E-Waste Treatment & Audit Standards: Are We Turning the Corner?

I’ve reviewed many industry standards during my career and taken part in plenty of environmental audits. But one formative experience especially stands out in my memory.

I was working with a partner and a few investors some years ago as we jointly considered the best location for a new e-waste treatment venture. We had many heated discussion about which state would best suit our needs. Eventually, I convinced them to build in California. I was aware of the state’s upcoming and progressive e-waste regulation and the fact that its SB20 programs eventually would be a revenue generator and would also help even the export-dominated field. I also knew the state’s stringent regulatory oversight and permitting requirements would add credibility to our new e-waste (toxin) treatment process.

At the time, e-waste-to-element resources, auto–processing and treatment were relativity new in California, and I was well aware that the e-waste treatment industry didn’t as yet have any widely recognized standards. That became even clearer when it came time to obtain California facility permits. I found that the regulatory agencies themselves didn’t even have an historical process to refer back to. Solid waste regulators and toxin control and air quality engineers didn’t have similar processes to fall back on for comparison or reference, and thus were hampered in their ability to stipulate best practices in the areas of plant design and controls. We were all forced to extrapolate a bit and, post-construction, were able to quantify vital engineering points, which ultimately proved to be effective. 

I was recently reminded of all this when a potential recycling partner asked which is best: ISO or another association certification. I had to respond that neither was ideal for a start-up process. Instead, I directed him first to federal & state level Lead (Pb) regulations, followed by California’s e-waste regulations and the upcoming New York regulations. I also suggested he use California’s SB20 recycling fee reimbursement accounting system for all e-waste. I suggested that combination would be a good start toward developing internal e-waste management standards exceeding most, if not all, written standards or regulations.  He expressed surprise at my response, since Redemtech is ISO-compliant. Yes, I told him, ISO is a widely accepted management system. On the other hand, the fundamentals of an ISO program revolve around regulatory compliance and compliance is the first step toward most certifications. He’ll probably never ask another question….

Over the years, I’ve found wide variations in audit and environmental due diligence practices. Recently, during an e-waste related audit meeting, I was disclosing details of our overall data security system, e-waste management, recycling methods and accounting system. The environmental auditor was extremely surprised at the degree of detail involved in managing and accounting for data-bearing assets and e-waste. Conversely, I’ve noticed that others companies having on-staff environmental professionals are adapting hazardous waste handling and accounting standards to e-waste, which is an excellent start.

At Redemtech, our Request for Environmental Information is only part of our e-waste recycling vetting process. It’s generally followed by a verification of process, ventilation and pollution controls, e-waste treatment products evaluation and feasibility studies. Feasibility involves ensuring that quoted recycling fees fall within a “responsible range,” based on the prevailing metals & polymer commodity markets, factoring in domestic e-waste treatment costs. Having a good understanding of e-waste resource recovery and full operational costs is both an advantage and a disadvantage, since recycling fees will fluctuate within market conditions and price ranges. We’ve received quotes from recycling service companies that were automatically disqualified, simply because they were too low to support responsible domestic recycling. Not understanding this e-waste treatment evaluation process can lead to irresponsible recycling partner selection. Or even worse, measureable irresponsible e-waste management, a vital liability service our customers expect from us.

After a few decades of experience in this field, there’s far less need to theorize these days (though of course we continue to be open to new e-waste treatment models and innovations). Happily, we have a body of reasonably well-developed reference regulations and best practices, and with long experience we know what works best and what yields the most environmentally responsible outcomes. There’s nothing quite so personally satisfying as sharing that hard-won expertise with clients.

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