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REFURBISHMENT & DISPOSAL - Implementation of Key Directives & Legislation

The WEEE Directive
ROHS Directive
Environmental Protection act 1990 and Environemt act
Other key UK Legislation
MIT Compliance
Quality Policy
MIT Environmental Policy Statement


As part of the UK Government measures to conform to EU environmental directives manufacturers, producers, local authorities, recyclers, retailers, businesses and end users alike will be required to conform to a number of environmental targets relating to two pieces of legislation, the WEEE (Waste Of Electric and Electrical Equipment) and ROHS (Restriction Of Hazardous Substances) directives. However, the current question is will all those affected have the required infrastructure in place to meet the deadline and the subsequent recycling targets? MIT is currently working with many leading UK corporate organisations to advise on and provide such an infrastructure!

The WEEE Directive

Initially required to be transposed into UK law in August 2005 this has now been delayed due to further consultation of businesses by the UK Government with a new schedule for early 2006. Even so this still leaves little time to prepare for such a major change to industry practices.

The key aim of the WEEE Directive is to reduce electrical waste, increase recovery and recycling, minimise environmental impact and improve the environmental performance of all operators involved in the life-cycle of EEE (Electrical & Electronic Equipment). There are currently 10 indicative categories: large household, small household, IT and telecoms, consumer equipment, lighting equipment, electrical and electronic tools, toys, leisure & sports, medical devices, monitoring and Auto disposal.

Within the conditions of the WEEE Directive, the cost of collecting, re-using, recycling and disposing of electrical and electronic equipment and the need to ensure they do not contain banned materials will be the producer’s responsibility. It does not however mean that they alone must comply with the requirements of the legislation, but so must all (of your) commercial customers and suppliers involved. It will be the responsibility of the producer to ensure that compliance is met for all products that they make, supply or sell.

Currently the UK Government is in a period of consultation with businesses that will be affected by the implementing of the WEEE and ROHS directives, (For details on the ROHS directive please see 2.2). Responses to this consultation are now posted on the UK Goverment's website, https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/34623/12-1167-restriction-of-hazardous-substances-regulations-guidance.pdf.

It is currently estimated that the cost of implementing the WEEE Directive to the UK economy is expected to be £217 - £455 million per annum. The European Commission estimates this will lead to an average cost increase of between 1% and 2% for most WEEE products and 3% to 4% for a few large/ complex products.

From the consultations that have taken place there are still a number of questions that need to be answered and which MIT is implementing strategies to ensure our customer not only comply to the WEEE Directive, and other legislative requirements, but also minimise costs whilst still maximising revenue opportunities from remarketing.

Question 1– How will organisations provide the appropriate information to limit recycling cost to a minimum? How will they pay for the recycling cost they are liable for?

Though the WEEE directive primarily passes the recycling cost to “producers” and “retailers” for old equipment being replaced by new, corporate organisations will potentially still be liable for a proportion of the recycling cost of historical waste that is not being replaced.

MIT is able to provide our customers with full management reporting and work with them to ensure all equipment replaced is accounted for.

Question 2 – How can organisations find the correct balance between utilising producer sponsored clearing houses and still being able to realise a revenue return for their end of use equipment?

Within the UK producers are looking to create a number of “clearing houses” to process end of use electrical equipment. Though this will mean that organisations will be able to arrange for the collection of equipment, it must be remembered that these bodies will represent the interests of the relevant producers NOT the end business that actually owns the equipment. Within the WEEE Directive the EU and UK Government are setting targets for recycling and considering separate target for reuse. In line with this producers are likely to utilise agents to remarket equipment processed through their clearing houses, if this is the case then any positive revenue will not be forwarded back to the business that owned the equipment. Though clearing houses offer a direct route they do not allow organisations to realise any revenue return for equipment remarketed.

If equipment is authorised as “End Of Use” by a customer of MIT this does not necessarily mean that others cannot find a use for it and therefore revenue maybe gained for its purchase. The challenge is to fully understand what product can be processed in this way, what condition it is in and finding the right markets / avenues to exploit its potential to the full.

When equipment has been delivered to MIT and booked in a series of audit and functionality tests will be carried out capturing asset and customer specific information. Such tests including product details; license verification configuration, cosmetic condition, and repair recommendations. Once completed, these tests provide MIT and our customers with a consolidated view of each item and whether it should be redeployed or remarketed. For equipment to be remarketed this information also gives us all the information to find the best revenue route available within our extensive network of resale customers. Only equipment that cannot be redeployed or remarketed will be sent for final disposal / clearing houses.

