BLOG: Standards are the backbone of WEEE Recycling but should be industry-wide

   Fri, 10th Sep, 2021

In our September blog, Managing Director of KMK Metals Recycling, Kurt Kyck, reflects on the many high industry standards that the company has sought to achieve and retain, and the benefits they bring to the business, while also lamenting the lack of binding standards across the European Union.

As leaders in the electronics and metals recycling industry in Ireland, KMK Metals Recycling are constantly reflecting on our current practices and looking towards the future to determine what will be required to demonstrate leadership in how companies should sustainably operate. We believe that the internationally recognised industry standards we achieve are what set us apart, and provide quality and assurance for our customers, contractors, employees and environment.

A standard is defined as something used as a measure, norm, or model in comparative evaluations. In a global industry like WEEE recycling, a system of checks and balances is needed to maintain quality and consistency and to ensure that all businesses are operating on equal footing. Standards can also help businesses build customer confidence, meet regulation requirements, reduce costs and gain market access across the world.

In terms of quality, we have achieved the ISO 9001:2015 certification which, like all of our ISO standards, is evaluated annually by the National Standards Authority of Ireland (NSAI). We ensure that all business activities within the company, whether it is the processing of materials or overseas export, are performed and handled in a professional and efficient manner.

The Plan, Do, Check, Act (PDCA) cycle and risk-based thinking related to the quality management system allow us to ensure that our processes are adequately resourced and managed, and that opportunities for improvement are determined and acted on.

Protecting the environment is a core part of our business model and extremely important to us and to our reputation. KMK Metals Recycling holds two industrial emissions licences at Tullamore, Co. Offaly and Kilbeggan, Co. Westmeath. The Tullamore licence, held since 2001, is currently in its fourth revision. The Kilbeggan licence, granted in November 2020, brings the company's total waste acceptance capacity up to 85,000 tonnes of metals, WEEE and battery waste per annum.

We are proud to have maintained ISO 14001:2015 certification since receiving our first EPA licence for our Tullamore facility in 2001. This environmental standard should be mandatory for all waste management companies. Many of our customers and other organisations we work with, have adopted this standard as a means of measuring their impact on society.

The people who make up KMK Metals Recycling – our employees and partners – are what drives the success of the business and therefore we strive to create a working environment in which they can operate without accidents or illness.

Occupational Health and Safety standards help us maintain consistent, high-quality productivity, having obtained the ISO 45001:2018 certification after having maintained OHSAS 18001:2007 since 2011. The more recent standard places a stronger emphasis on commitment from top level management to actively incorporate health and safety into the overall management system of the organisation. It puts stronger emphasis on participation and consultation with staff, which is achieved through in-house training, consultation with trained safety representatives and participation from key members of staff when completing risk assessments and it puts greater focus on objectives as drivers for improvements and assessing performance.

KMK Metals Recycling is highly regulated through the requirements of being an EPA IED licenced facility. We must also operate in compliance with the requirements of several other authorisations and certifications. These include our Waste Collection Permit, Broker/Dealer Registrations, ISO 9001:2015, ISO 14001:2015, ISO 45001:2018 and WEEELABEX certification.

Earlier this year, we became Ireland's first and only 'Type 3' WEEELABEX-Certified Treatment Operator. WEEELABEX (the ‘WEEE Label of Excellence’) is a series of comprehensive European standards that detail requirements on all aspects surrounding the treatment of waste electrical and electronic equipment (WEEE). In fact, we became the first company in Ireland to attain WEEELABEX attestation in 2014, setting the standard for compliant WEEE treatment in Ireland and measuring our performance against our peers in Europe.

The standards we achieve are set at European level. In accordance with the requirements of the WEEE Directive (article 8.5), the European Commission requested European Standardisation Organisations (ESOs) to develop European standards for the collection, logistics and treatment, including recovery, recycling and preparing for re-use, of WEEE. This Directive has since been amended through the CENELEC EN 50625 series of standards to require WEEE facilities to comply with quality treatment standards in some member states, including Ireland. However, the absence of binding standards across the EU has distorted recycling markets, led to unfair competition and low-quality operations.

Even just looking at Ireland, while statutory Instrument SI 149 article 22 sets out that all Irish WEEE be treated to the European standard, this has not come close to being fully enforced, which again contributes to an uneven playing field for compliant companies. One of the conditions of the directive is treatment to equivalent conditions. Without standards which allow measured evaluation of comparative conditions, equivalence outside of Ireland cannot be impartially guaranteed.

We seem to keep banging the same drum, but the message needs to get across. It is vital that the WEEE industry is operating on a level-playing field. The CENELEC EN 50625 series standards do not go beyond the WEEE Directive but support the Directive by providing clear requirements for the industry. They were commended by the European Commission and already six EU member states, including Ireland, have made the standards mandatory, directly, or indirectly. An independent assurance system to ensure auditing and certification of the standards is in place, accredited by WEEELABEX, CENELEC EN 50625 and operational in over 160 WEEE treatment plants in the EU, including KMK Metals Recycling. This guarantees EU citizens the assurance that regardless if they dispose of an electrical or electronic appliance in Ballydehob or Brussels, in Estonia or central Spain that it is the responsibility of the producer to assure it will be managed and treated under equal conditions.

So, standards are used as a measure, norm, or model in comparative evaluations. We know that by living the standards in our daily work and engagement with our customers and regulators that we can be comparatively compared to best practices throughout Europe.

All the way back in 2012, in the preamble to the original WEEE Directive, the EU Commission actually forecasted an unlevel playing field and advocated for the development of minimum standards.

The purpose of this Directive is to contribute to sustainable production and consumption by, as a first priority, the prevention of WEEE and, in addition, by the re-use, recycling and other forms of recovery of such wastes so as to reduce the disposal of waste and to contribute to the efficient use of resources and the retrieval of valuable secondary raw materials. It also seeks to improve the environmental performance of all operators involved in the life cycle of EEE, e.g., producers, distributers and consumers and in particular, those operators directly involved in the collection and treatment of WEEE. In particular, different national applications of the “producer responsibility” principle may lead to substantial disparities in the financial burden on economic operators. Having different national policies on the management of WEEE hampers the effectiveness of recycling policies. For that reason, the essential criteria should be laid down at the level of the Union and minimum standards for the treatment of WEEE should be developed.

Hopefully, as we head towards the next installation of the WEEE Directive, we can start to see minimum standards being enforced as the absence of binding standards across the EU has already taken a high toll. The need to level the playing field has gone into extra time, and we now need penalties.