Guidelines and recommendations for WEEE reuse and recycling operators

Risks associated with treating WEEE

Dismantling, crushing, recycling or refurbishing WEEE, if poorly managed, has the potential to release toxic substances into the environment and to endanger human health. The management of WEEE involves manual handling, storage and transportation of heavy and bulky items, so health and safety issues must also be considered.

These issues are discussed in more detail in the reuse and recycling sections of this guidance.

It is essential that the environmental and health and safety risks are identified and proactively managed by reuse and recycling operators. This has been recognised by the Organisation for Economic Co-operation and Development (OECD), which has produced comprehensive guidance on the environmentally sound management of wastes.

Barriers to reuse or recycling WEEE and drivers for increased collection

Why more WEEE is not reused or recycled

WEEE often ends up in our landfills because:

• end users are not aware of alternative options
• the alternatives are considered too expensive
• there is limited infrastructure available to collect WEEE separately
• there are no viable economic markets for the material once it is collected (for example, plastics or glass).

New Zealand’s dispersed and relatively small population means that the economics of establishing full WEEE processing facilities (including metal smelting) are not currently favourable. The recycling options are constrained by:

• the low and sporadic collected volumes
• vulnerability to fluctuating market prices
• high freight shipping and labour costs
• lack of certainty in supply
• low technology infrastructure.

Countries with larger populations, a comprehensive collection network with higher collected volumes, and access to the materials market are able to operate in an economically viable manner.

This has the potential to change in New Zealand as greater emphasis is placed on the efficient use of resources.

The drivers for increased collection of WEEE

There is an increasing desire by consumers for an ‘environmentally friendly’ disposal solution for their electrical and electronic equipment. There are already a number of industry-led voluntary recycling schemes for the take-back and recycling of products such as mobile phones, whiteware and IT goods and product stewardship is developing, driven by demands from government, businesses and consumers. This is expected to increase following the introduction of the Waste Minimisation Act in 2008 which enables the Minister for the Environment to accredit product stewardship schemes.

Such schemes, along with a strong international market for metals and a new levy on sending waste to landfill, will see changes in the way end-of-life electronics are disposed of in New Zealand. These changes may result in an increase in the separate collection and treatment of end-of-life electronics.

Main outcomes for collected WEEE

Figure 4 shows the different routes of WEEE from collection to end point. There are three main outcomes for WEEE. It may be:

• sent for reuse in New Zealand or overseas, from where it is either prepared for reuse, disassembled or becomes waste
• prepared for recycling in New Zealand or overseas, where materials are recovered
• sent straight overseas for recycling.

WEEE that cannot be reused or recycled is disposed of as waste.

Figure 4: The route of WEEE, from collection to end point

Guidelines and recommendations for reuse and recycling operators

All companies operating businesses that reuse, refurbish, and/or recycle WEEE should be committed to:

• minimising the health and safety risks associated with their operations
• minimising the release of hazardous substances to the environment by adopting good practice
• maximising the diversion of WEEE from landfill
• recording data so WEEE can be monitored through the reuse and recycling chain
• only working with competent companies operating at the next stage of the reuse and recycling chain
• providing a quality-assured service that meets customers’ needs.

To achieve these aims, reuse and recycling operators should:

• prioritise reuse
• have the financial, managerial and technical ability to perform their operations to the recommended good practice standards
• have systems to check that downstream recyclers also meet the recommended good practice recommendations.

Environmental, health and safety, and quality management systems

All operators handling WEEE should have the financial, management and technical ability to perform their operations. They should be fully aware of the environmental, health and safety issues associated with their business and have clearly defined roles and responsibilities for managing these issues.

The Organisation for Economic Co-operation and Development has developed guidance on environmentally sound management of waste.

The requirement for a management system does not necessarily require large changes in operations or the imposition of excessive costs. There is a judgement call as to what level of system is required.

However, whatever the scale of the system, some basic requirements need to be covered.

All operators should have formal management systems covering:

• environmental management
• health and safety
• quality management.

Depending on the size of the company and the scale of the operations, these systems may be:

• accredited to a recognised standard such as ISO 14001 [BSI Group UK website] or equivalent
• integrated or separate.

The systems should:

• cover the following areas:
  • commitment and policy (including a commitment to continual improvement, reducing operational waste sent to landfill or incineration, and reusing or recycling a high percentage of the WEEE received)
  • planning implementation
  • measurement and evaluation
  • review and improvement
• identify the key issues relevant to their operations
• clearly define roles and responsibilities for managing the issues
• include appropriate environmental, health and safety training, covering:
  • material and equipment handling
  • worker exposure
  • controlling releases
  • safety and emergency procedures
• include a formal emergency response plan for reporting and responding to exceptional pollution releases (accidents, spills, fires and explosions)
• include an emergency coordinator designated to handle hazardous wastes.

Operators should ensure:

• systems are documented and audited and records kept for a minimum of four years
• depending on the size of the organisation, that systems are audited by a competent third party for verification at least annually.

