Strengthening the competency of employees in key roles Since the United States EPA first established a multi-stakeholder group to establish the best practices for electronics recycling (the result of which was the R2 Standard, introduced in 2008), the industry has been on a path of continuous improvement. Observations made during SERI witness and spot audits conducted over the past six months have for the most part been encouraging, and signal an industry that is changing for the better.
In several of the companies audited, however, there was a common issued identified for improvement: a lack of expertise in key roles such as managing legal compliance, export compliance, due diligence, and technical repair and refurbishment. Both the size of a company, and its core business, appear to be contributing factors to lack of competency of key employees.Consider whether the following situations observed during SERI audits are occurring in your organization, and if so, take corrective measures.
Excelling in activities pertaining to a company's core competency (i.e. repairing and refurbishing) but lacking the expertise to adequately perform certain activities outside its core competency (i.e. recycling).
This is a common challenge for a small business. Until a business can scale to justify the cost of a staff person, it might be more effective to use outside resources. For example, if a computer refurbisher gets in a small number of cell phones to repair, it might be more efficient to partner with a cell phone refurbisher rather than internalize a function that is outside of the computer refurbisher's core business.
Promoting a general laborer to a technical position without the proper training or experience.
Not surprisingly, quality and conformance diminish when inexperienced employees are not properly trained to perform technical duties. Promotions to technical positions should be supported by education and experience to ensure employees have the tools and resources to perform their roles effectively.
Pulling the occasional "gems" out of the recycling stream to resell.
If not properly managed and documented, this type of transaction can result in multiple non-conformances. Companies must have key employees who understand the requirements of the R2 Standard and who can correctly apply them to adequately test these pieces of equipment for Key Functions.
Assigning an administrative assistant to provide health and safety management for the company.
While administrative personnel can adequately provide record keeping for Health & Safety, they may not have the experience or knowledge to properly apply regulations and risk analysis. This is a critical competency for any organization. Outside consultants can be a valuable resource for companies that lack the resources to hire someone with health and safety knowledge and experience.
Bottom line: Certification requires competency. Make sure your key roles are filled by employees with the knowledge and experience necessary to perform the job. Or partner with other companies/service providers/consultants who will supplement your internal resources and areas of expertise.
Strengthening the competency of Certification Body auditors
SERI witness audits and document reviews show that many Certification Body auditors are most competent evaluating management systems, written procedures and policies. Auditors must improve their industry competency by placing greater emphasis on evaluating the records and actual outcomes of a company's operation to objectively assess conformance to R2 requirements. The management system is an important component of the R2 program, but the outcome of the actual processes employed is perhaps even more essential to maintaining the integrity of certification. Judging the competency of consultants
Consultants tend to be experienced in management systems related to Quality, Environmental, or Health and Safety. Few consultants have competency in all three areas. More importantly, many consultants do not have sufficient experience in electronics recycling or refurbishment. Selection of a qualified consultant is extremely important. Be sure to do your homework. Ask how many companies they have helped to become R2 certified. Ask for references from other R2 certified companies that have used their services - and call them! As other areas for improvement are identified during SERI witness and spot audits, we will continue to share them with you in future issues of the R2 Update newsletter.