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Auditing your e-waste recycler


In the forthcoming December/January edition of Solid Waste & Recycling magazine I’ve written an article based on my recent plant tour of the Noranda Recycling e-waste recycling plant in Brampton, Ontario. I was very impressed with the plant, overall, and wanted to share with readers an item (below) that my tour guide Cindy Thomas handed to me, which is a ten-point check list anyone should use in auditing a potential service provider for e-waste recycling.
To my mind, this is critical information. As a former editor of HazMat Management magazine, I’m very familiar with the importance to companies of auditing facilities that handle their wastes, and I suggest you copy and paste the information below and use it as a reference. Share it with anyone in your company involved in this kind of decision making. I’ve toured a number of e-waste plants and found them superficially acceptable, but then I’ve been disturbed later by little details. For example, in one plant I took some photos, and then couldn’t use the most interesting pictures because droplets or deposits of some kind formed on my camera lens. This was invisible to me at the time, but it was interesting to me that the photos were fine up to the point in my tour when I was in the area of the shredding equipment. Clearly, the shredder was releasing some sort of fine dust into the air. In retrospect I’m concerned about the health and safety of the folks working in that area; it bothers me to think I was breathing that junk even for a short time. It’s likely made up of very fine particles of plastic and metal. Yikes!
With e-waste programs coming onstream across Canada, the importance will grow of plants operating to the same standard as Noranda Recycling. I hate to tout the virtues of any one company and I don’t mean to endorse Noranda and not someone else. But do yourself a favor: tour the Noranda plant, and bring the check list below on any other tours you take. Don’t settle for less. Another thing that impressed me about the Noranda plant was that they videotape operations and the destruction of equipment, to prove destruction and data security. I have a feeling that some of the companies taking e-waste these days need to make an investment in these areas, and I think regulators should insist on these as minimal standards, to establish a level playing field, and not one in which the low-cost operator wins contracts, while running a “dirty” business. Just my two cents.
Here’s the list.


Ten key questions to ask your end of life electronics recycler
1. Does your recycler provide evidence of its permitting, including air emission and waste permits, hazardous waste generation registration and regulatory compliance for the past five years?
2. Does your recycler provide evidence that 100 per cent of your material is not being landfilled or sent outside Canada or the U.S.?
3. Does your recycler provide downstream accountability (audit record and copies of permits/insurance) for the ultimate destination of 100 per cent of your hardware? For example, if your recycler sends a part of your hardware to another company, your recycler must provide evidence that this recycler is operating in and environmentally sound manner, not passing the waste on to another organization that might be landfilling or exporting to a lesser developed country.
4. Does your recycler provide copies of their environment, health and safety policies and practices, including their emergency response plans, closure plans, employee training plans, record keeping, fire prevention and security plans?
5. Does your recycler provide proof of insurance?
6. Does your recycler provide evidence that they do not use prison labor?
7. Does your recycler provide you with a certificate of recycling and destruction?
8. Does your recycler provide evidence of an environmental management system, such as ISO 14000?
9. Does your recycler provide evidence of suitable management systems in place to ensure that
applicable employee health and safety laws, regulations and standards are enforced?
10. Do YOU audit your recycler to verify that the above is in place and part of daily operations?
For more information contact Cindy Thomas at 905-874-6835.


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