Lifespan Environmental, Quality, Health & Saftey Policy
Lifespan has developed, and shall document, fully implement, and review at least annually, and update as needed (e.g., as products and/or technologies change) a written Quality, Environmental, Health, Safety and Security Management System (QEHS&S) that:
- Includes written goals and procedures and requires the organization to systematically manage its environmental, health, and safety matters, and
- Is based on a “Plan-Do-Check-Act” model
In order for Lifespan to sustain this Environmental Policy, the requirements of the QEHS&S apply to all activities, equipment, raw materials, and employees.
Roles and Responsibilities
Senior Management and the Senior Management MS Representative, as defined in “QEHS&S Responsibilities, Roles, and Roster” will support and provide adequate resources to the QEHS&S department. Lifespan’s QEHS&S shall be managed by a designated Management Representative (QEHS&S Manager) who has the responsibility to lead, plan, enforce, and maintain the QEHS&S program. The QEHS&S program will also be supported by the QEHS&S support team.
Material Disposition Hierarchy
Lifespan will manage the retirement of electronic equipment and components so as to balance financial objectives of our customers with the mitigation of reputation, environmental, and data security risks. Furthermore, Lifespan will manage used and end-of-life electronic equipment that is consistent with a “Hazardous Electronic Waste (HEW) Management Plan” and that is based on a “reuse, recover, dispose” hierarchy of responsible management strategies.
- Reuse –Lifespan shall take all practical steps to direct properly functioning and fully-tested equipment and components to reuse unless a customer directs otherwise,
- Materials Recovery – Lifespan shall separate as appropriate, through manual dismantling and/or mechanical processing, the materials in equipment and components that are not directed to reuse and direct them to properly-equipped materials recovery facilities when technically and economically feasible.
- Energy Recovery or Disposal – Lifespan shall direct remaining material to properly-equipped energy recovery and/or disposal facilities. Lifespan will not utilize energy recovery, incineration, or land disposal as a management strategy for HEW or equipment and components containing HEW. However, if circumstances beyond our control disrupt its normal management of a HEW, we may consider these technologies to the extent allowed under applicable law.
When authorized by our customers, Lifespan may sell complete systems or electronics components when the product has been tested and confirmed to be working in its original intended purpose. If the primary functionality of equipment is compromised, it is evaluated for refurbishment and reuse value. If it is not reusable then it is demanufactured. Certification body (CB) reuse principles and Lifespan’s Reuse Policy will be followed.
Legal and Environmental Compliance
Lifespan will comply with all relevant local, state, federal, and international environmental legislation and regulations. More specifically we will comply with all relevant regulations of the countries importing equipment, components, or materials containing HEW that have passed through our facility or control.
Lifespan will package, transport, and store all materials, equipment, and devices as to prevent release into the environment or damage to the functional components of the equipment.
Lifespan will track by project number the origin and destination of all processed materials. In addition, Lifespan will reconcile all shipping and receiving documentation in order to ensure that all in-bound quantities match outbound shipments.
Lifespan will exclusively utilize recycling and resale facilities that contractually commit to comply with all environmental laws and HEW plans. All universal waste, hazardous waste, and HEW downstream facilities are audited and will be reviewed on an annual basis.
Health and Safety Policy
Lifespan is committed to maintaining a safe and healthy work environment. Lifespan will take all reasonable actions to safeguard the health and safety of their employees and maintain documentation to be able to show we are doing so.
Safe work environments do not occur without thoughtful attention by all employees. Managers, supervisors, and employees all share the same responsibility of maintaining a safe and healthy work environment. Every Lifespan employee is encouraged and required to be proactive in supporting this policy.
