2009 Free Geek Oregon E-Cycles Audit

Environmental, Health and Safety Compliance and Systems Audit in Response to:

Oregon Electronics Recycling Program Environmental Management Practices

Facility Audited:	Free Geek Auditor: 			Kelley Keogh Date:			February 2009

Scope of Audit This audit was designed to meet the specific requirements of the State of Oregon’s Electronics Recycling Program Environmental Management Practices qualification requirements. The Oregon State standards were interpreted and a facility checklist was prepared to meet the standard requirements that related directly to the operation. The audit consisted of confirming the nexus between the two documents and the operations. The audit preparation included an inspection by Kelley Keogh, auditor, of the Free Geek facilities in February 2009. Also present were Liane Kocko, Operations Manager and Matteo Bell, Safety Supervisor. During the visit operations were observed and EMS Programs reviewed. The facility is located in SW Portland in the urban center.

The EMS written and maintained by the company was reviewed for compliance with the requirements of the standards as well as the operations. Safety training records, downstream due diligence, packaging standards, housekeeping, records maintenance and management commitment were observed throughout the process.

Audit Summary Facility Information: 1731 SE 10th Avenue Portland, OR Size:	17,000 sq ft Years in Facility: 8 Hours: 11:00 a.m. to 7:00 pm Tues.-Sat.


 * 1) of Employees: 14-18


 * 1) of Volunteers – up to 60 per shift

The following is a summary of a comprehensive review for compliance of operations in response to State of Oregon’s Electronics Recycling Program Environmental Management Practices.

SECTION 1: RESPONSIBLE MANAGEMENT STRATEGIES Facility Maintains Compliance Auditor observed material dismantling and separation consistent with Oregon Electronics Recycling Program (OREP) ERP Environmental Management Practices (EMP’s) and hierarchy requirements. Material is minimally dismantled and sorted to maintain highest and best commodity pricing and to work towards a goal of zero residual. All downstream vendors are audited for efficiency, EHS compliance and best management practices in the industry. Residuals are managed appropriately. Free Geek’s EMS Policy requires full disclosure from all downstream vendors and they address continuous improvement through daily, weekly staff and committee meetings. All of this is documented in Free Geek’s site on Wiki.

SECTION 2: COLLECTION Facility Maintains Compliance with Section 2 2.1. Fees Free Geek agrees to follow OERP requirements regarding fees as outlined in the EMP. Auditor reviewed requirements with Liane and Matteo.

2. 2. Legal Requirements Facility maintains compliance with all legal requirements pertaining to their operations. Free Geek is primarily a refurbish/reuse organization and recycles material only when it has no parts to harvest or is too outdated to refurbish. Free Geek recycles all CED’s that are either too old or too broken to repair. Free Geek agrees to, and understands they must; notify Oregon DEQ in the event of any NOV not corrected within 30 days. Free Geek maintains compliance with federal and international export laws – they use an Oregon DEQ approved processor for their unprocessed CRT’s and their metals broker sends their material to Umicore in Belgium, an OECD country. Free Geek audits all downstream vendors to their EHS requirements - documents viewed by auditor.

2.3. Service Standards Free Geek is staffed during operating hours, CED’s stored and managed indoors, handled according to Fed UW regulations – observed on site by auditor. Good housekeeping practices were observed. Free Geek agrees to make available all information required by the DEQ and to work with DEQ on sampling efforts. Auditor reviewed requirements with Liane and Matteo.

2.4. Reuse and Refurbishment Free Geek is first and foremost a refurbish facility. Auditor has never seen such a clear and organized hierarchy to support the highest and best recovery use for used computers. Training for employees and volunteers is extensive as is oversight from support staff. Computers are all triaged with a sticker system for whether or not they are inclusive in the DEQ program at arrival to the facility. A decision making tree is used to evaluate and repair all others. Repaired computers are donated or sold either to volunteers or the public. Free Geek agrees to post information re: CED’s are screened for refurbishment. Material is currently tracked; screened and written verification is on file that material will go for reuse and reuse vendors are audited. Whole products are stored in a manner to protect their value and integrity. All observed by auditor while on site and through document review.

2.5 Recordkeeping Free Geek agrees to comply with Oregon material recovery reporting requirements and all reporting and tracking requirements required by the OERP. Current program is in compliance as required – documentation viewed by auditor. Auditor verified that documents are backed up hourly on an off-site server.

2.6 Authorizing Access Free Geek agrees to authorize access to the DEQ or third party representatives as requested.

2.7 Multiple Programs Free Geek is currently able to maintain records as requested in this requirement for the DEQ..

2.8 Insurance Auditor has verified insurance coverage and notes it is adequate to address risks and liability associated with Free Geek’s current operations.

2.9 Site Management Free Geek has significant space constraints and moves recyclable material out 2 x’s per week so as to utilize their space for refurbish, resale and education. Auditor has observed operations and based on through-put and storage available concludes that speculative accumulation is not possible with the Sq footage of building. The in-bound volume of material is too high to accumulate material for any length of time.

