While the material storage requirements of R2:2013 are rooted in basic environmental, health and safety regulations in place in the US, the general principles and intent behind the regulations apply to all responsible recycling facilities, regardless of where they operate.
SERI’s key storage considerations of Provision 9:
Electronics cannot be stored outside and uncovered without appropriate storm water controls, which is consistent with most general storm water regulations. Materials that come in contact with rain or snow run the risk of mixing with storm water runoff and contaminating soil and water. In the US, most recyclers are required to manage storm water runoff based solely on their SIC code 5093. All recyclers are typically required to submit a No Exposure Certification to their respective state regulatory agency at the very least, even if all materials are stored inside. Best practices worldwide are to keep electronics sheltered from weather conditions, usually indoors, or at minimum, under an overhead shelter. This includes cover for roll-off containers usually containing recovered metals.
All containers and storage areas must be clearly labeled to identify contents. It is best practice to identify the status of the material, such as distinguishing between unprocessed equipment, material for recycling, or equipment for reuse. Best practices also dictate that material should be labeled with an accumulation start date of when material was received or generated from processing.
Storage practices must meet legal requirements. In many instances, legal requirements will coincide with common best practices. For instance, broken CRTs should be stored in structurally sound containers with liners and lids. Intact mercury lamps should be stored in closed boxes or drums to contain breakage during movement or shipping. Reactive batteries such as lead acid, nickel cadmium, and lithium batteries should be taped to prevent the terminals from making contact during storage to prevent risk of fire.
Equipment and materials must be securely stored. Provision 10 of R2:2013, provides more detail on specific security issues, but in general, security begins at the perimeter with locked doors and fencing, with additional layers of security in the warehouse depending on customer requirements and the sensitivity of equipment and media handled. Restricted areas and closed circuit cameras are common security measures in most facilities.
Earlier this month SERI suspended Global Environmental Services’ R2 certification following reports that GES operated an illegal dump, using a bulldozer to bury CRTs and other electronic equipment near its facility in Georgetown, Kentucky.
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