Dynamic ITAD Requires Guidance, Diligence and Leadership – Avoiding Negative Consequences from Electronic Disposal

By Patty Osterberg, SERI

What happens to your decommissioned IT equipment after it leaves your company?

Your company’s brand, reputation and bottom line could depend on your answer to this question. Almost weekly, another company is featured in the press for a data security breach. Big and small companies alike have suffered the fallout from this type of negative publicity. Some are the victims of determined hackers – others the victims of opportunists with direct access to decommissioned company hardware. The damage to your brand, reputation and bottom line from a data breach is impossible to fully calculate.

Do No Harm

Inadequately vetting an electronics broker or recycler can have consequences that reach beyond data security. Over the past two decades, the improper (and sometimes illegal) disposal of used electronic equipment has caused devastating harm to the health and safety of workers, communities, and the environment. Businesses are now under greater scrutiny to ensure decommissioned IT assets are managed in a way that does not harm workers or the environment.

As a result, a growing number of companies and organizations are enacting policies that require retired IT assets to be directed exclusively to R2 Certified IT asset disposition (ITAD) vendors as a way of reducing their exposure to environmental and data security liability. All U.S. Federal agencies, as well as some state and local agencies, have requirements that they use certified ITAD vendors. Why the growing trend towards R2 Certified vendors? Because the R2 certified mark proves that a prospective broker or recycler has successfully passed rigorous annual audits by a third party Certifying Body and conforms to the requirements of the R2 Standard.

The R2 Saga

The R2 Standard was developed in response to a growing awareness of the need for best management practices and accountability in the electronics reuse and recycling industry. About 10 years ago, the U.S. EPA convened a multi-stakeholder group made up of leaders from the electronics reuse and recycling industries, original equipment manufacturers, environmental organizations, and others who with a strong desire to improve the industry. John Lingelbach (who currently serves as Executive Director of SERI, the non-profit governing body for the R2 Standard) was enlisted by the EPA to facilitate the group, which was tasked with identifying best practices for the health and safety of workers and the environment.

The result of this collaborative effort came to be known as the R2 (“Responsible Recycling”) Standard, the most respected global standard for electronics brokers, refurbishers and recyclers. R2 Certified facilities now operate in 19 countries with more soon to follow.

Over time and with the complexities of the worldwide issues, the R2 Standard is scrutinized and updated frequently by SERI’s Technical Advisory Committee. To advance SERI’s mission of safe and sustainable reuse and recycling worldwide, SERI also recognizes and works with R2-committed companies through the R2 Leaders Program. Companies such as Sony, Oracle, and Microsoft have joined and agreed to take on projects that further the mission. Project activities include informational campaigns directed at college students, advice to industry providers and education to aid in the development of reuse and recycling.

The Role of the R2 Standard

The R2 Standard places significant emphasis on due diligence and chain of custody. In the US, this is particularly noteworthy in light of the Comprehensive Environmental Response, Compensation & Liability Act (more commonly referred to as CERCLA or the “Superfund” law). Under this law, the government can demand cleanup costs from all companies that have contributed to environmentally hazardous situations (such as improperly dumping electronics). This means your responsibility doesn’t necessarily end when custody of electronic parts or equipment is transferred to a broker or recycler. Organizations are responsible for the safe handling of electronics throughout the entire chain of custody–potentially exposing them to liability if the broker or recycler has not been thoroughly vetted.

There are steps that companies can take to minimize their exposure to Superfund liability. The Superfund Recycling Equity Act (SREA) offers a measure of protection to companies that take reasonable care to determine the environmental compliance status of brokers or recyclers prior to shipping IT assets for recycling.

The bottom line: Properly vet all downstream vendors in the recycling chain of custody. Requiring R2 certification as a vendor requirement is a good place to start.