Webinar for Recyclers of Waste Electronic

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Webinar for Recyclers of Waste Electronic
Electrical Equipment

• Wednesday, August 20

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Welcome

• All webinar audience
• Expand view to full screen
• 3 arrows to open close webinar control panel
• Audience lines muted until Question Answer
• Use control panel for questions
• send confidential questions directly to OES (do
  not use webinar QA feature
• Slides to be sent to participants

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Todays Topics

• Program overview update
• Online registration application process
  demonstration
• end of life (EOL) primary recyclers
• Application reviewers process
• Primary downstream recycler audit process
• Next steps

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Program Update

• Ontario Electronic Stewardship (OES) is
  not-for-profit Industry funding organization
  (IFO) for Waste Electrical Electronic Equipment
  (WEEE)
• Plan for Phase 1 WEEE approved by Waste Diversion
  Ontario (WDO)
• submitted to Minister March 31, 2008
• Approved on July 10, 2008

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Program Update

• Program commencement April 1, 2009
• Phase 2 WEEE program plan development has begun
• Phase 2 plan due July 10, 2009
• CSR
• contracted by OES as program manager
• SGS Systems Services Certification
• auditing body under contract with OES to provide
  processor audit services

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Two Phases of Obligated Products

• Phase 1 includes
• televisions
• computer monitors
• desktop, laptop notebook computers including
  CPUs
• computer printers fax machines
• computer peripherals such as keyboards, mice

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Phase 2 WEEE

• Phase 2 Designated WEEE
• photocopiers
• PDA, handheld computers
• telephones, cell phones, modems
• audio playback recording systems
• tape, disk digital
• video playback recording systems
• tape, disk digital
• cameras
• tape, disk digital

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Future Webinars

• Allocation process for collected WEEE
• Application registration process for other OES
  service providers including
• reuse refurbishment
• transportation consolidation
• approved OES collectors
• To be addressed in future webinars
• schedule under development

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Recycler Registration Application Process
Demonstration

• Paul Flegg

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Recycler Registration Process

• Online process for completing registration
  application
• Prospective primary recyclers must register
  complete application requirements
• Applications forwarded to SGS for audit
• only when complete
• all required documentation has been uploaded to
  OES

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Registration Requirements

• Registration URL serves as single access to OES
  system
• Online registration required for
• primary EOL WEEE recyclers
• reuse/refurbishers under the program
• transportation consolidation
• approved OES collection sites
• municipal collection sites
• stewards
• Not yet complete to be covered in separate
  webinar

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Application Sections

• Basic registration includes
• declaration of services applicant would like to
  provide
• primary billing contact details
• facility location(s) details
• Recycler application
• Section 1 completed by primary recyclers
• Section 2 completed for downstream recyclers by
  the primary recycler
• Section 3 through 7 completed by primary for
  primary downstream recyclers-as applicable
• Section 8 completed by downstream smelting or
  heat treatment facilities

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System Demonstration
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System Tips

• Once registered, applicants can save
  information return to complete on their own
  timing
• Applicants required to attach copies of pertinent
  documents
• Only fully completed applications forwarded to
  SGS for next steps

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Next Steps

• Repeat of this demonstration in September
• Targeted launch for is mid-September
• Likely to be combined with other registration
  steps for
• reuse/refurbishment
• collection
• transportation/consolidation
• Webinars to be held for other service providers

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Recycler Audit Process Requirements

• Scott Malloy, SGS

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Role of SGS

• SGS Systems Services Certification
• auditing body under contract with OES to provide
  processor audit services
• conduct document on-site audits of primary
  downstream processors as required
• report to OES Board

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Recycling Vendor Qualification Program (RVQP)

• RVQP developed by electronics industry through
  Electronics Product Stewardship Canada (EPSC) to
  prevent illegal export unnecessary landfilling
  of WEEE
• The Program consists of 3 distinct components
• Electronics Recycling Standard (ERS)
• Guidance Document
• Audit Process

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Electronics Recycling Standard (ERS)

• Establishes basic criteria electronics recyclers
  must meet
• Incorporates suggestions from electronics
  manufacturers, environmental groups,
  electronics recyclers
• Goes beyond provisions of ISO 14001 addresses
  specific issues resulting from recycling
  electronics
• enhanced requirements for Environment, Health
  safety
• prohibits use of prison labour
• prohibits shipping material to developing/non-OECD
  countries
• reinforces downstream accountability of waste
• ERS is currently used in BC, SK, NS now
  included as part of approved OES program
• see Appendix 9a 9b of approved Plan
• please note slight revisions in Standard compared
  with other provincial programs

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Guidance Document

• Serve as educational document on key
  environmental, legal, health safety hazards
  associated with WEEE
• Intent is to provide guidance to
• recyclers looking to develop environmentally
  sound recycling processes
• environmental auditors with knowledge base for
  conducting assessments of electronics recyclers
• Document provides information on
• Material Separation
• Substances of Concern
• Health Safety Occupational Hygiene
• Transportation Export
• Smelting, Energy Recovery Disposal
• Environmental Management System
• Material Processing End Use Acceptability Table

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Electronics Processor Evaluation

