1. BEST PRACTICES FOR CONDUCTING AN ON-SITE RECYCLING VENDOR REVIEW www.asincorp.com 410-312-3535 Presented by: Marvin Howell, Analytical Services, Inc

2. E.O. 13423 REQUIREMENT “Use environmentally sound practices with respect to disposition of agency electronic equipment that has reached the end of its useful life.” “Use environmentally sound practices with respect to disposition of agency electronic equipment that has reached the end of its useful life.” E.O. Implementing Instructions further clarify that agencies must: E.O. Implementing Instructions further clarify that agencies must: “Use national standards, best management practices, or a national certification program for electronics recyclers.” “Use national standards, best management practices, or a national certification program for electronics recyclers.” “In the absence of these, agencies shall use EPA’s Guidelines for Materials Management for Plug-In To eCycling partners.” “In the absence of these, agencies shall use EPA’s Guidelines for Materials Management for Plug-In To eCycling partners.” “Each agency and its facilities shall choose either to become a partner in the Federal Electronics Challenge (FEC), or to implement an equivalent electronics stewardship program…” “Each agency and its facilities shall choose either to become a partner in the Federal Electronics Challenge (FEC), or to implement an equivalent electronics stewardship program…”

3. FEC: READ & UNICOR Federal agencies/facilities that opt to use READ (Recycling or Electronics and Asset Disposition) or UNICOR recycling services do not need to perform additional due diligence to ensure compliance with E.O. 13423. The U.S. Environmental Protection Agency (EPA) has already conducted due diligence on READ and UNICOR Federal agencies/facilities that opt to use READ (Recycling or Electronics and Asset Disposition) or UNICOR recycling services do not need to perform additional due diligence to ensure compliance with E.O. 13423. The U.S. Environmental Protection Agency (EPA) has already conducted due diligence on READ and UNICOR

4. REASONS SOME MAY NOT CHOOSE READ OR UNICOR READ or UNICOR use is encouraged, however some exceptions may exist: Facilities do not always exist within a reasonable distance Facilities do not always exist within a reasonable distance Must pay for READ pickup Must pay for READ pickup May have to package and deliver to UNICOR May have to package and deliver to UNICOR Only a one-person staff to do all of the end-of-life property duties Only a one-person staff to do all of the end-of-life property duties Another recycling vendor may pay your organization for recycled goods Another recycling vendor may pay your organization for recycled goods

5. LOCAL RECYCLER Federal agencies and facilities that choose not to use a READ contractor, UNICOR or an EPEAT-related manufacturer take-back program may choose and contract with a local recycler that meets their needs. Federal agencies and facilities that choose not to use a READ contractor, UNICOR or an EPEAT-related manufacturer take-back program may choose and contract with a local recycler that meets their needs. When selecting a different recycler, federal agencies and facilities must practice due diligence to ensure that the electronics recycler they select utilizes environmentally sound practices, in accordance with E.O. 13423 and its Implementing Instructions. When selecting a different recycler, federal agencies and facilities must practice due diligence to ensure that the electronics recycler they select utilizes environmentally sound practices, in accordance with E.O. 13423 and its Implementing Instructions.

6. A RECYCLING NIGHTMARE

7. AN ELECTRONICS REYCLING FACILITY

8. FEC CHECKLIST FOR ON-SITE REVIEWS OF ELECTRONICS RECYCLERS FEC provides a Checklist for use in conducting reviews of electronics recyclers FEC provides a Checklist for use in conducting reviews of electronics recyclers Questions on the Checklist are intended to generally cover the considerations required in EPA’s Plug-In To eCycling: Guidelines for Materials Management Questions on the Checklist are intended to generally cover the considerations required in EPA’s Plug-In To eCycling: Guidelines for Materials Management FEC encourages review of the Guidelines, prior to completing an on-site review (www.federalelectronicschallenge.net) FEC encourages review of the Guidelines, prior to completing an on-site review (www.federalelectronicschallenge.net)www.federalelectronicschallenge.net The Checklist provides questions you must consider in a review and ensures documentation of your review The Checklist provides questions you must consider in a review and ensures documentation of your review

9. BEST PRACTICES (BP) OVERVIEW Select a recycler to review Select a recycler to review Choose your review team Choose your review team Prepare your team Prepare your team Determine acceptability criteria Determine acceptability criteria Focus on the purpose of each Checklist component Focus on the purpose of each Checklist component Conduct an on-site review Conduct an on-site review Finalize the review Finalize the review

10. BP #1 SELECT A RECYLER TO REVIEW Good reputation and highly recommended by others Good reputation and highly recommended by others Picks-up and loads recycled goods Picks-up and loads recycled goods Pays for some items Pays for some items Can decrease the number of items going to landfill or percent of aspects recycled Can decrease the number of items going to landfill or percent of aspects recycled

