Prep for Oregon Ecycles

Collection End

 * post signs in Receiving Area which indicate to the donor that we are a reuse organization and will try to reuse their hardware donations
 * Do we need to fill this out? http://www.deq.state.or.us/lq/pubs/forms/sw/PrivateRecyclerSurvey.pdf
 * Literature for interested donors
 * who qualifies for bringing more than 7 CED's? what procedure will we use for determining this?

Recycling End (EMP's)

 * (Section 4.2) Develop, document, implement, and update at least annually an EHSMS
 * Written goals and procedures to systemically manage environmental, health, and safety matters.
 * Use a "plan, do, check, act" model that identifies environmental and health risks and requirements, implements operational controls, and provides corrective action procedures
 * Plan for responding to and reporting exceptional releases, accidents, spills, fires, explosions, and other out-of-the-ordinary events that pose risks to worker safety, public health, or the environment. Provide plan to all appropriate emergency responders.
 * Procedure for identifying and evaluating the environmental, health, and safety impacts of downstream vendors and for using this information in the selection of downstream vendors.
 * Consistency with generally recognized standards that cover environmental and worker health/safety management such as ISO 14001, the International Association of Electronics Recyclers (IAER) certification standard, or the Recycling Industry Operating Standard (RIOS), or a similarly rigorous in-house standard.


 * Ensure all workers understand and follow the portions of the EHSMS relevant to the activities they perform


 * (Section 4.4.a.4) Designate an employee or consultant to coordinate and promote workers health and safety
 * (Section 4.4.a.5) Use a certified scale to weigh CED's that are reported as recycled through the OERP

...and training for new hires and refresher courses for all employees
 * (Section 4.4.b.1) Conduct on an ongoing basis a hazards identification and assessment of occupational and environmental risks that exist or could reasonably be expected to develop at the facility. Such risks, for example, could result from sources such as emissions of and/or exposure to substances, noise, ergonomic factors, thermal stress, substandard machine guarding, cuts and abrasions, etc. The hazards identification and assessment is captured in writing and incorporated as a component of the EHSMS.


 * (Section 4.4.b.3) Use monitoring and sampling protocols to provide assurances that the practices employed are effectively and continuously managing the risks identified. This includes complying with all applicable Federal or State OSHA standards and permissible exposure limits (PELs) for sampling and/or monitoring.


 * (Section 4.5.b) Conduct due diligence, or use documented due diligence that others have performed, on each downstream vendor sent materials for recovery by obtaining a written contractual commitment, or a written certification from the vendor, or other certified documentation, such as an audit report prepared by a certified auditor, that they have verifiable records demonstrating they meet the EHSMS practices outlined in subsection 2, and are in compliance with its environmental and worker safety legal obligations.


 * (Section 4.7.a) Implement practices that establish and maintain a written record, such as shipping documents, database extracts, or other documents that identify where any CEDs, components, or materials (including materials of concern) that are recycled from the time the equipment, components, or materials leave the facility through to the point at which materials become a single material commodity suitable for final processing.
 * (Section 4.7.b) Obtain from each downstream vendor where materials and materials of concern are sent, a written contractual commitment and verifiable business records or a third-party audit, or use documented due diligence that others have performed, verifying that the downstream vendor conforms to the following practices in this document:
 * 1) Legal requirements in subsection 1.
 * 2) EHSMS in subsection 2.
 * 3) Recordkeeping in subsection 3.
 * 4) Operating practices in subsection 4.
 * 5) Separation and recycling of materials in subsection 5.
 * 6) Management of CED components and materials that are not reused or recovered in section 6.


 * (Section 4.7.c) Obtain a written statement from immediate downstream vendors where CEDs, components, materials, or materials of concern are sent that those vendors maintain written documentation of where materials go when they leave their facility in order to assure a downstream chain of documentation is in place.
 * (Section 4.7.d) Maintain access to the downstream chain of documentation through to the point at which CEDs, components, materials, and materials of concern become a material suitable for final processing and review downstream vendors’ conformity to the practices listed in b) above. Check conformity at least every two years and more frequently if changes in circumstances warrant.


 * (Section 4.9.a) Prepare and keep current a written plan for facility closure and a sufficient financial instrument (e.g. bonds, trust fund, or letter of credit) that assures proper closure of the facility and assures against abandonment of any CEDs, components, or materials at the facility.


 * is Hard Drive wiping process/procedure documented? WRITE THIS UP
 * is Hard Drive destruction process/procedure documented? WRITE THIS UP