What happens if a recycler is not prepared for the audit?
The onus is on the recycler to maintain objective, verifiable evidence that demonstrates conformance with the requirements of the ERS. Inadequate or incomplete applications or corrective action plans will be rejected. If the recycler is unable to demonstrate conformance within the required timeframe, the audit will be closed as ‘not approved’.
Prior to submitting an application, it is strongly recommended that the recycler review the Audit Preparation information below, as well as the Top 10 Recycler Mistakes to ensure that you are suitably prepared to undertake the audit process and avoid any unnecessary delays.
Application & Audit Preparation
1. Responsibility and accountability
Start by assigning the responsibility for managing the Electronics Recycling Standard (ERS) implementation process. The individual(s) responsible must have adequate knowledge of management systems and the authority to impact and enforce modifications in processes and operations to ensure conformance with the requirements of the standard.
2. Conduct a ‘gap analysis’
A detailed and documented review of the operations against each element of ERS must be undertaken. For each element of the standard, compile supporting information that demonstrates conformance with the requirement and identify any gaps where suitable evidence of conformance does not exist.
3. Assess and allocate resources
Based on the nonconformance gaps identified, the available internal resources must be assessed to determine if they are sufficient and adequate enough to address the identified issues. Also, consideration should be given to the need for training as well as the use of external expertise to address specific issues.
To ensure a successful implementation of control programs, competent individuals, sufficiently knowledgeable in the following areas will be required:
- The Recycler Qualification Program
- The recycler’s operations
- Applicable regulatory requirements
- Environmental, health, safety and security risks and control measures
4. Address the gaps
For each of the identified gaps, an action plan must be developed to investigate the issue and define the appropriate actions to address the item. All action plans must be sufficiently detailed, including defining the specific actions to attain conformance, responsibilities for implementation and timing for completion.
5. Conduct an internal audit
Once all of the defined actions have been taken to address the ERS nonconformances, a formal internal audit must be conducted to verify the implementation and test conformance against each of the requirements of the ERS.
6. Corrective actions
Any nonconformances identified through the internal audit must be addressed through the detailed corrective action process, and follow up completed to verify the effectiveness of the actions taken.
7. Management review
The results of the ERS implementation activities, internal audit and all associated corrective actions must be reviewed by senior management and assessed to determine the adequacy and effectiveness of the control programs.
8. Evidence of Conformance
Once deemed adequate and effective, suitable evidence of conformance to the requirements must be compiled, appropriately documented on the RQP application form with clear direction to the supporting information, and submitted to the RQO for assessment.