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Frequent Questions about the Implementation Study of R2 and e-Stewards Certification Programs

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Question: Why did EPA conduct this study?

Answer: EPA conducted this study to fulfill a key commitment under the National Strategy for Electronics Stewardship, which tasks the federal government to lead by example in encouraging the environmentally preferable design and responsible management of used electronics. The goals of the study are to assess whether the Standards are being implemented transparently and consistently, and are achieving the desired results. Where appropriate, the study’s final report provides recommendations for improving the system using input from stakeholder interviews and certification audit observations. The study was conducted in collaboration with the U.S. General Services Administration and the ANSI-ASQ National Accreditation Board (ANAB).

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Question: How was the study designed?

Answer: To achieve the objectives of the study, EPA:

  • Conducted interviews with key stakeholders across the electronics recycling system to obtain their perspective on areas of strength and opportunities for improvement;
  • Observed audits of reuse and recycling facilities performed by the certifying bodies to assess the consistency and rigorousness of the audits; and
  • Analyzed the results and developed findings, conclusions and recommendations which are documented in the final report.

EPA also relied on a team of qualified contractors for technical support in conducting the study. The contractors possessed expert knowledge of the Standards as well as experience auditing recycling/reuse facilities to the Standards.

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Question: What are the limitations of the study?

Answer: The study’s findings are based on 39 stakeholder interviews EPA conducted and nine audits EPA observed. The nine facility audits reflect a small percentage of all certified electronics recycling facilities and auditors working in the electronics recycling industry in the U.S. However, the interviews included all of the organizations essential to implementing the Standards, such as the ANAB, R2 and e-Stewards®, and all of the certification bodies responsible for certifying facilities to the standards across the country. Though limited in number, the audits EPA observed reflected the range of audit types, facility sizes, and services offered by facilities seeking to obtain or maintain certification to the Standards. For additional discussion of the study’s limitations, please see the final report.

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Question: Did EPA assess both versions of the Standards (2008 & 2013) in the study?

Answer: Both the e-Stewards® and R2 standards were updated during the course of the study, in the latter half of 2013. EPA modified the scope of the study to include additional audits and interviews to ensure both versions of the standards were included in the study.

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Question: How did EPA select the facilities whose audits were observed?

Answer: When considering potential facilities for inclusion in the audit observation portion of the study, EPA aimed to include:

  • A cross-section of the different types of facilities that are seeking to obtain or maintain their certification in the United States, both in terms of the kinds of audits that are typically conducted by the certifying bodies, which are the organizations accredited to certify facilities to one or both standards, as well as the range of services offered by facilities seeking certification.
  • An equal number of R2 and e-Stewards® audits, as well as one combined audit where a facility was seeking certification to both Standards; and
  • Audits to both versions of the Standards (2008 and 2013).

With these criteria in mind, EPA worked closely with the certifying bodies to identify candidate facilities to participate in the study. For all nine audits observed, the certifying bodies contacted the facilities in advance of EPA’s arrival and the facilities agreed to let EPA attend the audit.

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Question: What are the key findings and recommendations of the study?

Answer: The study suggests that the accreditation, certification and implementation process of the R2 and e-Stewards® standards is working well. Though limited in scope, the study also identifies opportunities for improvement in key areas, including improving stakeholders’ knowledge of health and safety risks, understanding of legal requirements, and awareness of hazardous substances in electronics. EPA’s top recommendations for improving overall implementation include (but are not limited to) providing additional training and guidance materials in key topic areas, regularly updating the Standards, and increasing audit times to allow for more thorough audits.

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Question: Are the recommendations directed at any organization in particular?

Answer: In practice, many stakeholders will continue to influence and shape the development of responsible recycling in the U.S. and therefore have been considered when drawing the Study’s conclusions and making recommendations. As such, EPA encourages all organizations that have a role to play in shaping the standards and certification process to consider the suggested strategies for improvement and top recommendations in the study. This broader group of stakeholders includes:

  • The Standards owners (Sustainable Electronics Recycling International and the Basel Action Network)
  • The Certifying Bodies
  • Federal and state regulators
  • Trade associations
  • ANAB
  • EPA and other federal agencies, including the Occupational Safety and Health Administration, the National Institute for Occupational Safety and Health, and the Department of Transportation
  • Original equipment manufacturers
  • Academic researchers
  • Non-governmental organizations
  • Private sector companies

EPA remains committed to continuing the dialogue started by this study and supporting the continual improvement of the implementation of the electronics recycling Standards, and will provide assistance and support to stakeholders in discussing and implementing the suggested strategies and recommendations outlined in the final report.

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Question: Is one of the standards being implemented more successfully than the other?

Answer: The study intentionally does not compare the two standards or draw conclusions about whether one standard is being implemented more successfully than the other. The purpose of the study is to assess whether the Standards as a whole are being implemented transparently, consistently, and are achieving the desired results. To this end, the assessment focused on the implementation processes and procedures shared by both Standards, as well as 20 key topic areas that are addressed in both Standards, such as training and communication, health and safety requirements, and export issues.

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