Approaches to Assuring ESM with Downstream

Vendors

NAFTA CEC ESM Workshop

Cindy Coutts

June 12,2013

1

Agenda

Who is Sims Recycling Solutions?

Why bother with WEEE?

Standards

Downstream Accountability – Theory to Practice

Suggestions for a path forward

2

Who is Sims Recycling Solutions?

•Sims Recycling Solutions is part of Sims Metal Management, the world’s largest metal & electronics recycling company ($8B)

Public company ASX/NYSE)

300 Sites

14 million tons of metal processed annually

Carbon saved by recycling these materials: 307,337 tons

52 sites Globally

13 US

Operations

4 Canada

Operations25 EU

Operations

1 New

Zealand

Operation

5 Australia

Operations

3 India

Operations1 UAE

Operation

1 South

Africa

Operation

1 Singapore

Operation

Asia

Representati

ve Offices

3

52 Electronics Recycling Facilities Worldwide

We are 15th among the 100 MOST SUSTAINABLE CORPORATIONS globally

2009-2013 WINNER

Leading the Way Environmentally & Financially

The Global 100 is a list of publicly-traded, MSCI World-listed companies that, based on research and analysis by Corporate Knights Inc., have the best developed abilities, relative to their industry peers, to manage the environmental, social and

governance (ESG) risks and opportunities they face. For

more information log on to www.global100.org

• Participants in Carbon Disclosure Project (CDP6) • Listed on Dow Jones and FTSE4Good Sustainability Indices

5

6

Problem Statement

• We have a love affair with new electronic products

• They contain a multitude of resources: hazardous and otherwise

• Costs to recycle properly

• Society doesn’t want to pay the cost

• We respond, well intentioned, with EPR, and standards

• We produce semi processed resources in Canada, for further processing elsewhere where consumption demand into new product exists.

The E-Scrap Issue

•In Canada the volume of e-scrap reached 225,000 tonnes in 2010 (75,000 mt in Ontario alone last year)

•50-80% of all e-scrap generated in North America is shipped to developing countries, while only 11%-13%is recycled properly, the rest is land filled.

•Electronics contain a variety of materials that pose problems to human health and the environment if not managed properly at end of life.

• Electronics recyclers vary, it is important to know where your materials are going. No point in charging an ecofee just to export.

8

Greenwashing?

9

E-waste Recycling Standards

• General environment, industrial hygiene, safety regulations not enough

• ISO 14001, OHSAS 18000 not enough

Lead to development of e-waste specific standards for ESM

• R2 (US)

• E-stewardship (US)

• WEEE Directive/Weelabex

• EPSC RQP (Canada) – 4rd iteration

10

Downstream Accountability

• Canadian, US and EU experience – vast

leakage of WEEE outside programs

• Primary processors audited (manual or

mechanical processing)

• After that, “commodities” move to other

parties for further processing

• Need to understand what happens through

the whole chain of custody.

11

Sims Recycling Solutions Process

• Any downstream company with whom we wish to do business must go through a formal approval program

• Asked to submit all paperwork to satisfy our audit protocol.

• 36 Documents; non disclosure agreements

• Audit document developed within Sims to meet requirements of:

1. EC Regulation 1013/2006 on the supervision and control of shipments of waste within, into and out of the European Community

2. Basel Convention on the control of trans boundary movement of hazardous wastes and their disposal

3. OECD Decision (C(2001)107/Final) on the control of trans boundary movements of wastes destined for recovery operations

4. UNEP Technical Guidelines on the Environmentally Sound Recycling / Reclamation of metals and metal compounds (R4)

5. OECD Core Performance Elements of the Guideline for Environmental Sound Management of Wastes

6. UNEP Technical Guidelines for the identification and environmentally sound management of plastic wastes and for their disposal

7. ISRI Electronics Recycling Operating Practices

8. Responsible Recycling (“R2”) Practices for Electronics Recyclers

9. USEPA CFR 40 Part 9, 260 and 261 – Hazardous Waste Management System: Cathode Ray Tubes

10. Plug-In eCycling – Guidelines for Materials Management, USEPA, May 2004

11. EPSC Electronics Recycling Standard (Canada)

12. e-Stewards® Standard for Responsible Recycling and Reuse of Electronic Equipment©. Licensed and copyrighted by the Basel Action Network.

13. EPEAT (Electronic Product Environmental Assessment Tool)

12

Sims Downstream Audit

• Detailed questions (hundreds in total) on:

• Site History

• Product and Residual Waste

• Site Conditions

• Health and Safety Performance

• Environmental Performance

• Financial and Agreements

• Shipping and Receiving

• Physical and Data Security

• Social Responsibility

PASS/FAIL

13

Observations from Sims Recycling Solutions

• Over the past 4 years, Sims has audited 68 potential downstream vendors in Asia alone.

• ALL MET THE PAPER REQUIREMENTS

• Falsify documents and certifications

• All then had a site visit by qualified Sims personnel

• Only 6 have passed the Sims audit

• WHY?

15

16

17

18

19

Lessons Learned

• Physical site audit prior to use is a requirement

• Qualified personnel with industry knowledge must conduct audit

• To be qualified to a standard qualifying body must visit downstream sites

• Society must decide what is acceptable and what is not

• ENFORCEMENT is key

• No point in diverting from landfill here, if harm to human health and the environment elsewhere is greater

20

Recommendations for Continuous Improvement

Although we’ve made great progress in a few years, significant room for improvement:

• Standards established to Best Practices, by multi-stakeholder boards

• Overseen by government

• Eliminate conflicts of interest

• Requirement for 3rd party, informed auditing of primary and downstream recyclers

• Needs to apply to all WEEE recyclers, not just those in programs

• Consistent implementation

• Downstream Accountability mandatory

• Transparency

• ENFORCEMENT

21

Do we want to greenwash, or make a difference?

Yes there is a cost. Is it worth it?