Sources of further information
The Bureau of International Recycling has published Tools for Environmentally Sound Management for an ISO Compliant Environmental Management System [Bureau of International Recycling (BIR) website] that includes OECD Core Performance Elements for the World’s Recycling Industries.

Good practice collection and treatment guidelines for electrical and electronic products has sections on Traceability and Management Systems [PDF, 1.17 MB] [Wrap UK website] and Health and Safety and Environmental Procedures [PDF, 1.20 MB] [Wrap UK website]

Insurance

All operators should have appropriate levels of insurance to cover environmental liabilities, and for bodily injury, property damage, and contractual liability.

The insurance should be adequate for the size and diversity of the operation and include public liability and transport insurance. The requirements should be secured in the supplier agreement.

An adequate financial guarantee should be provided by large recovery facilities to assure clean up in case of a major pollution incident. Resource consents may require a financial bond to mitigate potential clean ups.

Business plan

All operators should have a business plan and knowledgeable staff in the senior management team.

Evidence of financial stability should be available to customers on request in the form of the preceding year’s audited accounts.

Recycling companies should have a closure plan that addresses processing equipment, abandoned materials after closure, and financial assurances in accordance with applicable laws.

Sources of further information
Good practice collection and treatment guidelines for electrical and electronic products produced by WRAP in the UK has a section on Treatment Facility Site Management which includes emergency contingency planning.

Legislative compliance

All operators should identify and comply with relevant health and safety, trading standards, employment, and environmental legislation.

Where appropriate, operators should have permits and licences from the appropriate agencies.

The legislation covers:

• waste and recyclables processing, storage, handling and shipping
• air emissions and waste water discharges
• worker health and safety
• trans-boundary movement of wastes.

Table 3 lists key legislation, along with links to the appropriate agency website where more detailed information can be found.

Staff training

Operators should have a training programme in place for all staff. This should link to their environmental management systems and risk assessments.

Where applicable, this should include formal workplace training provided by EXITO, the industrial training organisation covering this sector. EXITO subsidises training that leads to individuals achieving unit standard(s). The New Zealand Qualifications Authority [NZQA website] recognises the qualifications which have been designed by the industry, for the industry.

EXITO has developed a unit standard which is registered on the NZQA Framework for resource recovery, which covers:

• resource recovery operations
• resource recovery theory
• zero waste.

Key personnel should achieve the EXITO Resource Recovery Unit Standard.

Evidence of any training session should be documented.

EXITO has identified e-waste as an area which may need specific unit standards in the future.

EXITO can also subsidise and arrange training for first aid, fire training, health and safety, licences and endorsements.

Disposal chain responsibilities

Once WEEE has been discarded there are different routes it may take before it is reused or recycled (see figure 4). The route involves a range of organisations, which together make up the disposal chain.

To ensure WEEE destined for reuse and recycling is sent to appropriately qualified and managed companies the operator should:

• log, where practical, the name and details of all parties who will handle the waste downstream as far as possible
• take reasonable steps to ensure their contractors meet the recommendations in these guidelines
• provide, on request, a full audit trail of materials in, processes adopted, and materials out of the system where practical and as far as possible
• document the procedure adopted for their choice of contractor and the downstream audits that are in place.

The operator will provide a visible tracking system to the final processing destination and keep copies of contracts, stating how the destination facility will process the materials it receives, and how they assess and manage their health and safety and environmental impacts.

The New Zealand Business Council for Sustainable Development has information on a sustainable supply chain.

Examples of businesses with processes for disposal chain responsibility

• Sony Supplier Code of Conduct: Sony led the formation of an industry standard for the successful implementation of a sustainable supply chain.
• The Electronic Industry Code of Conduct is a code of best practices adopted and implemented by some of the world’s major electronics brands and their suppliers. The goal is to improve conditions in the electronics supply chain.The Electronic Industry Citizenship Coalition is a group of companies working together to promote the code. Tools to implement the Code can be found on their website.
• Hewlett Packard [PDF, 121 KB] have implemented a Code of Conduct for its suppliers.

Design of physical facilities

All refurbishing facilities should have separate areas within the facility for:

• WEEE entering the facility
• processing WEEE (refurbishment/disassembly or recycling), with clearly marked bays and areas
• storing WEEE, in a way that prevents spillages, contamination and release of hazards
• product leaving the facility (either refurbished equipment, disassembled products or recyclate – recycled material that will be used to form new products)
• waste leaving the facility.

The site should be a secured enclosure and have a functioning security system.

Dismantling operations and storage of components should be indoors and on impervious floors (that is, floors that can’t be penetrated).

Storage areas must be adequate to hold all processed and unprocessed items.

Appropriate equipment must be used for the proper processing of incoming materials and the control of environmental releases. This is particularly important in the destructive dismantling and physical treatment of WEEE.