Question 3 - How are organisations to manage their redundant IT before producer collection efficiently, with minimal cost and in compliance with all applicable business and other environmental legislation?

With multiple suppliers products across many categories of equipment this management could become extremely resource heavy. In addition, how will this resource ensure that equipment is erased of its data?

MIT provides our customers with a complete portfolio of Disposal & Redeployment Services, covering all types of IT equipment – including servers, desktops, laptops, monitors, printers, fax machines, audio visual, video conferencing, telecom and communications. Through automated decision-making we are able to process equipment in the most cost effective and efficient manner.

MIT guarantees that the processes we provide our customers conform to all current and anticipated UK / EU legislation governing the refurbishment and disposal of IT equipment.


ROHS Directive

Required to be transposed into UK law by 1st July 2006, the ROHS (Restriction Of Hazardous Waste) Directive compliments the WEEE Directive by seeking to reduce its environmental impact through restricting the use of certain hazardous substances during manufacture and restricting the disposal routes available for such substances. The result of this directive to end users and businesses will be the banning of substances from common disposal routes such as landfill.

In line with the ROHS Directive, MIT is already promoting services to its customers encouraging maximum re-use and recycling with minimal final disposal / landfill. Our solution ensures that all substances are processed through the correct routes to show environmental conformance and prevent penalties.


Environmental Protection act 1990 and Environemt act

To prevent the pollution from emissions to air, land or water from scheduled processes the concept of integrated pollution control was introduced through the Environmental Protection Act 1990. This Act ensures that all bodies operating within the waste stream must obtain authorisation in the form of licences to operate the relevant processes. Examples of such licences include:

Waste Management Licence: Every site though out the UK that receives waste in any form must hold or be formally exempt from holding a Waste Management Licence. These licences are issued by the Environment Agency. The Environment agency also inspects and reports on all licensed sites at regular intervals. It is the responsibility of the Producer of the waste to ensure their waste is being delivered only to licensed sites. MIT’s Final Disposal Partner holds a Full Waste Management Licence for both controlled and special waste. The current licence was issued on 22nd March 2001 and to date our operational record is unblemished.

Waste Carriers Licence : Every carrier of waste through out the UK must hold a Carriers Licence. This allows the supplier of the waste to be sure that the waste being transported is being carried out by a haulier that meets the standards as set out by the issuing authority. It also ensures the supplier meets his Duty of Care.

After clarification with the Environmental Agency, it has been agreed that MIT does not itself require a waste management licence for the solution we provide our customers, as the equipment received is often refurbished or remarketed and therefore cannot be defined as waste at the time of receipt. Any equipment sent for final disposal is done so through partners that carry all required waste transportation and processing licenses.

A.D.R Approval : The transportation of regulated hazardous substances (special waste) requires drivers to hold the A.D.R Vocational training certificate. Drivers holding this qualification will have been trained in classification of hazardous goods, documentation, vehicle markings, emergency actions, personal safety, fire extinguishers and emergencies. All drivers of our Final Disposal Partner are A.D.R. qualified.

In addition to licence approval, Environmental Protection Act also places a 'Duty Of Care' on all bodies involved in the management of waste, be it collecting, disposing or treating Controlled Waste which is subject to licensing. All such bodies must ensure that they audit, approve and utilise only those bodies that conform to such a duty of care. Under this Act passing ownership to a third party does not remove responsibility to ensure disposal is carried out properly.

Within the solution provided MIT will achieve this through 100% asset tracking of all equipment processed for disposal or redeployment. All actions and services will be recorded against an individual barcode for each item. No item is allowed to leave MIT’s warehouse until all specified services, e.g. hard drive erasure, have been carried out and once despatched such product will only supplied to organisations with sound environmental policies, audited under strict ISO quality procedures. A Certificate of Destruction / Duty Of Care will be supplied upon completion of the Disposal process.


Other key UK Legislation

In addition to environmental directives being implemented there are a number of current UK legislative requirements. These are detailed below:

(i) Data Protection Act

Data Security along with environmental issues is potentially the major concerns for customers of MIT in the entire disposal process. The Data Protection Act 1998 requires that appropriate security measures are in place to safeguard against unauthorised or unlawful access/processing of personal data. The Act also places very clear demands upon organisations that hold personal data in terms of the security that must be applied to protect it.

