Annual Environmental Audit at Good Point Recycling Today

As of July 1, Vermont will officially have the strictest regulations of e-waste facilities in the USA.  In Vermont, R2 compliance is not a "carrot" you need to do to win a contract - it's a mandatory regime which you must certify to in order to do business in Vermont.  And Vermont has added some bells and whistles "Vermont rules".  But whatever your standard, it's not very meaningful without an annual 3rd Party audit.  Ours is today.

What I'd like to do is wax philosophically on what parts of an environmental audit add value to the environment, what parts are a "snapshot" which means nothing a month earlier or a month later, and what parts of an audit are really valuable for sharpening the tools in the drawer.  As a result of the environmental audit (scheduled today from 9AM-2PM), we tended to a number of "wilting flowers" at Good Point Recycling:  Scheduled an overdue team safety meeting, replaced locks, reviewed our voluntary OSHA audit paperwork (from a year ago), and moved some lamps which were, shall we say, nearing their expiration date (lamps we collect and don't get paid for - stiffed on - we naturally tag for return to the client en principe, but that can put you beyond the 365 day storage limit).

Well, I am printing documents below, and just replaced my toner cartridge, so no time for Platonic analogies this morning.   I do think it may be interesting to show what an environmental auditor sends as a list of things to have ready (does not include "surprise" requests, like letters from "competent authorities" for export-for-recycling or disposal).

The highlighted portions are the people at Good Point Recycling I gave key responsibility to.  Our Asset Recovery Director, John, is on a 5 week bicycle trip across Canada, and we have had some other turnover.  But if you never test your operation, you will never improve.  So, time to brew some coffee and go back over the records.  Are you ready for your R2 gap analysis?

Audit will include as applicable:
  • Physical site audit and following material flow through facility  - Robin
  • HW, UW, fuel, combustible and or special waste storage areas  - Pete, Colin
  • Material processing areas - Colin
  • Waste management areas - Pete, Colin
  • Refurbishment activities and functional testing - Colin, Robin
  • Data destruction protocol - Colin
  • Perimeter - outside of facility - Robin, Pete, Colin
  • Security - Pete
  • Health and Safety Programs and systems - Colin, Robin, Rachael
  • IH Monitoring/Bio-monitoring - Rachael (drug test)
  • Air permits - management of and compliance to - ??
  • Waste permits – management of and compliance to - Rachael
  • Operating permits – management of and compliance to  - Rachael, Robin
  • Export compliance– permits and permissions - Robin
  • Material tracking systems - Robin, Pete, Colin, Rachael
  • Refurbishment activities and functional testing - Robin, Colin
  • Data destruction protocol - Colin, John? Zack?
  • Transportation management - Pete, Rachael
  • Shipping and receiving protocol - Pete, Rachael, Colin
  • Downstream due diligence - Robin, Rachael, Colin

As is applicable to the operation, please have available for our review:
  • Written Health and Safety Programs and training - Robin, Rachael, Colin
  • Analytical Data for IH monitoring, material testing, air emission monitoring, water monitoring waste analytical as applicable
  • Operation permits, business licenses, storm water, air emissions, soil testing, conditional use permits, occupancy permits etc., as applicable Robin,
  • Violations and mitigation of those and or final penalties Colin
  • BOL’s, Manifest, Shipping papers for 12 months of material, including but not limited to, circuit boards, circuit board containing equipment, CRT glass, batteries, PCB contain material, mercury containing material, HW, ink and toner cartridges and whole equipment Robin, Rachael, Pete, Colin
  • International documentation - Authority’s of Consent, Competent Authority letters, licenses for export/import Robin, Colin
  • Insurance certificate  Rachael
  • Closure plans and financial assurance Robin,
  • Material flow charts, Plot plans, site diagrams
  • Copies of ISO certifications, ISO policies, R2 polices, e-Stewards policies, all operating permits and licenses (table of contents is OK) safety training calendar, and waste analytical or profiles to include in the final audit  - we can put these onto a memory stick while on site or hard copies can be provided. Rachael,  Colin

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