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The PBS News Hour segment “Tracking Down America’s Electronic Waste” earlier this week raises serious questions about the mismanagement of a portion of the electronics discarded in the United States. It revealed that the Basel Action Network placed about 200 transponders in pieces of electronic equipment and dropped them off at recycling collection sites. They tracked the transponders, finding that around one-third were exported, mostly to Hong Kong where some of the tracked equipment was dismantled under unsafe working conditions. Though not mentioned in the News Hour segment, some R2 and e-Stewards certified e-waste recyclers reportedly have been implicated.
The R2 program is administered by Sustainable Electronics Recycling International (SERI), and e-Stewards is administered by the Basel Action Network (BAN).
After the segment, SERI released a statement acknowledging shortcomings found at the facilities of some R2 certified e-waste recyclers. The organization highlighted enhanced quality assurance initiatives it is taking to improve the program’s efficacy.
SERI / R2 Statement on Enhanced Quality Assurance Initiatives
SERI is reviewing the data and analysis behind BAN’s conclusions. In the meantime, we are making the following statement.
There are about 600 R2 certified facilities around the world. By virtue of being certified, each claims to care about the environment, and the health and safety of workers and communities — both at their own facilities and those of downstream companies.
“However, we are not naïve,” states John Lingelbach, executive director of SERI, the organization responsible for the R2 program. “We have identified and taken action against certified recyclers that are not meeting R2’s requirements. As a result, in the last six months eleven recyclers have been suspended or withdrawn from the program. And our quality program is continuing to evolve in significant, positive ways.”
“Policing” the certification program is a huge challenge, especially the flow of equipment from a certified facility through multiple downstream facilities. By way of comparison, in the European Union it is illegal for recyclers to improperly manage discarded electronics. And yet, based on research conducted by Interpol and the United Nations University, about 65% of the European Union’s discarded electronics is improperly managed. This occurs in spite of the significant enforcement power of Interpol and other EU enforcement agencies.
So what is SERI doing to keep bad actors out of the R2 program?
- Conducting unannounced audits of certified facilities, focusing primarily on their documentation of outbound shipments and downstream companies’ qualifications.
- Implementing new auditor competency requirements, including a rigorous multi-day training course and examination; adding auditor qualifications regarding knowledge of the industry; and ultimately requiring full-fledged accreditation of each auditor by an independent auditor accreditation body;
- Establishing new audit methodologies that will help auditors identify suspicious outbound shipments of equipment;
- Enhancing requirements concerning the evidence auditors must collect and evaluate as they determine whether a recycler meets R2’s requirements; and
- Reviewing each auditor’s evidentiary reports and the certification decisions based on them.
We are also currently assessing the pros and cons of a tracking program using Radio Frequency Identification (RFID) technology. It could serve as a significant deterrent to certified recyclers that consider violating R2 requirements concerning downstream companies.
At this point, we see BAN’s tracking effort as a “beta” program and are waiting to learn what design flaws its critics identify and what improvements can be made. In any event, we will not hide transponders in used electronic equipment without providing notice of the RFID program and of the possibility that, by virtue of being certified, a company may receive tagged equipment.
The primary objective of R2 certification is the environmentally sound management of discarded electronics. The program was created, and is managed, to achieve one goal: no harm, nowhere. We ardently strive to achieve this goal and we expect, and are working to assure, that each R2 certified recycler does the same.
Further Reading On E-waste Standards
More on SERI’s R2 and BAN’s e-Stewards can be found in this April 2016 coverage at Knowledge@Wharton, the online business analysis journal of The Wharton School of the University of Pennsylvania.