As stated previously, MIT recognises the importance of data security for our customers. The removal of data from highly sensitive environments demands high levels of security, both physical and electronic. Commercially sensitive information and obligations under the Data Protection Act 1998 are safeguarded MIT through the use of specialist data erasure software. Through multiple levels of erasure are solution is able to remove irretrievably all data from hard disk drives to standards that meet the requirements of the UK Government, UK Ministry of Defence and NATO.

If a hard drive is inaccessible for any technical reason MIT securely destroys and disposes of in line with current UK and EEC regulations. MIT guarantees the security of all our customers’ data and a certificate is provided upon completion of the Disposal process to further confirm this.
(ii) Packaging & Packaging Waste Act

Responsible for around one-sixth of EU-12 packaging, the UK the Packaging & Packaging Waste Act administers how packaging is placed on the market and how it is disposed of, whether it is used or released at industrial, commercial, office, shop, service, household or any other level, regardless of the material used. Currently in a period of amendment it is believed that the essential requirements of this packaging directive will be enforced more stringently. To prove compliance, all bodies involved in the re-use / disposal of packaging will need to provide data on packaging and packaging waste.

Within the processes MIT provides its customers it vigorously encourages the recycling and re-use of packaging. Any packaging requiring final disposal is processed in accordance to current and anticipated requirements of the Packaging and Packaging Waste Act.


MIT Compliance

MIT guarantees that the processes we provide our customers conforms to all current and anticipated UK / EU legislation governing the Disposal & Redeployment of IT equipment. ALL MIT processes, personnel and subcontractors are managed to ensure compliance with all relevant ISO standards, environmental and legislative requirements where applicable. These include ISO 2000:9000, ISO 14001, Health & Safety, Data Protection Act, Packaging & Packaging Waste Act, Environmental Act, Waste Carriage & processing licence requirements and forth coming UK / EU environmental directives – WEEE Directive (Waste Of Electronic & Electrical Equipment) and ROHS (Restriction Of Hazardous Substances).

Currently within the UK there is no official WEEE directive compliance certificate and final agreement on what data will be required by the UK Government in this area is yet to be finalised. MIT has, however, been working proactively with leading environmental bodies to ensure that as far as possible our processing system already includes the expected data capture necessary to show what recycling rate has been achieved and prove that all actions have been carried out in a proper manner. In addition, MIT also incorporates the flexibility necessary within our processing systems required to make any enhancements as and when necessary in the future.


Quality Policy

MIT has succeeded to date by concentrating on providing high quality product coupled with excellent customer service. Through applying this principle throughout the business we are able to provide our customers with the best available in networking and systems equipment. Indeed, it is our objective to have the best quality of service in the business. We recognise the high standards demanded by our customers and that these will increase further as our market continues to develop. Therefore, we believe that by enhancing our sourcing and supply and continuously improving the quality of our service we will continue to meet our customers’ expectations and requirements. The continuous improvement we are committed to, happens best when everyone in the business plays an active role. As a team we set objectives for improving quality and measure our performance against these. Therefore, everyone associated with MIT is encouraged to identify areas where we may fall short of our goals and make suggestions for improving the business and its systems. To assist in achieving continuous improvement, we operate a quality assurance system that gives us mechanisms for alerting us to any weaknesses in our business and taking action to overcome them. This is based on the ISO 9001 standard and is subject to regular outside scrutiny. In an increasingly competitive world we see that for MIT to continue to succeed our philosophy of quality first is key (essential).

Sheila Moore
January 2014


MIT Environmental Policy Statement

MIT recognises it’s obligations under legislation and our industry codes to minimise the impact on the environment of our operations and products we supply. Furthermore it is our policy to not only meet such obligations but also to take all practical steps to reduce our “environmental impact” and prevent pollution of the environment, whilst conserving resources. In support of this policy we will seek ways to reduce the impact of what we do by, reducing waste and energy consumption in all aspects of the business. We will examine all aspects of the business from initial sourcing to final disposal of machines and components at the end of their useful life. We will determine where renewable resources can be employed, where energy savings can be achieved and where waste reduction can be influenced, then work to introduce steps to carry this out. We will monitor our environmental impacts and the effectiveness of reducing these through the steps we take Wherever practical we will encourage our suppliers, customers and staff to join with us in reducing the effect we all have on the environment. It is our firm belief that stewardship of the environment rests with us all and that we should all play our part in ensuring future sustainability.

Sheila Moore
January 2014

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