SECTION 3: TRANSPORTATION – Facility Maintains Compliance with Section 3 Free Geek has no trucks – material is delivered and picked up either by individuals or recycling companies. Federal DOT rules are observed as the material is UW.

SECTION 4: RECYCLING – Facility Maintains Compliance with Section 4 4.1 Legal Requirements Auditor can verify that Free Geek is compliance with all applicable regulations and export laws. Free Geek agrees to make available information regarding fines, regulatory orders or violations as required by the plan.

4.2 Environmental, Health, and Safety Management Systems Free Geek’s EMS is a working document stored on their main server. All EHS programs and policies were reviewed by the auditor and a few suggestions were made. There is a constant review process inherent in the structure of the Free Geek organization, follow up meetings make sure that items get completed. Before new systems are implemented, committees are formed and solutions and systems are created and reviewed constantly to improve and readjust if necessary. All EHS risks are evaluated. Safety training, new volunteer orientation, facility compliance with OSHA regulations has been reviewed by the auditor and found to be in compliance with Federal, State and local regulations in respect to the operation. There is nexus between the EMS plan and the operation. Free Geek’s Board and committee leaders support and are active in program. They have designated personnel hours to maintain compliance and programs.

4.3 Recordkeeping Free Geek strives to maintain paperless systems. All documentation is backed up hourly onto an off- site server. Tracking of all material is maintained as well as all BOL’s to recyclers.

4.4 On-site requirements Material is handled, packaged, labeled and stored in compliance with standards. Worker safety and training in the regulations pertaining to the industry is apparent while observing the operation. EHS training standards as part of the EMS have been reviewed by auditor and comply with industry and regulatory standards. Facility housekeeping is well maintained, materials stored and labeled appropriately. Auditor observed Materials of Concern being handled, stored and labeled in accordance with standards. Material is tracked per piece so scales are not relied upon for tracking tonnage. Workers wear and maintain PPE. The health and safety training is consistent with requirements for the operation and the facility has systems in place to ensure employee comprehension. Downstream vendors are screened and audited for approval. Auditor confirms that facility is secure from un-authorized access.

4.5 Separation of Recycling Materials Auditor observed dismantling and separation to marketable levels for the best use and highest grade of recycling. Downstream vendor audits are conducted - observed by auditor. Documentation of all material through final destination is conducted and records maintained. CRT’s are not dismantled and are sent whole to Total Reclaim, an approved Oregon DEQ Processor. IMS receives laptops (another DEQ approved Processor) and circuit boards are exported and the documentation in place viewed by auditor conforms to Fed EPA standards and international law (Basel). Auditor has been to and audited facility’s downstream vendors for materials of concerns and is familiar with the operations of all three vendors and confirms they are compliant, high end use recovery operations. Free Geek does not accumulate material and moves out shipments of recyclables 2 x’s per week.

4.6 Management of Residuals Facility waste management protocol follows state and federal guidelines as observed by auditor. No materials of concern go to landfill or incineration. Waste is managed and separated to minimize material going to landfill.

4.7 Due Diligence Downstream Free Geek keeps the down streams simple – whole CRT’s to Total Reclaim, laptops to IMS, batteries to the County HW facility, circuit boards to Hallmark refining who sends to Umicore, Belgium, an OECD country. Free Geek does do a paper review of facilities as an approval process. This is part of their EMS Policy.

4.8 Insurance Auditor has observed certificates of insurance sufficient to cover requirement as set forth in the OERM EMP

4.9 Closure Plan and Financial Responsibility Free Geek is in the process of completing their closure plan and it was reviewed with the auditor during the site visit.

4.10 Data sanitization or destruction Free Geek does data destruction to US DOD spec’s and further.

4.11 Facility Security This facility is secure from unauthorized access during operations hours by a front door screening process, volunteer sign in system and key control program for unauthorized access areas.

Findings There were no significant findings in regards to EHS compliance, compliance to the company’s EHSMS or to the Oregon DEQ’s Environmental Management Practices. Free Geeks triage system for sorting and repair is exceptional and their commitment to the re-use industry outstanding. Re-use is the highest and cleanest procedure from an environmental, health and safety standpoint within the electronics recycling hierarchy and Free Geek does an exceptional job at creating the perfect system.

The facility is well maintained and Free Geek has shown commitment to the principles and action items of the EMS. In all of the company operations, as well as document review, complete transparency was observed on behalf of the organization to the auditor and other entities as required.

Auditor Qualifications The auditor is certified by the State of WA DOE and the State of Oregon DEQ to perform electronics processor certification audits. Kelley is an auditor with the EPA sponsored R2 Responsible Practices for Electronics Processors pilot, is working with the R2 program currently on their certification process and has worked over 18 years in the recycling and waste management fields in environmental, health and safety compliance. She is the principal of Sin Fronteras, an EHS consulting firm whose main body of work is in the electronics processing and recycling fields. The State of Oregon DEQ maintains the auditor qualifications on file.