- Comply with applicable Health and Safety regulations;
- Manage the HEW that pass through our facility or control in a manner protective of worker health and safety, public health and the environment;
- Prevent workplace injuries by providing a safe environment for employees, contractors, visitors, volunteer workers, temporary workers and anyone else performing activities under our direction;
- Investigate any workplace accidents, illnesses and near-misses, and promptly correct any unsafe condition or practice;
- Annually perform Hazard Assessments on our facilities;
- Once identified, minimize (or eliminate) hazards in the workplace. Furthermore, we will perform corrective actions within a reasonable and time appropriate manner;
- Ensure that the workplace environment provides adequate ventilation, temperature, and lighting;
- Ensure each employee knows the risks and proper management of universal waste and hazardous electronic waste;
- Ensure safe and clear access to fire exits, first aid equipment, and fire extinguishers;
- Continually check our facilities for any structural defects, electrical hazards, and mold and take the necessary remedial action;
- Ensure that all equipment is suitable for its intended use and is properly maintained, used, registered, certified, and licensed;
- Ensure that all staff are aware of the emergency procedures and regular drills are carried out;
- Ensure that all members of staff are aware of the procedure in case of accidents or spills;
- Ensure that all members of staff are aware of and carry out their health and safety responsibilities as set out in their job descriptions;
- Prohibit any contractor working on the premises without prior discussion with the officer in charge to negate any risks to the staff or users;
- Provide appropriate personal protective equipment and train on the use;
- Provide clear access to injury statistics, environmental testing results, MSDS, regulatory requirements and other QEHS&S documents to all employees;
- Provide source control so upstream shipments are packaged safely and without unknown wastes or are rejected;
- Annually test the work environment for quantifiable levels of dust, noise, light, lead, and other concerns as mandated by certification body and regulatory requirements.
The nature of Lifespan’s operations has a positive impact on the environment through the conservation of metals, plastic and other non-renewable resources and the proper management of used and end-of-life electronic equipment. Consistent with these core operations, it is Lifespan’s overall goal to accomplish its business objectives while striving for an injury-free workplace, minimizing pollution, and providing quality products to our customers.
The QEHS&S Management System only works effectively if all employees participate and operate within its framework. By supporting the management system and its policy, all employees contribute to continuous improvements in quality, environmental, health, safety, and security aspects of Lifespan’s operations.
It is our intention to:
Develop and maintain quality, environmental, health & safety and security programs that conform to the best practices within the scrap and electronics recycling industry;
- Comply with all relevant environmental, health & safety laws and regulations, including federal, state and local and other requirements;
- Comply with all relevant regulations of the countries importing equipment, components, or materials containing HEW that have passed through our facility or control;
- Prohibit the use of prison or child labor at any Lifespan or partner facility;
- Comply with customer and product requirements and industry guidelines;
- Manage used and end-of-life electronics equipment, components and materials based on a hierarchy of first, reuse/refurbish; second, materials recovery; and finally, energy recovery/disposal;
- Manage HEW that pass through our facility or control in a manner protective of worker health and safety, public health and the environment;
- Prevent workplace injuries by providing a safe environment for employees, contractors, visitors, volunteer workers, temporary workers and anyone else performing activities under our direction;
- Investigate any workplace accidents, illnesses and near-misses, and promptly correct any unsafe condition or practice,
- Promote prevention of pollution in all of our operations, including the elimination of electronics waste from landfills;
- Work with our entire recycling chain including downstream vendors, suppliers, customers and contractors to fulfill our environmental, health & safety goals; and
- Continually improve our quality, environmental, and health & safety programs and resulting performance.
We recognize that the responsibilities for quality, environment, health, safety and security are shared, requiring cooperation, not only between employees and their supervisors, but among and between all those who assume the various roles within the company.
Lifespan will continually improve its QEHS&S system and performance. This will include the setting of QEHS&S goals, taking into consideration our QEHS&S footprint and our business, financial, operational and legal requirements as well as the views of interested parties.
Environmental and Medical Surveillance
An electronics recycler operating potentially hazardous technologies such as a shredder must have regular medical surveillance.
- Lifespan has a Bloodborne Pathogen (BPP) procedure and process in place.
- Environmental testing from a CIH is used to evaluate exposure, noise, air pollution, and ergonomics.
- Medical examinations, biological and blood testing, and audiometric testing will be performed as needed per workplace incidence.
- Lifespan performs monthly PPE evaluations.
- Lifespan has a written Hazard Communication program.
Reuse before recycling is our preference, but only if it meets our other policies and the customer’s needs/policies. With client authorization, Lifespan may also reuse components of larger assemblies. Some clients designate that we destroy the whole units, including components such as memory, chips, etc. in which case we will not reuse the unit or any component of that unit. Only whole, tested, wiped, working units or components will be designated for reuse. We may ship to North American wholesalers, global markets, Lifespan store fronts, or use online sales.
