1. Submission of a deficient application
Incomplete applications will not be audited. Recyclers that have not supplied all of the required information and/or have not provided clear direction to the relevant information will have their applications rejected. Applications must be organized with clear direction provided to all submitted supporting information.
Nonconforming applications will not be audited. Applications submitted for processes that do not conform to the requirements of the ERS will be immediately rejected. As well, all processes covered under the application must be in full operation at the time of application.
Where it is determined that false information has been provided or any part of the application, supporting information or processes undertaken have been misrepresented, the application will immediately be rejected.
2. Internal ERS conformance audit has not been conducted
Prior to submission of an application, the recycler must complete an internal audit against the requirements of the ERS to determine conformance. All nonconformance issues must then be addressed through the recycler’s corrective action process. The RQP Application should only be submitted after the recycler has completed an internal audit and compiled sufficient detailed evidence to demonstrate conformance with all requirements of the ERS.
3. Regulatory requirements have not been identified
Specific regulatory requirement as applicable to the recycler’s operations must be identified and evidence of compliance with those requirements maintained.
A list of regulations is not simply a detailed summary of applicable legal requirements. Recyclers need to demonstrate that all applicable regulatory requirements have been identified; detail specifically how the requirements apply to the operations; and demonstrate that adequate compliance programs are in place.
If a detailed regulatory compliance audit has not been completed, a summary of regulatory requirements is not available or there is no verifiable evidence of compliance with or exemption from regulatory requirements, the application will be rejected.
4. A detailed risk assessment has not been completed
Recyclers must be aware of the potential environmental, health and safety risks associated with their operations and demonstrate that adequate control measures are in place to prevent hazardous releases and exposures.
Risk assessment must account for material and process specific hazards. Understanding these risks may require conducting workplace sampling such as air or surface samples, or medical evaluations to test worker exposure.
In addition, the risk assessment must incorporate mechanisms to test and verify the effectiveness of the established control measures. For instance, that cleaning programs are effective in eliminating contaminants and hygiene programs are effective in reducing worker exposure. This includes risks directly in the processing areas as well as transfer of contaminants that could lead to exposure in clean areas.
5. Procedures lack sufficient detail or clear direction
In order to be repeatable and effective, procedures must include detailed actions, responsibilities and timing for completing any necessary tasks. Procedures omitting any of these details are considered incomplete as they do not include a suitable framework under which the activities will be undertaken in order to provide an adequate level of assurance that they will be completed as intended. In addition, effective procedures must also detail the actions to be taken in the event of any deviations from the established procedures.
Procedures must be detailed and applicable to the operations. Use of generic procedures is not sufficient nor is the use of overly voluminous procedures that are too complex to be followed in actual practice.
6. Corrective actions with no root cause analysis
In order to ensure effective resolution of any identified issues, recyclers must first conduct a thorough root cause analysis to determine the underlying source of the issue. By addressing the nonconformance at the source, there is increased probability that the actions taken will be effective in preventing any further occurrence of the same issue, and even similar issues.
Recyclers that address only the immediate identified issue and not the broader underlying cause risk reoccurrence.
7. Reliance on other ‘certification’ programs
There are a variety of different environmental, health and safety standards and certification programs that exist. Due to some common elements between the standards, these other programs may provide a good starting point for recyclers seeking approval under the RQP however recyclers must ensure that they specifically meet all of the requirements of the ERS.
Reliance on a certification from another program alone does not provide adequate basis for undertaking the RQP audit process. The recycler must demonstrate that they have assessed the requirements of the ERS in accordance with their operations, and suitable conformance programs are maintained.
8. Lack of education, training and understanding
Recyclers must ensure that adequate and competent resources are available to develop control programs and maintain their operations in accordance with the requirements of the ERS.
A combination of internal and external resources may be used; however responsibilities must be assigned only to those that are adequately trained and competent in the specified areas. Training and competency levels must be clearly defined and verified for all responsible individuals. Additional training or education may be required prior to undertaking certain tasks, as well as periodic development training to maintain skills or knowledge of particular requirements.
Where external resources are used, the recycler must be able to demonstrate an adequate level of knowledge of and control over the systems and controls, and not solely rely upon an external party to ensure conformance with the ERS.
9. Lack of downstream accountability
Recyclers are required to maintain a documented process to evaluate downstream recyclers to evaluate their ability to handle material in a safe and environmentally sound manner, in accordance with the ERS and regulatory requirements.
Often recyclers have not completed the necessary preparatory work with downstreams to adequately prepare them for the RQP audit process.
Downstream recyclers must be sufficiently knowledgeable of the requirements of the ERS and have conducted their internal audit and prepared evidence of conformance with the ERS, prior to submission of an application for approval under the RQP. Where there is no evidence of conformance or the necessary preparatory work has not been completed, the application will be rejected.
10. Lack of accountability and transparency
The intent of the RQP is to ensure that end-of-life electronics and the resultant materials are managed in an environmentally sound manner that safeguards worker health and safety, and the environment from the point of primary processing to the point of final disposition.
Recyclers are expected to develop and adopt into their operations environmentally sound management principles that guide their decision making processes. Where there is a lack of commitment to proactively adopting these principles, actions are often taken for the purpose of the RQP audit only and significant gaps in conformance as well as history of performance are identified.
In addition, recyclers must transparently disclose the information and evidence that demonstrates and supports their commitment to safe, secure and environmentally sound management practices. Claiming any such supporting information is confidential and not sharing it provides no assurance that the necessary safeguards are in place.
Recyclers need to adopt a culture of commitment to safe, secure and environmentally sound management practices and provide transparency into their processes to demonstrate performance, rather than simply reacting to an audit.