Safety Management System (EHSMS) to plan and monitor its environmental, health, and safety

practices, including the activities it undertakes to conform to these R2 Practices.

trained and capable of carrying out responsibilities; and (c) Establish a process for communicating about the

EHSMS.

Check

recurrence; and (c) Provide a measurement system.

Act

necessary changes to the EHSMS; (c) Create and implement an action plan for continual improvement.

3

(F) A list of the activities necessary to conform to the requirements of these R2 Practices and

a list of the documentation necessary to show conformity with these requirements.

(b) An R2 electronics recycler shall obtain a certification from an Accredited Certification Body

stating that:

(1) Its EHSMS conforms to the requirements of this provision, and

(2) Its practices conform to the EHSMS and to the requirements of these R2 Practices.

“Reuse, Recover, …” Hierarchy of Responsible Management Strategies

General Principle –

R2 Practices:

(a) An R2 electronics recycler shall develop in writing and adhere to a policy stating how it manages

used and end-of-life electronics equipment, components, and materials – with respect to both onsite

activities and the selection of downstream vendors – which is based on a hierarchy of

responsible management strategies:

(1) Reuse – An R2 electronics recycler shall take all practical steps to direct properly functioning

equipment and components to reuse unless a customer directs otherwise,

(2) Materials Recovery – An R2 electronics recycler shall separate as appropriate, through

manual dismantling and/or mechanical processing, the materials in equipment and

components that are not directed to reuse and direct them to properly-equipped materials

recovery facilities when technically and economically feasible.

(3) Energy Recovery or Disposal – An R2 electronics recycler shall direct remaining material to

properly-equipped energy recovery and/or disposal facilities in conformity with Provision 5.

(b) This policy shall incorporate and be consistent with the Focus Material Management Plan that the

R2 electronics recycler develops in accordance with Provision 5.

3.

General Principle –

R2 Practices:

(a) In order to maintain its compliance with all applicable environmental, health, and safety legal

requirements and to assure it only exports equipment and components containing FMs to

countries that legally accept them, an R2 electronics recycler shall develop and implement a plan

covering these matters that shall be included as a section of its EHSMS.

(1) The plan shall identify and document the environmental, health, and safety legal requirements

that cover the recycler’s operations. The recycler shall keep the plan up to date, identify (in

to countries for which it has such documentation 

the following:

(A) A copy of the relevant information from the United States Environmental Protection

Agency, or

(B) Documentation 

accepts such imports, or

(C) A copy of a law or court ruling from the importing country that demonstrates the legality

of the import.

4.

General Principle –

R2 Practices:

General

(a) An R2 electronics recycler shall possess the expertise and technical capability to process each

type of equipment, component, and material it accepts in a manner protective of worker safety,

public health, and the environment.

(b) An R2 electronics recycler adheres to good housekeeping standards, including keeping all work

and storage areas clean and orderly. Clean up operations for all areas of the facility should be

planned, regularly implemented, and monitored.

Workforce and Environmental Protection

(c) An R2 electronics recycler shall conduct on an ongoing basis (e.g., as new types of materials are

processed or new processes are utilized) a hazards identification and assessment of occupational

and environmental risks that exist or could reasonably be expected to develop at the facility.

This includes shipments made by downstream vendors.

The R2 Document makes the assumption that these shipments are legal to import into OECD countries.

Recyclers that export used CRTs for reuse and CRT or mixed CRT glass for recycling also have export obligations

under USEPA’s CRT rule (FR: July 28, 2006 Volume 71, Number 145).

The documentation must be in English, or otherwise comprehensible, to the R2 recycler’s third-party R2 auditor.

Such risks could result from any sources, including but not limited to emissions of and/or

exposure to substances

cuts and abrasions, etc.. The hazards identification and assessment shall be captured in writing

and incorporated as a component of the recycler’s EHSMS.

(d) An R2 electronics recycler shall manage the hazards and minimize the releases it identifies using

an appropriate combination of strategies, including but not limited to (1-3 below are in order of

priority, per OSHA regulations):

(1) Engineering controls such as (A-C below are in order of priority, per OSHA regulations):

(A) Substitution (e.g., replacing a toxic solvent with one less toxic),

(B) Isolation (e.g., automating a process to avoid employee exposure), or

(C) Ventilation and, if appropriate, capture (e.g., fume hood),

(D) Dust control, capture, and clean up, and

(E) Emergency shut-off systems, and

(F) Fire suppression systems,

(2) Administrative and work practice controls, including appropriate combinations of:

(A) Regular, documented health and safety training that covers information from the hazards

assessment, as well as safe management handling, spill prevention, engineering controls,

equipment safety, and use and care of personal protection equipment; with training for

new hires and refresher courses for all employees that is understandable to them given

language and level-of-education considerations,

(B) Job rotation as feasible given workforce size,

(C) Safe work practices,

(D) Medical surveillance,

(E) Safety meetings,

(3) Personal protective equipment, including respirators, protective eyewear, cut-resistant gloves,

etc., as appropriate for the risks involved in the tasks being performed.