Proper management of reuse equipment is critical for ensuring that Lifespan’s environmental policy is met. Equipment destined for reuse must be handled in such a way as to prevent release of customer data or hazardous electronic waste. Contracts and documentation must be created to show the reuse equipment is actually being resold and not simply recycled. The participation and cooperation of multiple departments within Lifespan is crucial to successfully fulfil this policy.
Lifespan will utilize recycling and resale facilities that contractually commit to comply with all local, state, federal and international laws when we sell over 15 units (e.g. Bills of Sale and/or Sales Terms and Conditions). If a waste is created during the sale, it will be handled in accordance with all regulatory and CB requirements, and documented accordingly.
- Lifespan will track by project number the destination of all reuse material. In addition, Lifespan will reconcile all shipping and receiving documentation in order to ensure that inbound quantities match outbound shipments. Each reuse transaction is tracked by serial #’s when possible and by weight and/or unit count.
- When authorized by our customers, Lifespan may export complete systems or electronics components. The product must be fully tested and confirmed to be working in its original intended purpose. If it fails testing, it will be demanufactured and recycled.
- Lifespan will transport all reuse equipment, components, and materials using entities that have the necessary regulatory authorizations and in a manner protective of public health and the environment.
- Lifespan shall refurbish as needed, properly test, and adequately package equipment and components going to reuse.
An electronics recycler shall not allow equipment or components to be sold or donated for reuse if contrary to commercial agreements.
- Lifespan has an implemented procedure that all Reuse/Resale transactions have a BOL and/or Master Services agreement in place.
- An electronics recycler shall, with respect to equipment and components it ships downstream:
- Label and sort each shipment in a manner sufficient to track throughput in conformity with CB requirements.
- Lifespan tracks all materials in an external database, tracking origin or plant material to 1st tier vendor.
- Handle and package shipments in a manner that protects them from damage or release to the environment.
- Lifespan has in place a procedure for packaging reuse materials.
An electronics recycler, prior to shipping equipment and components (except equipment and components that are new and in their original packaging) that contain HEW and that will be reused as is or repaired, refurbished, or remanufactured, shall:
- Utilize effective testing methods to confirm that all key functions of the equipment are fully functional, especially if this equipment contains hazardous electronic equipment
- Lifespan has a ‘Testing for Key functions’ procedure in place and a testing matrix to indicate and document the functionality of components and key functions.
- Utilize certified processes and methods to remove all customer data (including asset tags and other branding) from the device and data-bearing equipment contained within, as verified to the customer through chain-of-custody documentation.
- Determine that the recipient vendor is a certified electronics recycler – R2 certification required if equipment is not reused/refurbished by Lifespan
- Lifespan’s reuse vendors are usually not R2 certified.
- Separate toxic components during demanufacturing before shredding or other potentially hazardous activities.
- Lifespan has a demanufacturing procedure in place.
- Confirm through an appropriate combination of contractual agreements, detailed materials tracking and recordkeeping, and auditing that:
- Due diligence has been performed on all downstream recyclers before sending material to them to ensure they have the proper capacity and capabilities to properly manage the material
- (a) The equipment or components meet the specifications of the recipient vendor, and
- (b) The recipient vendor sells the equipment or components for reuse, with their Key Functions functioning properly, and
- (c) The recipient vendor manages all residual HEW resulting from refurbishing operations in a manner that conforms to Lifespan’s management practices.
- (d) An electronics recycler need not conform to Section (c) for shipments of less than 15 units that either are going to a new vendor as a sample for purposes of evaluation of whether to purchase larger quantities for refurbishment or that are being sold with a practical return policy to an end user. This Section (d) does not apply to multiple sales or shipments within a proximate timeframe to the same entity.
- (e) An electronics recycler need not conform to the downstream CB requirements for shipments that satisfy the requirements of Section (c) or (d), or are new and in their original packaging.
- (f) An electronics recycler need not conform to the CB exporting requirements for shipments that satisfy either the CB functionality requirements or are new and in their original packaging.
- Refurbished components and equipment make their way into reuse markets, or are being sold at a price at least three times higher than the applicable prevailing scrap rate.
- No electronic waste is being exported to a non-OECD country.
- Customer data and other identifying information has been managed through chain-of-custody documentation and completely eradicated.
