Audit of recyclers: approach and method
Recycling partners in the SENS and Swico take-back systems are contractually obliged to comply with certain technical requirements. How do SENS and Swico ensure that these technical requirements are met? Mainly through audits and batch tests conducted by auditors from the SENS and Swico Technical Commission. How are these audits actually carried out, and what standards do they use? How can we ensure that all recyclers are assessed equally when it comes to their implementation of requirements? What checks are carried out upstream of the chain, in particular at dismantling facilities, and at downstream operators abroad? This article aims to answer these questions, which are frequently put to auditors by the various parties in the recycling industry.
What audit standards are used?
The assessments carried out at recyclers are based on the CENELEC SN EN 50625 series of European standards, which define the requirements for recycling waste electrical and electronic equipment at the main stages of processing (collection, manual processing, mechanical processing, final processing, etc.). They are also based on the supplementary technical regulations ofSENS and Swico. This document, which is included as an appendix to the recyclers’ contracts, supplements the European requirements with Swiss specifications, such as the recycling rates to be achieved.
The audits are also based on the relevant Swiss legal requirements. However, although several areas of law are discussed (water management, noise management, etc.), the duration of the audit does not enable all the environmental legislation to be covered systematically: the audit focuses on waste management. Alongside the audit commissioned by SENS and Swico, the cantons remain responsible for monitoring recyclers’ compliance with applicable law.
Who audits the recyclers?
The audits are conducted by auditors mandated by the take-back systems SENS/Swico and who are members of the Technical Commission: for SENS, they are people working for the companies Abeco Sàrl, Büro für Umweltchemie GmbH, Carbotech AG and IPSO ECO AG, and for Swico, DSS+. Each year, the recyclers due to be audited are allocated to the members of the Technical Committee based on a number of criteria: specific knowledge of certain topics such as the recycling of lighting equipment, geographical proximity, and so on.
How do the auditors coordinate their work?
Each recycler has its own characteristics. To ensure that recyclers are treated as fairly as possible, auditors hold regular discussions with each other. At least four meetings with the SENS/Swico Technical Commission are planned per year. In addition, regular progress briefings are scheduled internally at SENS and Swico. These meetings, along with various topic-specific working groups as well as informal exchanges, help to harmonise audit practices.
What elements are checked during a recycler audit?
A number of elements, which are listed in the audit protocol, are used to check compliance with the requirements, in particular:
- Holding discussions with the team, for example regarding the management system, training, or internal quality control of sorting and processing
- Checking documents: for example, tracking documents relating to the transport of special waste in Switzerland as well as notifications and tracking slips for exported waste all make it possible to check the receivers and distribution channels, the conformity of the codes used, and the quantities declared
- Verifying the annual declarations of material flows: a check ensures that all of the expected fractions are declared, and in quantities that correspond to the usual values. The absence of a fraction may be an error in classification when declarations were made, or may reveal an error in sorting the fraction
- Verifying laboratory analyses (metal losses, quantities of pollutants), and
- Visiting plants: this helps to confirm the consistency between the elements discussed with the team during the audit and the reality on the site.
Furthermore, batch testing enables recycling and recovery rates to be calculated, and also complements the data collected during the audit.
Are the other parties in the chain – upstream and downstream – also audited?
Recyclers are audited every year. Other parties are also audited, but at different intervals. The upstream partners, the dismantling facilities, are audited every two years. The requirements applicable to the facilities are the same as for recyclers (same standards). However, when it comes to pollutant removal, the recycler managing the workshop decides at which stage the depollution will be carried out. For example, oil radiators must be emptied before shredding, but the recycler can decide whether to have them emptied by the dismantling facility, or just once the radiator has arrived at the recycler’s premises.
Downstream partners, such as the recipients of the fractions leaving the recycler, are also audited. Inspections are mainly carried out at acceptors that perform additional separation, such as plastics recyclers or at those that separate plastics from non-ferrous metals. These inspections are sometimes conducted as part of batch processes carried out at downstream treatment operators.
As a result, these audits help to guarantee high environmental quality recycling throughout the chain.