(e) An R2 electronics recycler shall utilize monitoring and sampling protocols to provide assurances

that the practices it employs are effectively and continuously managing the risks it has identified.

This includes complying with all applicable Federal or State OSHA standards and PELs for

sampling and/or monitoring.

(f) An R2 electronics recycler shall treat its entire workforce, including volunteer workers,

temporary workers, and anyone else performing activities under its direction, using the standard

of care established pursuant to Section (d) of this provision.

(g) An R2 electronics recycler shall designate a qualified employee or consultant to coordinate its

efforts to promote worker health and safety. This individual shall be identified to all employees

and two-way communication shall be encouraged between employees and this individual

do not under ordinary conditions pose a risk to worker safety or the environment. Such substances may include

mercury, lead, beryllium, cadmium, PCBs, some phosphor compounds, certain brominated flame retardants (i.e.,

polybrominated biphenyls, pentabrominated diphenyl ether, and octabrominated diphenyl ether), silica dust,

chlorinated or brominated dibenzodioxins and dibenzofurans, and hexavalent chromium. Special attention should be

given to potential lead and cadmium exposures during the creation or handling of broken CRT glass, as well

as where lead solder is melted during chip recovery.

Exceptional Releases

(h) An R2 electronics recycler shall be prepared at all times to implement the plan set forth in its

EHSMS for responding to and reporting exceptional releases, accidents, spills, fires, explosions,

and other out-of-the-ordinary events that pose risks to worker safety, public health, or the

environment.

General Principle –

R2 Practices:

Development and Adherence to an FM Management Plan

(a) An R2 electronics recycler shall analyze and plan how the R2 Focus Materials (FMs) that pass

through its facility or control will be properly managed both on site and throughout the Recycling

Chain (and include this analysis and plan as the “FM Management Plan” section of its EHSMS).

The FM Management Plan shall state how the recycler and its downstream vendors shall conform

to the requirements set forth in the rest of this Provision 5.

Removal of FMs

(b) Prior to shredding, materials recovery, energy recovery, incineration, or land disposal of

equipment or components, FMs (as well as toner and toner cartridges) shall be removed using

safe and effective mechanical processing or manual dismantling, with two exceptions:

(1) Items containing mercury if they are too small to remove safely at reasonable cost, and

workers are protected from the risks posed by the mercury during and subsequent to any

processing or manual dismantling of the equipment containing it, and the equipment and

components containing such items are sent to materials recovery facilities that are properly

licensed to receive, and that utilize technology designed to safely and effectively manage,

equipment or components containing such mercury-containing items.

(2) CRTs, batteries, and circuit boards contained in equipment or components destined for

materials recovery need not be removed prior to shredding and/or materials recovery if the

shredding and/or materials recovery occurs in facilities that are properly licensed to receive,

and that utilize technology designed to safely and effectively manage, equipment or

components containing these FMs.

Processing, Recovery, and Treatment of FMs

Selection and Ongoing Due Diligence of Downstream Vendors for FMs

(e) For shipments of removed FMs, and shipments of equipment and components containing FMs, an

R2 electronics recycler shall select downstream vendors that possess and conform to:

(1) The R2 recycler’s FM Management Plan (developed in accordance with and including the

requirements set forth in Sections (b) - (d) above),

(2) A documented environmental, health, and safety management system,

(3) A list of its environmental permits and copies of each,

(4) This Section (e) of Provision 5, thereby establishing that each vendor in the Recycling Chain

conforms to these subsections (1) – (7),

(5) Provision 6 (Reuse),

(6) The exporting requirements of Provision 3 (a) (2), and

(7) Provision 7 (Tracking Throughput).

(f) An R2 electronics recycler shall confirm, through audits or other similarly effective means that

each downstream vendor in the Recycling Chain to which Section (e) applies continues to

conform to the requirements of Section (e) for as long as it receives FMs directly or indirectly

from the R2 recycler.

Reusable Equipment and Components

General Principle:

R2 Practices:

(a) An R2 electronics recycler shall not allow equipment or components to be sold or donated for

reuse if contrary to commercial agreements.

(b) An R2 electronics recycler shall, with respect to equipment and components it ships downstream:

(1) Label and sort each shipment in a manner sufficient to track throughput in conformity with

Provision 7.

(2) Handle and package shipments in conformity with Provision 12.

