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Electronic Recyclers
Are You Up To Standards?


By now, most people are aware of the skyrocketing global e-waste problem and its effects on human health and the environment. The e-waste problem is bad… really bad, and, unfortunately unsafe recycling practices are mostly to blame. Not surprisingly, the Environmental Protection Agency (EPA) encourages all electronics recyclers to become certified through an accredited third-party auditor to ensure that they are meeting the industry standards for management and recycling of electronics.

We all know that safe recycling practices reduce the environmental and human health impacts of improper recycling, and conserve natural resources. But it’s also good for business. Safe recycling practices increase access to quality reusable and refurbished equipment to those who need them. Not to mention that it reduces energy consumption, thereby lowering costs. Thus, it can truly be said that certified recyclers are responsible recyclers.

But getting certified is hard work. Recyclers that wish to be certified must periodically prove they’re on their mettle. In other words, they must subject themselves to the occasional third-party audit to make sure they’re up to snuff. Currently there are two prevailing standards for electronics recyclers, e-Stewards® and Responsible Recycling Practices (R2). Both are designed to ensure responsible recycling of used electronics, and both are recommended by the EPA to maximize recycling and ensure safe management of materials by downstream handlers.

THE ANATOMY OF A CERTIFICATION AUDIT

Accredited third-party certification bodies conduct audits to determine if organizations meet the requirements of safe recycling standards. They employ professional auditors who can communicate clearly, understand the electronics recycling industry and can produce consistent, thorough audits.

Accreditation of certification bodies is gove rned by the ANSI -ASQ Nat iona l Accreditation Board (ANAB). In order to be granted accreditation by ANAB, a certification body must demonstrate continued compliance with international auditing standards for confidentiality, impartiality, independence, objectivity, audit planning and practices, auditor competence, response to complaints and other issues. This provides assurance to the end user that an accredited certification body will conduct their audits in a professional and unbiased manner.



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During Stage 2, on-site audits, auditors observe a recycler’s processes and activities, interview their personnel, and review procedures, documentation and records. They then compare their results to the requirements of the standard and determine whether or not a recycler should be certified. If an organization does not meet one or more of the requirements, the auditor will identify the nonconformance so the recycler can take action to fix the situation.

Auditors are trained to be open-minded. They are there to determine if a requirement has been met, not to dictate how requirements are to be implemented. Likewise, they are trained to focus on personnel and activities within the audit scope, and to minimizing disruption to operations during the audit.

BASICS OF CERTIFICATION

The first step in the certification process is the submission of the recycler’s company information to a certification body. This information should include the scope of the recycler’s business as well as the standard(s) to which they wish to be certified. A gap analysis can be performed to determine areas of noncompliance, but this is an optional step. After a recycler submits its information to the certification body, a brief Stage 1 audit is performed to determine their readiness for the in-depth Stage 2 audit. If they aren’t ready, there may be additional steps to take before continuing the process.

As noted previously, the Stage 2 audit involves a thorough examination of the recycler’s processes, record-keeping, etc. If at the completion of the Stage 2 audit the recycler demonstrates effective compliance, the certification body awards them with certification. After that, surveillance audits are conducted at least once a year to verify continued compliance. Every three years a recertification Stage 2 audit is conducted to ensure that the recycler is operating to standards as a whole.

After the recertification audit, the cycle continues with yearly surveillance audits and a recertification audit every three years. If nonconformities are found at any stage during this cycle, these must be addressed by the recycler and then verified by the certification body.

CERTIFICATION PRICING

o, how much does all of this cost? Well, the price of certification is based on the mandays of audit time plus any fees charged by the certification body or other parties. Audit time is based on:

  • Number of employees in the audit scope;
  • Number of locations in audit scope;
  • Maturity of the programs;
  • Complexity of audit scope; and
  • Risk and regulation level of the organization.
Since the complexity and risk of the recycler’s processes play a role in determining audit time, the more information an organization provides to the certification body at the beginning of the process, the better the quotation.