• Evaluation process for OES approved processors
  consists of the following
• Electronics Processor Registration Application
  process
• Document Audit on All Information Presented for
  Primary Downstream Processors
• Primary Processor On-Site Audit
• Downstream Processor Document Audits
• Deficiency Closures
• Report to OES
• Recognition as OES Approved Processor

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Evaluation Stages for Electronics Processors

• Step 1 Processor interested in being approved
  by OES registers, completes submits Electronics
  Processor Application plus supporting
  documentation for review
• Step 2 OES reviews processor application
  supporting documentation for completeness
• Step 3 Completed applications forwarded to SGS
  to begin audit process
• Step 4 Document audit conducted on all
  identified processors reports submitted to each
  processor

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Evaluation Stages for Electronics Processors (2)

• Step 5 Based on results of each downstream
  processors document audit processes, SGS
  conducts on-site audits submits reports to each
  processor
• Step 6 Following closure of all deficiencies
  identified during audits, audit summary provided
  to OES
• Step 7 Primary Processor recognized as an OES
  approved processor

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Processor/Vendor Mapping
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Document Audit of Processors

• Conducted against requirements of Electronics
  Recycling Standard
• Conducted against information provided to OES by
  Primary Processor
• ¾ day
• Audit Checklist is key tool
• Onsite audit required for Assessment Factor of 15
  or more OR score of 5 for factors 6 or 7 (as
  per audit assessment process)
• OES has final call on whether on-site audit is
  required

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Processor Evaluation
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Onsite Assessment of Processors

• Conducted against requirements of Electronics
  Recycling Standard
• Dates arranged through Technical Project
  Coordinator or Account Coordinator
• Checklist Audit Plan sent in advance of audit
• Audit Report to be issued within 3 days
• Goal for follow-up response time is 3 days
• Records (to downstream processor OES)
• onsite Audit Report
• follow-up Audit Report
• Closure of issues usually do not require
  additional site visit

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Minor Deficiency

• Single observed lapse identified with respect to
  a process or procedure required as part of
  client's management system, or
• in judgment of auditor, deficiency does not
  represent an immediate hazard to environment,
  employees or organizations ability to meet
  intent of OES Recycling Standard
• e.g. (for documentation review)
• lack of documentation of fire drills
• lack of documentation of daily checks on fork
  lift trucks
• eye wash stations not inspected
• first aid kits not inspected
• preventative maintenance on equipment overdue

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Major Deficiency (1)

• Where nonconformity likely to result in an
  immediate hazard to environment or immediate risk
  with regard to human life e.g.
• organization fails to demonstrate that it has
  evaluated legal regulatory compliance that
  action has been taken in cases of non-compliance
  with relevant legislation regulations
• failure to report legal non-compliance to an
  enforcement authority where required
• absence of or total breakdown of a procedure
  required as part of the management system

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Major Deficiency (2)

• significant number of occurrences of minor
  non-conformities against a particular element of
  management system or within single department or
  activity
• inability to demonstrate regulatory compliance
• lack of evidence of emergency response
• lack of evidence of occupational health program
• lack of environmental worker safety measures
  for mechanical processing
• failure to demonstrate commitment of not sending
  to non-OECD non-EU countries unless it meets
  equivalent Ontario standard or
• failure to implement air emissions systems for
  monitoring (e.g. if using heat treatment)

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Conditional Approval

• Conditional Approval may be granted to the
  Facility by OES
• Conditional Approval lasts for 90 days
• Designed for processors with limited number of
  very minor issues so material is not held up

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Final Assessment Report

• Report will include
• mapping of downstream flow of materials,
  including a mass balance of the materials
• results of document audits, including any
  identified deficiencies the actions taken to
  address them
• results of onsite audits, including any
  identified deficiencies the actions taken to
  address them
• confirmation of compliance status of primary
  recycler sub-processors measured against the
  ERS at time of assessment
• audit reports to be included as appendices

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Common Issues/Findings During Audits

• SGS has conducted audits for 3 provincial
  programs has found the following common issues
• identifying complying with all applicable
  Environmental OHS Legislation
• process for communication, regulatory fines or
  orders
• handling hazardous materials in accordance with
  regulations
• implementing Emergency Response Plans (i.e.
  testing)
• process to complete a documented annual (at
  minimum) Risk Assessment for Worker Exposure to
  Toxic Substances
• inadequate material flows provided
• inadequate mass balancing provided

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What You Should Expect from OES/SGS

• Confidentiality
• OES program staff, SGS employees subcontractors
  have signed confidentiality agreements
• board receives high level results only
• document or On-Site Audit Reports only provided
  to audited facility OES, NOT the primary
  processor
• unless Primary Processor has requested specific
  downstream processor audit as part of process
  change application
• Reasonable response time to submitted information
• Assistance guidance along the way

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Next Steps

• Repeat of this demonstration in September
• Targeted launch is mid-September
• Likely to be combined with other registration
  steps for
• reuse/refurbishment
• collection
• transportation/consolidation
• Webinars to be held for other service provisions

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Questions

• Use Question Answer box on screen
• If question is of a confidential nature, please
  send tocustomerservice_at_ontarioelectronicstewards
  hip.ca
• to be addressed individually following webinar

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Thank you!