11. BP #2 CHOOSE YOUR REVIEW TEAM Team of two to five persons is recommended Team of two to five persons is recommended Should be interested in, or have some responsibility for, recycling electronics Should be interested in, or have some responsibility for, recycling electronics Candidates are: Candidates are: Environmental Management System (EMS) Team Chief Environmental Management System (EMS) Team Chief Environmental, Health & Safety (EH&S) Manager, Environmental, Health & Safety (EH&S) Manager, Property staff (those responsible for end-of-life tracking) Property staff (those responsible for end-of-life tracking) EMS Team Members EMS Team Members

12. BP #3 PREPARE YOUR TEAM Step 1: Review the checklist Step 1: Review the checklist Step 2: Assign portions of the checklist for certain team members to focus Step 2: Assign portions of the checklist for certain team members to focus Step 3: Decide which findings would be acceptable to your organization Step 3: Decide which findings would be acceptable to your organization Step 4: Arrange a mutual date for review with the recycle vendor and review team Step 4: Arrange a mutual date for review with the recycle vendor and review team Step 5: Send checklist to recycler and have them fill out and return prior to visit Step 5: Send checklist to recycler and have them fill out and return prior to visit

13. BP #4 DETERMINE ACCEPTABILITY CRITERIA 1. Yes NoWithin 250 miles? 2. Yes No Recycles the kind of electronics we need to recycle? 3. Yes NoProvides a Certificate of Recycling? 4. Yes NoHas a Federal, State, or Local permit for recycling operations? 5. Yes NoInput versus output is within a reasonable range? 6. Yes NoPossesses an EPA number related to generation of hazardous waste? 7. Yes NoHas documented procedures and tracking system? 8. Yes NoIs site clean and orderly? 9. Yes NoAre safe employee work habits used on the site? 10. Yes NoDoes the facility ship to reputable recyclers? 11. Yes NoDoes recycler ship broken electronics overseas?

14. BP # 5 FOCUS ON THE PURPOSE OF EACH CHECKLIST COMPONENT Reviewer Information Reviewer Information General Facility Facts General Facility Facts Electronic Waste Input Electronic Waste Input Electronic Waste Processing Electronic Waste Processing Electronic Waste Output Electronic Waste Output Due Diligence Due Diligence Documentation and Records Documentation and Records Physical Examination Physical Examination Confidentiality Notice Confidentiality Notice

15. CHECKLIST REVIEWER & GENERAL FACILITY FACTS How long has the recycler been in business? How long has the recycler been in business? Has the facility changed ownership recently? Has the facility changed ownership recently? Compare the input of electronics with the output (via processing or resale): Compare the input of electronics with the output (via processing or resale): Are the majority of the incoming electronics processed or resold? Are the majority of the incoming electronics processed or resold? A difference between input and output of +/-10% is usually considered acceptable. A difference between input and output of +/-10% is usually considered acceptable. Anything larger may indicate the facility is sending a significant amount of the input electronics to landfills. Anything larger may indicate the facility is sending a significant amount of the input electronics to landfills. If there is cause for concern, you may wish to ask your point of contact for clarification. If there is cause for concern, you may wish to ask your point of contact for clarification.

16. CHECKLIST ELECTRONIC WASTE INPUT Types and sources of the electronics accepted Types and sources of the electronics accepted “Certificate of Recycling” provided? “Certificate of Recycling” provided? Usually the recycler’s own certification of the total weight of material received, date received, and acknowledgement that it was (or will be) processed “in accordance with all State and Federal regulations” Usually the recycler’s own certification of the total weight of material received, date received, and acknowledgement that it was (or will be) processed “in accordance with all State and Federal regulations” For record-keeping purposes, a Certificate of Recycling is essential For record-keeping purposes, a Certificate of Recycling is essential Availability of a certificate does not absolve the Federal agency/facility or recycler of environmental liability if mismanaged Availability of a certificate does not absolve the Federal agency/facility or recycler of environmental liability if mismanaged

17. CHECKLIST ELECTRONIC WASTE PROCESSING Does the facility strive to maximize reuse and refurbishment, and minimize incineration and landfilling, within the facility? Does the facility strive to maximize reuse and refurbishment, and minimize incineration and landfilling, within the facility? Used electronics are not necessarily hazardous waste. Used electronics are not necessarily hazardous waste. A facility may not need to be permitted or licensed to handle hazardous waste if the electronics they handle are not classified as hazardous waste. A facility may not need to be permitted or licensed to handle hazardous waste if the electronics they handle are not classified as hazardous waste. Please see EPA’s eCycling Regulations Web page: http://www.epa.gov/waste/conserve/materials/ecyclin g/rules.htm Please see EPA’s eCycling Regulations Web page: http://www.epa.gov/waste/conserve/materials/ecyclin g/rules.htm

18. INTERNAL COMPUTER PARTS Recyclers often disassemble certain computer components and separate them to maximize their resale value.

