These special schemes, called conformity assessment schemes (CAS), are owned and maintained by private enterprises and generally incorporate, reference or require certification to international standards. The process requirements are specific and the audits are meant to be tough as well as thorough. The outcome of these certifications is intended to provide confidence to the certified organizations’ customers and end users that advertised benefits or outcomes are achieved. In the case of electronics recycling firms, these benefits aim to provide confidence of proper refurbishment, reuse and/or disposal of e-waste.
But does a proper audit, leading to certification, guarantee the end result? The answer is no, unless we begin to measure both actual reuse and the actual final disposition of e-waste.
Programs achieving promised outcomes
There are at least two global schemes that include proof of achievement of the promised outcome.
CAS programs like the accredited certification programs for automotive (TS16949, created 1994), and Aerospace (AS9100, created 1999) are subject to extensive measurement and tracking proving the expected outcomes of improving supply chain component quality and cutting supply chain cost. The result is better products and improved safety for the end-user public.
These programs are closely managed by the scheme owner, and are mandatory for supplier/supply chain systems with comprehensive, benefit-defined measurements of the outcomes of certified firms. These sector-specific programs were created because certification auditing of processes did not always guarantee the desired end results using accredited certification alone.
Both industry groups are well-funded and dedicated to measuring the process as well as the end result: product quality. Neither program promises benefits that can’t be measured and verified. Finally, the schemes are mandatory, which channels supplier efforts to be focused on outcomes.
Necessity of tracking and verification
It is increasingly clear that mere certification and claims of meeting requirements is not enough to guarantee the benefits of responsible electronics recycling that are so vital to corporations depending on recyclers. Nor do they necessarily satisfy the public interest. Tracking and verification of final reuse and final proper disposal are essential to achieving the promised benefits of accredited certification in the electronics recycling industry.
Simply auditing paperwork that claims compliance with the laws of importing countries is not enough to guarantee that illegal exports are not taking place. There are several well-publicized examples of certified organizations directly violating their promises and the law.
In my opinion, the Basel Action Network’s (BAN) e-Stewards certification program comes closest to proving the outcome of proper final e-waste disposal. BAN has developed and employs tracking technologies for discarded electronics and e-waste containers being shipped overseas to verify real outcomes. The purpose is to detect any improper or illegal waste disposal by recyclers. When it is shown that the e-waste has been trafficked in violation of the standard or the laws of the importing country, the recycler can be held accountable. The consequences are almost always loss of certification for the recycler and potentially a public outing of the party responsible for the improper disposal.
Unfortunately, well-meaning corporate end-users of electronics recycling are also held to account, regardless of their actual knowledge of wrongdoing. This can do serious damage to their brand and public image. The negative environmental and health outcomes of improper and illegal e-waste disposal warrant strong accountability outcomes.
Support outcome measurements
No program is perfect. But providing random tracking of a statistically significant sample of discarded equipment and containers provides tangible evidence of outcomes, both proper and potentially illegal. The overwhelming majority of stakeholders should demand proper recycling and support methodologies that prove the effectiveness of the recycler’s certificate, such as the tracking mechanisms employed by BAN. Many recyclers are honest and deliver on their promises to end-users. BAN’s tracking methodologies also provide proof of this fact. And, these recyclers deserve to be recognized for their honorable efforts and proper outcomes.
Having said that, any tracking program must be accurate and continual to be effective. Tracking is costly and time-consuming and must be financially sustainable by the scheme owner.
Recyclers, who believe their industry should be held to account and are eager to differentiate themselves from the cheaters, should be fundamentally supporting tracking or an equivalent outcome measurement.
The end users/customers of any industry-specific scheme should expect and demand measurement of outcomes. Committed scheme owners must be prepared to take measures to prove the implied or promised outcome of its requirements. Certification of management, production, and environmental processes and documents, on its own, is not enough for a serious sector scheme. It is a bit of a cliché, but outcomes matter!
H. Pierre Sallé is an independent consultant, formerly president of KEMA Registered Quality, Inc, and DEKRA North America Certification bodies for over two decades and president of Independent Association of Accredited Registrars [IAAR] for multiple terms. Mr. Sallé currently represents the IAAR during International Accreditation Forum meetings.
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