Choosing A Responsible Recycler

So with all the problems and potential liability issues involved in disposing of your end-of-life IT assets, how do you choose an ITAD vendor you can trust? While you can never be 100% sure of the performance of any vendor, the following steps should help you find a responsible recycler:

▲ Trust, but verify. This phrase that Ronald Reagan used when dealing with the former Soviet Union applies in spades to e-waste re-cyclers. No irresponsible recycler is going to publicize the fact that they are irresponsible, so verification is a must. Review and inspect the processes the recycler uses, from properly destroying data to disposal of unusable toxic material. Visit its facilities and those of any subcontractors - third-party contractors are where many of the problems occur. Your vendor should have rigorous auditing and monitoring processes in place to ensure that its partners are meeting the same high standards it follows.

▲ Transparency. An ITAD service provider should be able to provide you with tools (preferably Web based) that allow you to track your items throughout the process. You should know how each piece of equipment was handled, who handled it and when, and what was its final disposition. These same systems can provide you with details on the services your vendor provides, such as the costs involved and any potential areas for revenue back to your organization.

▲ Security. Confidential or private consumer data left on hard drives or other storage devices can be more valuable than the equipment. If the data ends up in the wrong hands, you could find yourself in a competitively weakened position or face fines for exposing private consumer data. Have your vendor demonstrate how data is destroyed and how a chain of custody is tracked. The vendor should be able to provide you with a complete report showing the tracking and disposition of each storage device.

▲ Size matters. Look for a vendor that can provide service in all areas where you have a substantial amount of equipment. Transportation costs can be a big part of a vendor's cost structure. The partner should have collection sites everywhere you do business. Companies such as IBM and HP have operations worldwide; ITAD provider Redemtech has facilities in the United States, Canada, and Western Europe, while competitor Intechra has a large number of locations, but only in the United States. Match the size of your organization to the size of your ITAD provider; larger vendors are better equipped both logistically and financially to handle the needs of larger organizations.

▲ Look for certifications. While certifications for e-waste handling are still in their infancy, organizations that have earned certifications, such as IDC's G.R.A.D.E., have at least made an effort to meet minimum standards. As these certifications mature, sponsoring organizations will most likely become better at ensuring that their standards are being followed through more stringent audits and other controls.

▲ Get your money's worth. Of course, some of your old equipment may have some value; a good ITAD partner will help you figure out what it is worth. Some companies, such as HP, will sort through your old equipment and give you a report showing its value. If your organization refreshes equipment every three years or less, you could see a significant return on your end of life equipment.

The U.S. EPA has produced a checklist for federal agencies to use when evaluating recycling companies for electronic equipment. The checklist includes the following questions:

▲ Can you provide a general description of the business that includes point of contact, number of employees, years in business, ownership history, number of locations, description of services offered, etc.?

▲ Does the electronics recycler accept the products you want recycled?

▲ Does the electronics recycler service your geographic area and type of organization?

▲ Can the electronics recycler clearly describe its fees for various types of equipment?

▲ Can the electronics recycler offer additional services that you may require? Additional services may include on-site collection support, transportation support, product reuse or refurbishment, product tracking, and recycling guarantee or certificate.

▲ Is the electronics recycler equipped to provide needed media san-itization and destruction services for your electronic equipment and components?

▲ Does the electronics recycler audit this portion of their services for quality assurance?

▲ Can the electronics recycler identify its federal, state, and local environmental agency contacts?

▲ Is the electronics recycler geographically located in an area that is regulated by a state and/or local electronics recycling law? If so, can the electronics recycler provide a description of those laws?

▲ Can the electronics recycler provide information on its compliance history? This type of information should include recent criminal (past five years) or civil (past three years) violations, and how they were, or are, being addressed.

▲ If the electronic recycler exports CRT monitors for reuse and/or mixed CRT glass for recycling, are they able to provide documentation that they are in compliance with the export section of the CRT rule (i.e., notification letter to EPA; consent letter for export from EPA)?

▲ Does the electronics recycler have environmental, health, and safety management systems and/or plans in place? Management systems and/or plans may include: Environmental management system (EMS), environmental risk management plan, hazardous materials management plan, and emergency prevention, preparedness, and response plan.

▲ Can the electronics recycler provide a description of its processes? An electronics recycler should be able to provide an overview of its procedures for disassembly, reuse/resale/donation, secure media destruction, disposal and waste handling, product manufacturing, and storage.

▲ Can the electronics recycler provide a description of what it does with the electronic equipment it receives? An electronics recycler can utilize a variety of processing methods, including brokering (matching buyers and sellers), resale of whole units, remanufac-turing (refurbishing equipment), disassembling into parts and subassemblies, material recovery (physical separation to capture plastics, metals, glass, etc.), material processing (shredding and grinding) and donation (school systems, not-for-profit organizations, etc.).

▲ Can the electronics recycler provide the names and/or locations of the downstream businesses to which it sends equipment or components?

▲ Does the electronics recycler, or its downstream vendor(s), export equipment outside the United States? If so, can the electronics recycler supply you with information on the legality of such exports?

▲ Does the electronics recycler practice due diligence for its end-markets, through audit, questionnaire, or other measures?

▲ Does the electronics recycler send materials for disposal in landfills or for incineration?

▲ Can the electronics recycler supply you with documentation or certification of final disposition?

▲ Does the electronics recycler maintain appropriate insurance/ assurance? Types of insurance/assurance may include general liability insurance, environmental liability insurance, and financial assurance (e.g., bonding).

▲ Will the electronics recycler allow you to verify this information through an on-site evaluation? It is critical to have the ability to visit on-site with short notice. Can the recycler provide references and contact information for other businesses that have used their services?

The Federal Electronics Challenge (FEC), a program that encourages federal facilities and agencies to manage the use and disposal of electronics responsibly, has an excellent resource on how to perform on-site reviews of electronics recyclers on-line at http://www.federalelectronicschallenge .net/resources/docs/onsite_review.pdf.

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