19. View of the various waste stream containers at an electronics recycling facility.

20. Hard Drive Hopper/Chipper

21. CHECKLIST ELECTRONIC WASTE OUTPUT Does the facility send output to recipients that maximize reuse and refurbishment, and minimize incineration and landfilling? Does the facility send output to recipients that maximize reuse and refurbishment, and minimize incineration and landfilling? Is equipment that is sent for reuse tested to ensure that it is working, or sent to a recipient that can reuse or refurbish non-working equipment? Is equipment that is sent for reuse tested to ensure that it is working, or sent to a recipient that can reuse or refurbish non-working equipment?

22. EQUIPMENT TESTING ROOM Equipment received is tested to determine if it is in working order and available for re-use. Equipment is either donated to a non-profit group or re-sold.

23. MONITOR STACKING Some recyclers don’t recycle all electronics components, but send on to another recycler. Here monitors are stacked and wrapped in accordance with recycler’s requirements. Customers are often charged fees for items like these that are passed to another recycler.

24. CHECKLIST - DUE DILIGENCE Incinerators and landfills Incinerators and landfills Exporters Exporters Recyclers of designated materials Recyclers of designated materials Downstream Downstream

25. DOWNSTREAM DUE DILIGENCE It is important that the facility understand and document the practices of downstream recipients, to ensure that recipients of electronics and components from their facility also practice environmentally sound reuse and recycling It is important that the facility understand and document the practices of downstream recipients, to ensure that recipients of electronics and components from their facility also practice environmentally sound reuse and recycling

26. CHECKLIST DOCUMENTATION & RECORDS Electronic recyclers who export, or use downstream vendors that export, specific electronic equipment outside the U.S should be able to supply you with information on the legality of the export. Electronic recyclers who export, or use downstream vendors that export, specific electronic equipment outside the U.S should be able to supply you with information on the legality of the export. Documentation is needed for equipment or materials that contain mercury, polychlorinated biphenyls (PCBs), batteries, CRT glass, or circuit boards. Documentation is needed for equipment or materials that contain mercury, polychlorinated biphenyls (PCBs), batteries, CRT glass, or circuit boards.

27. CHECKLIST DOCUMENTATION & RECORDS Note: EPA HAS NO CERTIFICATION PROCESS FOR RECYCLERS !! If the facility handles hazardous materials they should have an EPA ID number related to their generation of large or small quantities of hazardous waste. If the facility handles hazardous materials they should have an EPA ID number related to their generation of large or small quantities of hazardous waste. Recyclers may say they are “EPA permitted,” “EPA approved,” or “EPA certified,” however, the EPA has no permit, approval, or certification process verifying environmentally sound practices by electronics recyclers. Recyclers may say they are “EPA permitted,” “EPA approved,” or “EPA certified,” however, the EPA has no permit, approval, or certification process verifying environmentally sound practices by electronics recyclers. An EPA hazardous waste ID number is not a federal permit to recycle electronics, but may be indicative of due diligence related to hazardous waste disposal. An EPA hazardous waste ID number is not a federal permit to recycle electronics, but may be indicative of due diligence related to hazardous waste disposal.

28. BP #6 CONDUCT AN ON-SITE REVIEW CHECKLIST – PHYSICAL EXAMINATION Observe Observe Ask questions (utilize Checklist!) Ask questions (utilize Checklist!) Focus Focus Be polite Be polite Is the recycler responsible? Is the recycler responsible? Is the site clean, orderly, safe, and organized? Is the site clean, orderly, safe, and organized? Who receives the recycled goods and are they responsible? Who receives the recycled goods and are they responsible?

29. CHECKLIST CONFIDENTIALITY NOTICE The confidentiality notice was developed by EPA staff to inform electronics recyclers of their right to: The confidentiality notice was developed by EPA staff to inform electronics recyclers of their right to: claim certain information as confidential claim certain information as confidential to request the recycler's consent to share information gathered from the on-site electronics recycling facility review with other federal agencies to request the recycler's consent to share information gathered from the on-site electronics recycling facility review with other federal agencies Notice is provided as a sample document for staff from other agencies Notice is provided as a sample document for staff from other agencies Consult your own agency’s procedures with respect to notification of confidentiality Consult your own agency’s procedures with respect to notification of confidentiality

30. BP #7 FINALIZE THE REVIEW 1. Complete the checklist 2. Check findings of team versus acceptability criteria 3. If acceptable, write a report 4. Coordinate report and checklist with FEC 5. If no adverse comments, then set up a file for other Federal agencies to review 6. Notify the recycler

31. FUTURE Promote ISO 14001 EMS for Recyclers Promote ISO 14001 EMS for Recyclers Encourage use of R2 practices (Responsible Recycling) as a guide. Encourage use of R2 practices (Responsible Recycling) as a guide. In the future, EPA may develop a certification program for recyclers using R2 as a guide. In the future, EPA may develop a certification program for recyclers using R2 as a guide.

32. THINK GREEN Any questions?