(c) An R2 electronics recycler, prior to shipping equipment and components (except equipment and

components that are new and in their original packaging) that contain FMs and that will be reused

as is or repaired, refurbished, or remanufactured, shall:

(1) Utilize effective testing methods to confirm that the Key Functions of the equipment or

components are working properly, or

(2) Determine that the recipient vendor is a certified R2 electronics recycler, or

(3) Confirm through an appropriate combination of contractual agreements, detailed materials

tracking and recordkeeping, and auditing that:

(A) The equipment or components meet the specifications of the recipient vendor, and

(B) The recipient vendor sells the equipment or components for reuse, with their Key

Functions functioning properly, and

(C) The recipient vendor manages all residual FMs resulting from refurbishing operations in

a manner that conforms to the R2 Practices.

(d) An R2 electronics recycler need not conform to Section (c) for shipments of less than 15 units

that either are going to a new vendor as a sample for purposes of evaluation of whether to

purchase larger quantities for refurbishment or that are being sold with a practical return policy to

an end user. This Section (d) does not apply to multiple sales or shipments within a proximate

timeframe to the same entity.

(e) An R2 electronics recycler need not conform to the downstream requirements of Provision 5 for

shipments that satisfy the requirements of Section (c) or (d), or are new and in their original

packaging.

(f) An R2 electronics recycler need not conform to the exporting requirements of Provision 3 (a) (2)

for shipments that satisfy either the functionality requirement of Section (c) (1) or the

requirements of Section (d), or are new and in their original packaging.

Tracking Throughput

General Principle –

R2 Practices:

(a) An R2 electronics recycler shall maintain for at least three years commercial contracts, bills of

lading, or other commercially-accepted documentation for all transfers of equipment, components,

and materials into and out of its facility, as well as for any brokering transactions.

General Principle –

R2 Practices:

(a) An R2 electronics recycler shall sanitize, purge, or destroy data on hard drives and other data

storage devices (the National Institute of Standards and Technology’s (NIST’s) Guidelines for

Media Sanitation – Special Publication 800-88 88

sanitization consideration), unless otherwise requested in writing by the customer. The R2

electronics recycler shall adhere to the data sanitization, purging, or destruction practices

described in the NIST Guidelines for Media Sanitation: Special Publication 800-88 or another

current generally-accepted standard, or be certified by a generally-accepted certification program.

(b) An R2 electronics recycler shall document their data destruction procedures.

(c) Employees involved in data destruction shall receive appropriate training on a regular basis.

(d) Data destruction processes shall be reviewed and validated by an independent party on a periodic

basis.

General Principle –

(a) An R2 electronics recycler shall store items removed pursuant to Provision 5, and equipment and

components destined for reuse, in a manner that:

(1) Protects them from adverse atmospheric conditions and floods and, as warranted, includes a

catchment system, and

(2) Is secure from unauthorized entrance, and

(3) Is in clearly labeled containers and/or storage areas.

See http://csrc.nist.gov/publications/nistpubs/800-88/NISTSP800-88_rev1.pdf

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Facility Security

General Principle –

R2 Practices:

(a) An R2 electronics recycler shall maintain a security program that controls access to all or parts of

the facility in a manner and to a degree appropriate given the type of equipment handled and the

needs of the customers served.

11.

Insurance, Closure Plan, and Financial Responsibility

General Principle –

R2 Practices:

(a) An R2 electronics recycler shall possess adequate Comprehensive or Commercial General

Liability Insurance including coverage for bodily injury, property damage, pollutant releases,

accidents and other emergencies.

(b) An R2 electronics recycler shall develop and keep current a written plan and a sufficient financial

instrument that assures proper closure of the facility and assures against abandonment of any

electronics recycling products, components, or materials.

12.

Transport

General Principle –

R2 Practices:

(a) An R2 electronics recycler ensures that all equipment, components, and materials to be

transported are packaged appropriately in light of the risk they could pose during transportation to

public health or the environment and the level of care warranted by their intended use.

(b) An R2 electronics recycler obtains written documentation or a third-party certification indicating

that their transporters have all the necessary regulatory authorizations and no significant

violations of relevant legal requirements during the past 3 years.

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13.

Recordkeeping

General Principle –

R2 Practices:

(a) An R2 electronics recycler shall maintain in a single location each piece of documentation

necessary to show conformity to each requirement of this document.

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October 30, 2008

An “accredited certification body” is accredited under ISO Guide 66 or ISO/IEC Standard 17021:2006 to

certify electronics recyclers to the R2 Practices.

“Downstream vendors” include any entity to which a recycler transfers used or end-of-life electronic

equipment, components, or materials including reuse, refurbishing, demanufacturing, processing,

materials recovery, energy recovery, incineration, and disposal facilities.