This guidance is not prescriptive, so sites can be designed within the constraints of the building and adapted for situations where the same location has multiple or temporary functionality. These recommendations may not be suitable where one room serves multiple functions at different times. A common-sense approach is advised for these circumstances.

Sources of further information

• Fit for Reuse: A Guide to the Repair, Refurbishment and Reuse of Domestic Electrical Appliances [PDF, 835 KB] provides more detailed guidance on the layout of refurbishment operations.
• The Auckland Regional Council’s Industrial Pollution Prevention Programme has produced a series of information sheets including pollution prevention requirements [PDF, 257 KB] [Auckland Regional Council website] for sites undertaking an industrial or trade process. This guidance may also useful for other disassemblers.
• The OECD’s Technical Guidance for the Environmentally Sound Management of Specific Waste Streams: Used and Scrap Personal Computers [OECD website] guidance sets out specific requirements for scrap PCs.
• The International Precious Metals Institute Environmentally Sound Management Used Mobile Telephone[PDF, 181 KB] [International Precious Metals Institute USA website] guidance sets out specific guidance for mobile phones.
• WRAP’s good practice collection and treatment guidelines for electrical and electronic products has a section on Treatment Facility Site Management which includes advice on traffic management and site infrastructure.

Health and safety risk assessments

Health and safety policy, procedures and programmes should be in line with health and safety legislation.

Risk assessments should be carried out for:

• exposure to hazardous substances
• fire and explosion
• cuts and lacerations
• musculoskeletal injury.

Staff training should be undertaken to reduce these risks.

Operators must prevent the release of hazardous substances into the environment.

Companies may apply for the British Standard Occupational Health and Safety Standard (OHSAS) 18001:2007, which has been designed to be compatible with ISO 9001 and ISO 14001.

Detailed health and safety information is provided in the Health and safety considerations when reusing or recycling WEEE section.

Sources of further information

• The OECD’s Technical Guidance for the Environmentally Sound Management of Specific Waste Streams: Used and Scrap Personal Computers guidance sets out specific requirements for scrap PCs.
• The International Precious Metals Institute Environmentally Sound Management Used Mobile Telephone(http://ipmi.org, PDF, 257 KB] guidance sets out specific guidance for mobile phones.

Verification of processes and data collection

When requested by customers, the operator should provide:

• evidence of secure destruction of data (where appropriate)
• certificates of recycling for all WEEE recycled (certificates can link to other data gathering)
• data on the WEEE handled and processed to the specifications requested by the customer.

It is good practice for refurbishers or recyclers to provide a certificate of destruction for removal of data from hardware. Refer to the Reuse of WEEE section for more information.

Information exchange programme

All facilities in the disposal chain should share information to ensure wastes are separated and treated in a way that allows the maximum recovery to take place.

This could be in the form of specifications for material coming through the chain (acceptance criteria).

The OECD requires recovery facilities to have an information exchange programme to optimise recovery, which requires participants to:

• establish and maintain an information exchange programme with waste producers to optimise recovery rate and quality of the product, and minimise the generation of waste from the recovery process
• get feedback from subsequent recovery and disposal facilities concerning the optimum composition of wastes.

Source of further information
Online good practice collection and treatment guidelines for electrical and electronic products produced by WRAP in the UK has a section on Communication between treatment facilities and stakeholders [PDF, 1.04 MB].

Environmentally sound management of waste and the OECD

Waste is an international commodity and is often exported overseas for treatment. The Basel Convention regulates the movement of hazardous wastes between countries. In addition to this, there are protocols for the environmentally sound management of wastes. This is in recognition that:

... less stringent environmental controls, safety levels or human health standards (usually implying the lower cost options) in some countries have ... created the potential for exporters, importers or waste managers to direct shipments of wastes destined for recovery to OECD countries and/or waste management facilities having lower waste management standards. (OECD, 2007)

Environmentally sound management is defined by the Basel Convention as

taking all practicable steps to ensure that hazardous wastes or other wastes are managed in a manner which will protect human health and the environment against adverse effects which may result from such wastes.

In this context, the criteria to assess environmentally sound management include the following:

1. There exists a regulatory infrastructure and enforcement that ensures compliance with applicable regulations;
2. Sites or facilities are authorised and of an adequate standard of technology and pollution control to deal with the hazardous wastes in the way proposed, in particular taking into account the level of technology and pollution control in the exporting country:
3. Operators of sites or facilities at which hazardous wastes are managed are required, as appropriate, to monitor the effects of those activities:
4. Appropriate action is taken in cases where monitoring gives indication that the management of hazardous wastes have resulted in unacceptable releases:
5. Persons involved in the management of hazardous wastes are capable and adequately trained in their capacity.

Countries also have obligations to avoid and minimize waste generation and to ensure the availability of adequate facilities for their waste, so as to protect human health and the environment.

The Basel Parties are developing technical guidelines on the Trans-boundary movement of e-waste and these should also be referred to.

Further sources of information on reusing and recycling WEEE