Question:

Why does the R2 Standard require a periodic “evalua[tion] of the risk of exposure to hazardous substances” in Core 3 even though my facility does not perform any materials recovery activities? 

ANSWER:

End-of-life electronics historically have a high propensity for containing hazardous substances, and simply handling them can sometimes expose workers to those substances. For this reason, Core 3 requires all R2 Facilities that receive electronic equipment, components, and materials to evaluate the risk of exposure to these substances, and to do so periodically. 

Core 3 (d) (3) indicates that an R2 Facility shall:  

Maintain a process to periodically evaluate the risk of exposure to hazardous substances such as mercury, lead, beryllium, cadmium, PCBs, phosphor compounds, flame retardants, silica dust, and hexavalent chromium through processing or handling of electronic equipment, components, and materials 

R2 Facilities have different exposure levels to hazardous substances based on the types of processing techniques related to the wide variety of electronics.  Some R2 Facilities perform processes with a negligible risk of exposure to hazardous substances in electronic equipment. For example, R2 Facilities that only sort and refurbish electronics and do no dismantling or other processing might find that the risk of exposure is quite low to virtually nonexistent. However, those R2 Facilities might want to consider abnormal situations like receiving broken devices and whether those situations present a risk of exposure to hazardous substances.  So, while facilities that only perform testing and other ITAD functions may appear as if their risk of exposure is minimal, there may be other considerations to evaluate. Each R2 Facility operates a bit differently and those factors should be considered when evaluating the risk of exposure to hazardous substances. Risks assessments related to normal and abnormal situations should be clearly defined and implemented as part of the R2 Facility’s Environmental, Health and Safety Management System. 

For those R2 Facilities that perform materials recovery processes, Appendix E requires them to conduct a deeper evaluation in the form of hazards identification and assessment. That‘s because materials recovery processes inherently have a higher risk of exposure. Appendix E(4) goes on to require that risk assessments address hazards and operations that are specific to material recovery activities. Additional EH&S criteria are to be implemented based on the results of the hazards identification and assessment. For instance, an industrial hygiene monitoring program to sample airborne contaminants found in electronics may not be applicable to a facility that solely manually dismantles desktop computers, because the activities may not result in a release of pollutants to the air. However, a facility that is performing shredding might present the risk of releasing pollutants and hazardous substances to the air. That risk might be higher depending on the materials that are being shredded, the output particle size, and the presence of any dust-capturing equipment. The R2 Facility needs to understand the results of hazards assessment to implement the appropriate additional EH&S criteria as necessary.   

Keep in mind that these requirements for R2 Facilities certified to Appendix E are in addition to the periodic evaluation for hazardous substances required in Core 3.