- Lifespan controls and tracks the destinations of Hazardous E-Wastes through the entire supply chain until reaching the End Processor or Final Disposition.
Universal Waste Management
Universal wastes (UW) are hazardous wastes that are more common and pose a lower risk to people and the environment than other hazardous wastes. Simplified regulations apply to the management of universal wastes, but none may be placed in regular trash. All universal wastes are hazardous wastes and would otherwise have to be managed under the same stringent standards as other hazardous wastes if not recycled.
Because Universal Waste laws vary from state to state and Lifespan has several facilities nationwide, the lowest common denominator will be used for management. Both Federal and State regulations identify universal waste and provide simple rules for universal waste.
Depending on the location of our facility, the following is a list of universal wastes (not inclusive): Batteries, mercury thermometers, thermostats, switches, lamps (fluorescent tubes, sodium vapor lamps), non-empty aerosol cans, consumer electronic devices, cathode ray tubes (computer monitors, televisions) and vacuum gauges (U tube manometers, barometers, sphygmomanometers). In some states whole electronic units are considered a universal waste, not just the components.
It is our intention to handle universal wastes in the following manner:
- Prohibited from disposing of any universal waste in the trash
- Prohibited from diluting or treating (other than for spills) universal waste
- Universal waste shall be managed in a way that prevents the release of the universal waste, or any component of the universal waste, to the environment.
- Lifespan stores UW indoors, in a structurally sound container
- Not accumulate universal waste for longer than one year from the date the universal waste becomes a waste or is received
- Universal waste must be shipped to another Universal Waste handler or TSDF with proper shipping documentation.
- We will train all employees on the proper handling, labeling, storage, and transport of universal wastes respective to their job requirements
Hazardous Electronic Waste (HEW) Management
Lifespan will manage – both on site and in the selection of downstream vendors – the Hazardous Electronic Waste defined in the R2 standard that passes through its facility or control in a manner protective of worker health and safety, public health, and the environment; and will perform due diligence on downstream vendors to which it ships these materials.
Hazardous electronic wastes are present in most electronic devices and must be handled more diligently than less toxic commodities. Because of this, it is important to follow and document hazardous electronic wastes all the way through the recycling chain to ensure safe final disposition. This requires contributions from all Lifespan employees as well as Lifespan partners and downstream processors. HEW can only pass through the custody of approved, audited, and documented processing facilities that operate in conformance with these policies. No HEW can be sent to any non-approved vendor.
Hazardous Electronic Waste or (HEW) are materials in end-of-life electronic equipment that warrant greater care during recycling, refurbishing, materials recovery, energy recovery, incineration, and/or disposal due to their toxicity or other potential adverse worker health and safety, public health, or environmental effects that can arise if the materials are managed without appropriate safeguards.
The following are Hazard Electronic Waste:
Items containing polychlorinated biphenyls (PCBs)
- Items containing mercury
- Circuit boards
- Fluorescent lights
- CRTs and CRT glass
- Ink and Toner cartridges
- Items with hazardous concentrations of toxic elements (those exceeding USA EPA TCLP limits)
- Radioactive material
- Items containing selenium or arsenic
- Items containing glycol-based coolants
- Items containing brominated flame retardants
Equipment, components, or materials (whole or shredded) that have undergone safe and effective mechanical processing or manual dismantling to remove HEW, yet still retain de minimus amounts of HEW, are not subject to the Certification Body (CB) requirements that are triggered by the presence of HEW.
HEW Management Plan
Lifespan will analyze and plan how the Hazardous Electronic Waste (HEW) that passes through its facility or control will be properly managed both on site and throughout the Recycling Chain. This HEW Management Plan will also be included in Lifespan’s QEHS&S and distributed to each warehouse, material tracking, downstream vendor, and reuse managers. Please refer to the ‘Downstream Account Management’ section of the QEHS&S for procedures on hiring a downstream vendor who will handle HEW.
Prior to shredding or being sent for shredding, materials recovery, energy recovery, incineration, or land disposal of equipment or components, HEW will be removed using safe and effective mechanical processing or manual dismantling, with two exceptions:
- Items containing mercury if they are too small to remove safely at reasonable cost, and workers are protected from the risks posed by the mercury during and subsequent to any processing or manual dismantling of the equipment containing it, and the equipment and components containing such items are sent to materials recovery facilities that are properly licensed to receive, and that utilize technology designed to safely and effectively manage, equipment or components containing such mercury-containing items.
