A successful, coherent, and comprehensive e-recycling risk management program needs to be inclusive of all on-site processes and activities, as well as consider multiple external influences and connections – upstream and downstream of an e-recycling or asset recovery facility.

This is why smartEE consulting offers expertise and support for all elements relevant to managing your risks and your customers’ risks:

Comprehensive Facility Risk Assessments

Like an annual health check-up for your facility, these baseline assessments are typically one-day “top-to-bottom” on-site surveys of your facility’s processes, activities, documentation, etc. followed by a thorough documentation review and discussion. You will receive a detailed risk analysis, prioritized findings, and recommended actions. Audit elements and outputs will be customized to meet your specific needs.

Environmental Management Systems (ISO 14001:2004) Consulting

ISO 14001 is quickly becoming a basic risk management cornerstone for e-recycling companies. If you want to – or need to – show a systematic approach to managing your environmental impacts through documented and audited environmental practices, ISO 14001 is an excellent option. smartEE consulting can facilitate and accelerate this process for you by offering:

• EMS Gap Analysis
• EMS Development and Implementation Support
• Internal (1. party) and External (2. party) Auditing
• Registration (3. party) audit preparation and support

Environmental, Health, and Safety (EHS) Consulting

Depending on the type of your recycling operations, your EHS risk could be substantial; the efforts needed to mitigate such risks using a formalized EHS system, however, are not. smartEE consulting can help you with your EHS system from inception to maintenance by offering:

• Policy development
• Objectives development
• Program and activities implementation
• Review of existing EHS program
• Regulatory compliance review
• OHSAS 18001 registration support
• ISO 14001 registration support

Post-Audit Corrective Action Process Support

Whether they are the results of your internal assessments or audit findings from a third-party audit, following up on open findings using a formalized corrective action plan can seem like a time-consuming and often confusing process. Audit findings offer your company the opportunity to position itself better in the market, to improve internal processes, and to minimize risk – but only if you take it. In practice, too often these valuable insights and findings are squandered. smartEE consulting can help you tackle your audit findings in a timely manner and with reasonable effort.

Downstream Due Diligence Assessments

Despite being one of the broadest and most unpredictable risk areas for any recycling and asset recovery company that sends waste, recyclables, or untested assets to downstream vendors, the management of downstream due diligence and material disposition is often neglected or falls short of true transparency. Even if you are managing and processing all of your materials of concern in-house and are sending only presorted raw materials and tested assets to your vendors, you will need a systematic and vigilant approach to your downstream vendor and material management – well beyond your next tier of vendors. smartEE consulting has extensive experience in helping you:

Evaluate your existing vendor network, if needed by conducting on-site audits

Track your material stream to the true point of final disposition

Assess regulatory compliance of your transboundary shipments

Evaluate your internal and external logistics processes and safe-guards

Adjust your vendor contract language to better manage risk and set accountability standards

Establish a systematic vendor management and internal audit program

Vendor Search & Qualification

In evaluating your existing vendor relationships, new material streams, or possibly new geographies, you may find yourself in the position of searching for new vendors. While this search is rightfully dominated by economic considerations, a systematic risk and compliance evaluation of each potential vendor should be an integral part of the vendor qualification process. smartEE consulting can help you speed up this vendor search and qualification process by supporting you in:

Drafting a vendor request for quote (RFQ) that details your performance expectations

Reviewing and assessing submitted vendor responses

Ranking potential vendor choices by risk and other factors

Conducting on-site verification assessments at the potential vendor facility

Data Security Assessments & Process Consulting

Nothing has the potential of throwing a wrench into your operations like a data security breach concerning your customer’s hard disk drives or other data-bearing media. While many recyclers take a good-faith effort at establishing a functioning data wipe routine, many fail to grasp that the data security process begins when, for instance, the hard disk drives arrive at the facility, and does not end before the destruction of the failed or rejected drives has been verified – even if that destruction occurs off-site. smartEE consulting can help you minimize your exposure risk by assessing and implementing:

Physical security of any media entering your facility

Logical staging and flow through your data wipe process

Straightforward labeling and triage of wiped versus failed media

Documentation and training processes for your technicians and support staff

Internal auditing and sampling procedures

Further, smartEE consulting offers support in evaluating alternative data destruction software and hardware products, standards (e.g. DoD, NIST), and processes and help you select those that are compatible with your goals, established processes, and/or customer requirements.

Green E-Recycling Certifications Consulting (BAN e-Stewards© and R2)

Currently, OEMs, non-profit organizations, and industry associations are seeking to homogenize recycling facility and downstream due diligence performance requirements and EHS compliance standards, and to establish a certification that could reasonably forecast what a customer would find at any of the facilities bearing the certificate. Several certifications are currently launched into the marketplace with BAN e-Stewards© and R2 receiving the most industry attention. Though not a certifying body itself, smartEE consulting can help you evaluate, prepare for, and pursue the following e-recycling certifications:

• R2 Certification
• BAN e-Stewards© Certification

Regulatory Support & Interpretation

Rapidly changing regulatory frameworks can

• affect the way you conduct business,
• facilitate of hinder your access to e-scrap take back materials,
• influence your geographical expansion plans.

Depending on the number of jurisdictions your company operates under or ships materials to, regulatory compliance can add new levels of complexity. smartEE consulting can help you evaluate current e-scrap legislation, interpret the rules applicable to your company, and help you prepare applications for “preferred vendor” systems at the US State level.