenge—of certification was documenting operating procedures, these companies say. “We are a family-run company, and we have a lot of people with knowledge who have worked here for a lot of years,” says Young, who’s in the third generation of family leadership of the 52-year-old company. In most cases, he says, a process employees follow to do their jobs, something they had developed through the years, “wasn’t written anywhere. It was all in someone’s mind, or on their desk.” When the company had to document those processes and procedures, “none of it was impossible,” but it “had to be put together and formalized correctly,” he says. Some parts were easier than others, Bouton says. Because it operates in California, Allan Co.’s environmental compliance requirements were already quite high. The company could use existing documentation there and in its health and safety operations to meet the certification requirements.

Documentation “took time, energy, and a lot of effort, but it also was a good process,” Young says. “You look at every part of your business, see what its strengths and weaknesses are. You look at certain processes and ask, ‘Why were we doing it that way?’ We did a lot of soul-searching.” In the end, the company did not change much about how it operates, he says, but “we definitely looked at everything aggressively.”

Far West Recycling says its experience was similar. “Our philosophy is to do things the right way, which is what RIOS is all about, [so there were] not many things we weren’t already doing—we just needed to document them,” Ristau says. “That was nice to discover,” he adds.

“We were probably 80 percent or so of the way there” already, Singh estimates, and the certification process “helped us find weaknesses” in existing systems and correct them. Looking at Far West’s safety program, for example, “we were doing essentially everything we needed to do,” but perhaps we “needed to use a [different] form or verbalize it differently.”

Another example Ristau and Singh recall is that the company did not have a shutdown plan for situations such as bankruptcy. “You have to have a plan for it. How would you pay people, get rid of all your equipment? We never thought about that,” Ristau says. Such a plan is “part of knowing we are able to handle our material responsibly,” Singh points out. (It’s not just an academic exercise: An R2/RIOS-certified facility shut down its Portland operation last year.)

One benefit of this documentation, Singh says, is that “from top to bottom, everybody has a better understanding of practices and procedures. It avoids shortcutting [and] ensures people are following the right processes, from receiving to shipping. It provides improved clarity for everybody on what we’re supposed to be doing.”

Unlike RIOS and R2/RIOS, ISO 9001 certification addresses only quality, not environmental compliance or safety, but its implementation is similar. GLR had to come up with standard operating procedures for the facility it certified, and Rosen believes the process was beneficial. “We had the people doing the jobs write the SOPs and assigned them the corrective action when something went wrong. It gave them ownership of the process, and we got pretty good compliance,” he says. “There’s no question that getting organized and having everything systematic led to better results.”

The corrective-action process the facility implemented as part of its certification did not entirely eliminate quality issues, Rosen says. “If the procedure says, before putting a bale on the truck, the driver walks around the bale [and inspects it], theoretically we would never have a bale with a visible defect. But at the end of the day, the guy’s in a hurry,” and those steps get skipped, he says. Still, “for the most part, people followed it.”

Also, in his experience, at times the SOPs “removed some common sense” from the operation, Rosen says. When written correctly, they’re “designed to be followed to the letter,” he explains, but the risk is that people will follow them so rigidly that they don’t think at all. So, theoretically, if you had an accident and your procedures didn’t specify “call 911,” that call wouldn’t be made. “We’ve never experienced anything that extreme,” Rosen says, but “there have been many occasions where a little common sense would have brought a better result” than strictly following the SOP. Even so, the company “took the theory/philosophy [of ISO 9001] and applied it to all the facilities” the company then owned, Rosen says.

Time and Money

Recyclers often cite the costs and time commitment required for certification as a barrier. Allan Co. says its RIOS certification process took about one year; Far West Recycling’s R2/RIOS certification took closer to 18 months. Both Far West and Great Lakes Recycling say they stopped pursuing certification and later restarted. For GLR, the 2008 recession was the cause of the delay; Far West moved and consolidated part of its operations when a lease expired. The company waited until the move was complete to finish, Ristau says, then it had trouble scheduling the audit.

Views differ on whether to seek assistance from consultants. Far West used Perry Johnson Consulting (Southfield, Mich.) to manage the project with the part-time participation of Singh and two other employees. Singh estimates it was about 20 percent of his work for the 18-month period. “I suggest getting a consultant,” he says. “It helps to have someone familiar with the process, what to do, how you need to put the plan in place, what you need to improve.” GRSO and SERI offer “great programs, a lot of support, webinars, [and other] resources to do it yourself, but if you’re not a certification expert, if it’s not your job, it’s very helpful to have [a consultant].”

