Back to: SRI Online Training on E-Waste Management

 

 

Tools and Techniques

In this module, we’ll be focusing on the final part of the Standardisation and Conformity Assessment. Here, we’ll dive deeper into Tools and instruments, Audit techniques and Code of conducts within the e-Waste management sector.

Procedures

  • Clarification of audit scope and brief
  • Pre-audit mooting with auditoo
  • Second pre-audit meeting to clarify points and logistics (optional)
  • Audit team meeting (optional)
  • Audit
    • Opening mooting
    • Site tour
    • Questioning, documentation review, consolidation of findings
    • Exit mooting
  • Draft Audit report
  • Final Audit report
  • Audit findings Action Plans
  • Next audit

Structure of the audit protocol

Random checks

Document review

Site tour

Photographs

Interviews

Specific notes

Sampling

Techniques for auditing WEEE recycling companies

Office part

Verification method Audit of WEEE recycling companies
Review of documents/records
  • Verification of documentation: complete? plausible? up to date? well illustrated?
  • Includes: permits / authorizations, SOPs, material flow documentation, delivery notes, export documents, contracts, guidelines, quality and safety management manual, health and safety certificates, chemical analysis results, training, correspondence, photos, etc.
Interviews
  • Clear questions
  • The questions in the checklist are questions to the auditor! Questions need to be reformulated.
  • Interviews with employees during plant tour

Site tour

Verification method Audit of WEEE recycling companies
Observations
  • Guiding question: What does the company process and what needs to be looked at/considered?
  • Walk through the material flow: Receiving, handling, storage, storage, processing, delivery) and focus on critical materials and flows
  • Visual check of incoming material, containers, workplaces, material feed, vehicles, conveyors, quality of intermediate and outgoing fractions (hazardous/non-hazardous), storage of hazardous waste
  • Ask to see what has not been shown
  • Verify the use of PPE according to activities
  • Verify emergency exits, signs, accessibility
  • etc…
Random checks/sample
collection
  • Visit to the surroundings and additional facilities (material scale, radioactivity measurement, etc.)
  • Look behind the curtains!
  • Storage and labeling of problematic fractions
  • Quality of disassembly and separation of fractions
  • Occasionally on-site measurements (e.g., of mercury)
Photographs
  • Documentation of good and bad practices (deviations from the N&S)
  • No pictures of faces of people
Specific notes
  • Additional Information
  • Bring paper and pen to write down things you may ask later, etc.
  • Outside of the checklist: Specific comments or statements

Interrogation techniques

  • The audit protocol is a tool for auditors for a structured, complete and common audit procedure.
  • The questions to the auditee shall be formulated differently from the question asked in the protocol and shall invite the auditee to provide information and a description based on which the auditor can assess compliance with the N&S

Example:

  • Question in the audit protocol:
    (4.1.3.1) Are temperature exchange equipment stored and transported upright and adequately protected?

  • Question to the manager:
    How are temperature exchange equipment stored and transported?
  • Ask mostly open-ended rather than closed-ended questions.
  • Auditors should be persistent in asking questions and reflect critically on the answers given by the auditee. If the answer is vague, follow up with a follow-up question.
  • Questions in the protocol that are not related to the documents, but need to be assessed during the site visit, should be marked in advance in the checklist and asked during the site visit.

Example:

  • Protocol question: (4.1.2.3) Is storage of not fully decontaminated WEEE protected from weather either under a roof or by using a weatherproof covering?
  • Question to the manager: Based on which criteria do you know that WEEE is not fully decontaminated?
  • Manager’s reply: We separate hazardous and non-hazardous electronic waste.
  • Supplementary question to the manager: How do you distinguish between these two categories?
  • Manager’s reply: We separate them according to our QMS SOP.
  • Follow-up question to the manager: … And where is this SOP? … What is the basis for this distinction? … … Is this SOP available in the reception area? Is it known to the workers? … etc. ….

Site visit

  • Normally, the auditee guides the plant tour and usually shows the good things and does not put the spotlight on what they think is not so good. To identify minor or critical deviations, it is important to move around the facility at some point quite independently (with the company’s consent, of course).
  • Prohibited activities should not be asked during the office portion of the audit but should be checked during the site visit.

Example:
The auditor sees a closed drum in the storage area that was not shown by the manager during the site visit. The auditor should ask the auditee, “Can you open this barrel?”

Example:
Protocol question: (4.1.1.1) “Are all facilities and collection setups suitable for all types of WEEE received and stored and do they provide adequate consolidation and storage space?”

Questions during the tour at the plant (in the reception area):

  • What types of WEEE can you receive under your permit?
  • Based on which criteria do you differentiate in storing the different types of WEEE?
  • Can I have a look at your storage area?

Proof of proper downstream treatment

Revision the output documentation

  • Which fractions are registered? Do they match with the incoming devices and materials?
  • Where are the fractions sent to?
  • Is there a clear indication of the recipient (name of company, address)?
  • Is it a dealer or a processing company?
  • Does the processing company have the necessary >authorizations and technologies to treat the fraction?
  • Does the recycler know what happens to his fractions in the downstream operation

Code of conduct

The Code of Conduct provides specific rules and guidelines governing individuals’ actions within an organisation, often addressing compliance with laws and organisational policies.

Key elements of a Code of Conduct include:

Integrity

Importance of honesty and ethical behaviour in all actions.

Objectivity

Requires individuals to maintain impartiality and avoid conflicts of interest.

Confidentiality

Need to protect sensitive information and not disclose it without propser authorisation.

Competence

Ensures that individuals possess the necessary skills and knowledge to perform their duties.

Professionalism

Encourages adherence to high standards of conduct and respect the laws and regulations.

Accountability

Individuals are held responsible for their actions and decisions.

Respect

Promotes a culture of respect among colleages, clients, and stakeholders.

Global examples: Different Set-ups of conformity assessments systems

Further reading

For additional context, we have included an optional PDF with further reading. 

Access it here