Processes that affect the complexity and risk (and thus, the cost) of a certification audit include:

  • Disassembly of electronic equipment;
  • Harvesting of working parts or components;
  • Repair or refurbishment of electronic equipment;
  • Sales of original or refurbished electronic equipment;
  • Shredding of computer hard drives or circuit boards;
  • Shredding of other electronic components (plastic, etc.);
  • Processing of any electronic components;
  • Processing of glass or batteries;
  • Metals reprocessing (furnaces).
There are also differences in pricing between the two standards. R2 does not have rules for audit time, and does not have usage fees, whereas e-Stewards® does have rules regarding audit time, and requires usage fees to be paid to the creators of the program, BAN. For both standards, audits are conducted as least annually as long as the certification is maintained.

We have provided some cost examples below, but it should be noted that these examples cover only the first two years of the certification program. It should be understood that there is an on-going investment required to maintain certification.

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A WORD ABOUT R2 PRICING

Since there are no specific rules for R2 audit time determination, certification bodies will have to determine the time requirements for audits to this standard by comparing it with other standards. Because of this, audit times are likely to vary by certification body. R2 audit time will likely be less than that needed for e-Stewards®, since there are fewer requirements to audit. For comparison, audit time will likely be greater than for ISO 14001 environmental management system audits.

E-STEWARDS® PRICING

Appendix B of the e-Stewards® standard provides these requirements for audit time:

  • Begin with the amount of time required for an ISO 14001 audit;
  • Add at least an additional 30% for e-Stewards®.
  • If the organization is already ISO 14001 certified, reduce time by 50%.

For the examples below we have used an audit day fee of $1,300 with no additional fees. These may or may not reflect the actual market average, as certification is competitive. This example does not include travel costs for auditors, which is charged by most certification bodies.

  • Example #1 – A small recycler, non-profit, which does primarily disassembly and sales, with less than $1 million in sales.

    First year - $4,150 ($3,900 to certification body, $250 to BAN).

    Second year - $1,550 ($1,300 to certification body, $250 to BAN).

  • Example #2 – A small recycler, primarily disassembly and sales, approximately $1.5 million in sales.

    First year - $6,500 ($5,200 to certification body, $1,300 to BAN).

    Second year - $3,250 ($1,950 to certification body, $1,300 to BAN).

  • Example #3 – A recycler with two locations, primarily disassembly, repair, and sales, approximately 10 million in sales.

    First year - $16,750 ($8,450 to certification body, $8,300 to BAN).

    Second year - $12,200 ($3,900 to certification body, $8,300 to BAN).

  • Example #4 – ISO 14001 certifier recycler, primarily disassembly and sales, approximately $7.5 million in sales.

    First Year - $10,600 ($5,200 to certification body, $5,400 to BAN).

    Second Year - $8,000 ($2,600 to certification body, $5,400 to BAN).



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    FINDING A CERTIFYING BODY

    Aside from price, it is also important for organizations to also consider other factors when selecting the standard to which they wish to be certified. There are some significant differences between the requirements of the two standards, as well as in the goals and proponents of the standards. Companies who wish to pursue certification to one or both of these standards can do so by contacting the accredited audit providers below.

    E-STEWARDS®:

    • AQA International, LLC
    • Orion Registrar, Inc.
    • SAI Global Certification Services Pty Ltd (trading as SAI Global)

    RESPONSIBLE RECYCLING PRACTICES (R2)

    • AQA International, LLC
    • Orion Registrar, Inc.
    • Perry Johnson Registrars, Inc.
    • SAI Global Certification Services Pty Ltd (trading as SAI Global)
    • Systems and Services Certification, a Division of SGS North America Inc.

    The list of accredited audit providers, complete with company details and contact information is available at http://anabdirectory.remoteauditor.com/.

    ABOUT THE AUTHORS

    Paul Burck is the President of Orion Registrar, Inc. Orion Registrar is an accredited certification body headquartered in the Denver metropolitan area. Orion has 10 other offices around the globe, and has issued approximately 6,000 certificates to clients in a wide range of industries. Orion’s clients range from one-person businesses to multinational organizations. Paul can be reached at This email address is being protected from spambots. You need JavaScript enabled to view it. or at 303-456-6010.

    Penny Ouellette is the Program Development Director for Orion Registrar, Inc. She can be reached at This email address is being protected from spambots. You need JavaScript enabled to view it. or at 303-645-4023. Additional information about Orion can be found at www.orion4value.com.

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