Allan Co., in contrast, did all the work in house. “We were encouraged by a lot of people to use a consultant,” Bouton says, but by doing it themselves, “we understood 100 percent what we were doing; we embraced it.” She does not think the process would have received the same buy-in if it had come across as criticism from someone outside the organization.

Bouton says she coordinated a group of about eight employees, one from each part of the company, who met twice a month for nearly a year. Each department documented its own procedures and then brought the documentation back to the group to review it. She estimates she spent six to eight hours a week on the project. Essential to its success “was the commitment by the leaders in the organization to come together and commit the time to talk about the issues,” she says. Certification “requires companywide buy-in” because one change to an operational procedure can affect many different people and departments. Without that buy-in, she says, “we couldn’t have gotten it done.”

The most intensely time-consuming aspect of certification was the initial audit, Bouton says. It consisted of two on-site visits, two and four days each, and one off-site review of paperwork and changes the company made to meet the requirements.

Maintaining certification, in contrast, requires minimal time and effort, these companies say. Singh estimates he spends perhaps an hour a month on it. Similarly, Bouton says maintenance requires “some more review of logs and meetings, but in general it hasn’t added a lot of extra time to our daily operations.” Annual audits to renew the certification have taken three days each, she says; after the third year, the company must undergo a full recertification like its initial one. Allan Co. has received its second full certification and plans to keep going, Young says.

One challenge Far West and Allan Co. both identified was communication with the auditing bodies. “Even though we were doing a lot of the right processes,” Singh says, part of the difficulty was “understanding the right certification-speak, if I didn’t understand the question, or translating some of the terminology” into language that made sense for their operations. If the auditing firms have not certified many recycling facilities, they might not understand some of the unique aspects of the recycling industry, Young says. For example, “customers in our business are on both sides”—they’re suppliers and buyers, he explains. “The customers that we buy from, [the auditors] wanted to call them vendors. They’re not vendors, they’re our customers. We have vendors, too—they sell us equipment,” not scrap.

What did the whole thing cost? The annual cost of membership in RIOS or R2/RIOS is $1,250 for ISRI members, $4,200 for nonmembers; add to that a copy of the standard ($125) as well as the cost of getting audited by a certification body. These companies estimate their total costs were between $10,000 and $20,000 (GLR), roughly $25,000 (Far West), or “tens of thousands” (Allan Co.).

Making the Certification Decision

These recyclers say certification has helped them in ways beyond their initial goals. “It has helped us as a marketing tool when we’re trying to get customers,” Bouton says. And in

the community, “when we go to present ourselves, recycling is not always loved. It helps

us to say, ‘Hey, we’ve worked hard to meet these standards.’”

Certification also helps with training and communications with employees, she says, especially the environment, health, and safety aspects. EHS was “in our training already, but this is an added layer that reinforces that.” Singh agrees. “The fact that people know there’s a system [creates] more responsibility, higher expectations,” he says.

That doesn’t mean certification is right for everyone. If someone asked him whether to do it, “I would ask them what they want it for,” Young says. “What is leading you to do this? For us it was a good process; I don’t know if it would be for everybody.” Rosen says he found the process of codifying the company’s policies and procedures more beneficial than the credential itself. But GLR has changed significantly over the past four or five years, he points out. It no longer owns materials recovery facilities, and it now handles more metal than paper. “You need to have the operation at a cruising altitude” to make certification worthwhile, he says. “In the next year or two, we might find ourselves at that cruising altitude and make that a priority for the management team.

“Personally, I’d love to see our people move toward RIOS [certification] at the metals facilities,” Rosen says, but he’s not going to force it on them. “You’ve got to have buy-in.”

Far West Recycling plans to certify more of its facilities in the future. “We want to have the best operations we can have—the safest, the most efficient. We want to do everything we can to be high performers,” Singh says. “Good practices spread quickly” from one facility to another, he says. “There will be a learning curve, definitely, but as far as being able to duplicate the standards, it should be easy to take what we’ve learned and move it over” to another facility. He believes R2/RIOS will help Far West manage and expand its operations properly. “Continual growth is the goal.”

Rachel H. Pollack is editor-in-chief of Scrap. This article originally appeared in Scrap magazine’s September/October 2016 issue. Reprinted with permission.

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