How is everyone recycling batteries for R2 Standards, we have some questions about how to properly label them.
If anyone has any experience doing this for R2 please point me in the right direction or email me directly if possible so we could talk about it, any help would be greatly appreciated
Thank You!
Brendan Schmolz
RET3 Job Corp.
Microsoft Registered Refurbisher
1814 East 40th St.
Cleveland, Ohio 44103
Office: 1-216-361-9991 EXT: 102
Fax: 1-216-361-9989
The above communication contains information from RET3 JOB CORP INC that may be confidential and/or privileged. Except for personal use by the intended recipient, or as expressly authorized by the sender, any person who receives this information is prohibited from disclosing, copying, distributing, and/or using it. If you have received this communication in error, please immediately delete it and all copies, and promptly notify the sender at the above telephone number or electronic mail address. Nothing in this communication is intended to operate as an electronic signature under applicable law.
Someone told me they are allowed to throw them away, is that true? Even if R2 certified?
Thanks
is this for alkaline or other types?
Thanks
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RET3 Job Corp.
Microsoft Registered Refurbisher
1814 East 40th St.
Cleveland, Ohio 44103
Office: 1-216-361-9991 EXT: 102
Fax: 1-216-361-9989
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Conformity review: battery handling part 1 -- in-house requirements
Conformity review is a monthly column highlighting important operational information concerning the R2 Standard. For the last number of months it has been written by Corey Dehmey of Momentum, Inc. Corey can be reached at CDe...@m-inc.com.
R2 Solutions last reported on batteries in February 2011. The issue of battery management still remains a common pitfall for many electronics recyclers not R2-certified. Batteries are often found co-mingled in insufficient storage containers and improperly packaged for shipment. However, with R2-certified companies the requirements of certification combined with the oversight of independent auditors are improving battery handling by the entire electronics recycling industry.
To begin, let's evaluate the scope. Batteries are referenced as Focus Materials (FMs) throughout the R2 Standard. R2 does not distinguish between types of batteries. All batteries are FMs, including alkaline batteries. At the highest level in the organization, batteries must follow the hierarchy of reuse, recover in planning operational flows. However, batteries cannot be directed to energy recovery, incineration, or landfill in accordance with Provision 5(d) for Focus Materials unless it is an exceptional situation, such as a spill cleanup.
Planning for battery management should be found in the EH&S Management System (EHSMS). Evidence of battery planning will be referenced in the environmental, health and safety hazard and impact assessments. It will be referenced specifically in emergency plans in accordance with Provision 4(h) including plans for spill response, fire, and exceptional releases. The EHSMS will have documented procedures for handling of batteries, as well as monitoring activities to ensure conformance to the plans and compliance with all legal requirements.
The legal requirements of battery handling will be addressed in the legal compliance plan required under Provision 3. This plan will address rules and regulations at all levels of government. In the United States, this should include, for example, CERCLE, SREA, RCRA, and in California Title 22 Chapter 23. It will also include Department of Transportation regulations under 49 CFR 171-180 when batteries are transported.
Transportation is of particular concern. Often recyclers do not identify this as a legal requirement. In reality, if a business is offering batteries for someone else to transport, the recycler usually must document training of the hazardous materials regulations for its shipping employees. Depending on the classification of the battery material, it may require hazardous endorsements. Futhermore, R2 Provision 12 as well as legal requirements require only qualified transporters with proven safety records.
Another common mistake of recyclers is the mishandling of batteries within the recyclers' facilities. Specific attention to labeling, accumulation times, and packaging are important in ensuring legal compliance. In addition, it is important in mitigating the environmental risks of spills and fires. Documented procedures and training in these areas will ensure appropriate responses to these exceptional situations. Inappropriate responses tend to compound the issues. Finally, the safety of employees is an important benefit of proper battery handling. This may be as simple as providing personal protective equipment (PPE) such as a face shields and gloves for protection from the wet acid in some batteries.
In the next R2 Update we will continue the discussion of battery handling and look at the impacts of downstream processing and due diligence. |
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