“Electronic equipment”, also referred to as “equipment and components”, includes computers and

peripheral equipment – central processing units (CPU’s), monitors, printers, keyboards, scanners, storage

devices, servers, networking systems; copiers; fax machines; imaging systems; printing systems;

telephones; televisions; video cassette recorders; camcorders; digital cameras; control boxes; stereo

systems; compact disc players, radios, cell phones; pagers; personal digital assistants (PDAs); calculators;

organizers; and game systems and their accessories. It furthermore includes any other or new (future)

types of equipment that are designed primarily to store or convey information electronically, and any new

accessories to such equipment.

“Key Functions” are the originally-intended functions of a unit of equipment or component, or a subset

thereof, that will satisfactorily serve the purpose(s) of someone who will reuse the unit.

“R2 Focus Materials”, also referred to as “FMs”, are materials in end-of-life electronic equipment that

warrant greater care during recycling, refurbishing, materials recovery, energy recovery, incineration,

and/or disposal due to their toxicity or other potential adverse worker health and safety, public health, or

environmental effects that can arise if the materials are managed without appropriate safeguards.

The following are R2 Focus Materials:

(1) Items containing polychlorinated biphenyls (PCBs),

(2) Items containing mercury,

(3) CRTs and CRT glass,

(4) Batteries

(5) Whole and shredded circuit boards, except for whole and shredded circuit boards that do not

contain lead solder, and have undergone safe and effective mechanical processing, or manual

dismantling, to remove mercury and batteries.

Equipment, components, or materials (whole or shredded) that have undergone safe and effective

mechanical processing or manual dismantling to remove FMs, yet still retain de minimus amounts of FMs,

are not subject to the R2 requirements that are triggered by the presence of FMs.

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October 30, 2008

“Recycling Chain” refers to all the downstream vendors that handle end-of-life equipment, components,

or materials that pass through an R2 electronics recycler’s facility or control. It includes, but does not

extend beyond materials recovery facilities such as smelters. For equipment and components that are sold

or donated for reuse, it does not extend beyond the entity that conforms with Provision 6 (c) or (d).

“Recyclers” includes but need not be limited to electronics resellers, refurbishers, recyclers,

demanufacturers, asset recoverers, brokers, as well as leasing companies that engage in these activities.

The purpose of this document is to take a first step in addressing this situation – to develop a commonlyaccepted set of R2 practices for the electronics recycling industry. Accredited certification programs—by

verifying an electronics recycler adheres to these R2 practices—will enable customers to make better informed decisions and have increased confidence that their end-of-life electronic equipment will be dealt with in a responsible manner.

The R2 practices set forth herein are not legal requirements and do not replace electronics recyclers’ legal obligations. Electronics recyclers that adhere to this set of R2 practices are doing so on a voluntary basis.

If a requirement of this document conflicts with an applicable legal requirement, the recycler must adhere to the legal requirement.

(“R2”) PRACTICES

 Storage

Data Destruction

An R2 electronics recycler shall maintain business records sufficient to

. However, if circumstances beyond the control of the R2 recycler disrupt its normal management of an FM, it may consider these technologies to the extent allowed under applicable law.Unless applicable law requires the use of one of these technologies (e.g., thermal destruction of PCBs).

(c) An R2 electronics recycler shall send removed FMs to processing, recovery, or treatment

facilities that are properly licensed to receive, and that utilize technology designed to safely and

effectively manage, the FMs. This shall include:

(1) For items containing mercury – mercury retorting,

(2) For circuit boards – removal of batteries and mercury and then smelting for metals recovery,

and

(3) For items containing PCBs – technology specifically designed for PCB destruction and

licensed under the Toxic Substances Control Act and/or any other applicable law.

(4) Toner and toner cartridges, though not an FM, shall be recycled through the OEM or other

qualified toner recycler unless it is not economically feasible.

Energy Recovery, Incineration, and Land Disposal of FMs

(d) An R2 electronics recycler shall not utilize energy recovery, incineration, or land disposal as a

management strategy for FMs or equipment and components containing FMs

 regarding potential hazards and how best to address them.R2 Focus Materials

Risks posed by exposure to substances may arise in a variety of situations – sometimes involving substances that

, noise, ergonomic factors, thermal stress, substandard machine guarding,

R2 electronics recycler shall utilize practices at their facilities that protectOn-Site Environment, Health, and Safety

from the country’s Competent Authority stating that the country legally

. The documentation shall consist of one of

The recycler shall identify the countries that are receiving such shipments, obtain documentation demonstrating that each non-OECD country legally accepts such shipments, and only make such shipments

the plan) and implement the steps necessary to comply with each requirement, document the

implementation of these steps, periodically evaluate its compliance with the requirements,

and take corrective action to address any issues of non-compliance.

(2) The plan also shall identify and document the legality – under the laws of the importing

countries – of all international shipments of equipment, components, or materials containing

FMs that have passed through the R2 recycler’s facility or control

Legal Requirements