- CRTs, batteries, and circuit boards contained in equipment or components destined for materials recovery need not be removed prior to shredding and/or materials recovery if the shredding and/or materials recovery occurs in facilities that are properly licensed to receive, and that utilize technology designed to safely and effectively manage, equipment or components containing these HEW.
Lifespan employees may not send ANY HEW to a ‘non-approved’ HEW recycler.
Processing, Recovery, and Treatment of HEW
Lifespan must send removed HEW to processing, recovery, or treatment facilities that are properly licensed to receive, and that utilize technology designed to safely and effectively manage the HEW. No employee shall send HEW to a downstream vendor that has not had prior approval from QEHS&S Manager and VP of Operations.
- For items containing PCBs – technology specifically designed for PCB destruction and licensed under the Toxic Substances Control Act and/or any other applicable law. Lifespan does not knowingly accept materials with PCBs. Please refer to the “Upstream Source Control” or “Unacceptable Materials” procedures of the QEHS&S MS for appropriate steps handling PCBs.
- For items containing mercury – mercury retorting. If Lifespan receives equipment with mercury, it may be removed if warehouse employees are properly trained to do so. If it is “Unacceptable Material,” then the QEHS&S Manager must be notified and Veolia or a related TSDF or appropriate HW/UW company will be contacted to properly handle the material. Please refer to the “Unacceptable Materials” procedures in QEHS&S MS for mercury items and the“Spill Kit” procedures of the QEHS&S MS.
- For leaded CRT glass. TV’s or CRTs – These materials are sent to materials recovery facilities that are properly licensed to receive, and that utilize technology designed to safely and effectively manage, equipment or components that contain leaded glass and phosphor. TV’s, CRTs and CRT glass material will be listed on the project settlement for proper tracking and disposal cost.
- These materials are sent to materials recovery facilities that are properly licensed to receive, and that utilize technology designed to safely and effectively manage, equipment or components that contain leaded glass and phosphor. Batteries will be listed on the project settlement for proper tracking and disposal costs.
- Ink, toner and toner cartridges must be recycled through an approved toner recycler unless it is not economically feasible. Please see the ‘Ink & Toner’ section of QEHS&S MS for further details
- For circuit boards – Lifespan will remove batteries and mercury and then send to an approved downstream vendor for smelting for metals recovery. Please see the “Material Handling” and “Commodity Sorting” sections for PC demanufacturing under the QEHS&S MS. For reuse items that contain circuit boards, please refer to the ‘Reuse’material handling section for guidelines on what qualifies a material as reusable.
Energy Recovery, Incineration, and Land Disposal of HEW
Lifespan will not utilize energy recovery, incineration, or land disposal as a management strategy for HEW or equipment and components containing HEW. However, if circumstances beyond the control of Lifespan disrupt its normal management of an HEW, we may consider these technologies to the extent allowed under applicable law. Before HEW is sent for energy recovery, incineration, or land disposal the QEHS&S Manager must be notified with an explanation.
Selection and Ongoing Due Diligence of Downstream Vendors for HEW
For shipments of removed HEW, and shipments of equipment and components containing HEW, Lifespan will select downstream vendors that possess and conform to:
- Lifespan’s HEW Management Plan that will be included in Lifespan’s downstream agreement.
- A documented environmental, health, and safety management system, that will be reviewed either on-site or via e-mail during Lifespan’s Downstream audit process.
- A list of its environmental permits and copies of each, that will be collected during Lifespan’s Downstream audit process.
- Whenever possible Lifespan will utilize vendors that are the final destination or first tier for HEW. When economically feasible, Lifespan will perform final destination audits for HEW if they are not sent directly to the final destination.
- Lifespan’s HEW downstream vendors will conform to the reuse practices outlined in the ‘Reuse’ section of the QEHS&S MS and under the Reuse Policy.
- Lifespan does directly not export any material internationally, and does not use any non-OECD country in the HEW recycling chain.
Lifespan will audit on an annual basis that the HEW downstream vendor in the ‘Recycling Chain’ are conforming to the HEW Management Plan as stated above. This applies for as long as the vendor receives HEW directly from Lifespan.