Thursday, June 7, 2012
I’m participating in a listening session hosted by US EPA and the GSA to get input on the voluntary electronics recycling standards (e-Stewards and R2). EPA is trying to make sure these standards, and any other standard that might throw itself into the ring, meet a set of minimum environmental requirements to be used by federal government agencies when disposing of electronics assets.
The stated purpose of today’s listening session is to, “investigate the implementation of current electronics reycling certification programs, including the following: vigorousness of facility and downstream audits; consistency and frequency of audits; auditor training; documentation of exports, internet sales; and, real world outcomes of certification processes.”
The EPA and GSA are embarking on a two phase study. First, they are conducting research by gathering input from ANAB, certifying bodies, the certification programs, and through listening sessions. Then, they plan to perform witness audits at electronics recycling firms to see for themselves how effective the
Their goal is to make recommendations, as appropriate, for potential improvement to the certification process.
It appears EPA wants to find out, as a potential user of processors, whether the R2 and e-Stewards certifications meet an as yet undefined set of environmental standards. This seems like reasonable due diligence to protect the government (and ultimately us American citizens) from disposing of hazardous e-waste in an irresponsible and illegal manner. A lot is riding on this evaluation.
With more than 275 firms certified to the R2 or e-Stewards standard, there are clearly a lot of options for the federal government to recycle according to its current stated selection process. But is that a sufficient guide?
I am hopeful this EPA study will recognize the differences between the two standards, differences among certifying bodies auditing to these standards, and differences among processors holding each standard. I suspect EPA will find significant disparities within each of these areas.
There were several processors in the listening session who shared their experience with e-Stewards being more rigorous than R2. No one said R2 was more rigorous than e-Stewards. Through this process, I expect EPA will come to witness this difference. But will they finally report this finding and say that e-Stewards sets a higher bar than R2?
Would EPA say that R2 is good enough or will it realize that R2 contains loopholes to give pause to federal agencies who might be liable for the malicious acts of a certified processor that could lead to illegal dumping or export of equipment with sensitive federal data?
Also, how will EPA treat the variation in auditing processes and the implementation of standards at processors? Within the group of companies certified to each standard, some are definitely better than others. EPA’s unconditional endorsement of either or both standards would lead to a race to the bottom for each standard’s requirements because there would be no market based incentive to do more (it’s not like a company would get more federal work by being more responsible).
Many private companies see 3rd party certifications as a minimum threshold for selecting processors for work. Then, they look specifically at the company (which often includes their own on-site audits) to ensure the processor is effectively meeting its own requirements prior to engaging in service. The federal government, through the GSA, should do that as well if it wants to be a leader in environmentally responsible asset disposition.