LifeSpan’s Environmental Policy
LifeSpan’s Environmental Policy is based upon the following principles:
LifeSpan has developed, and shall document, fully implement, and review at least annually, and update as needed (e.g., as products and/or technologies change) a written Quality, Environmental, Health and Safety Management System (QEHS) that:
- Includes written goals and procedures and requires the organization to systematically manage its environmental, health, and safety matters, and
- Is based on a “Plan-Do-Check-Act” model
Senior Management (CEO and CFO) and Senior Management EHS Representative (VP Operations) will support and provide adequate resources to the QEHS. LifeSpan’s QEHS shall be managed by a designated Management Representative (Environmental Director) who has the responsibility to lead, plan, enforce, and maintain the QEHS program. The QEHS program will also be supported by the QEHS support team (Managers- sales, downstream, warehouse, logistics).
LifeSpan will manage the retirement of electronic equipment and components so as to balance financial objectives of our customers with the mitigation of reputation, environmental, and data security risks. Furthermore, LifeSpan will manage used and end-of-life electronic equipment that is consistent with a “Focus Material (FM) Management Plan” and that is based on a “reuse, recover, dispose” hierarchy of responsible management strategies.
- Reuse –LifeSpan shall take all practical steps to direct properly functioning equipment and components to reuse unless a customer directs otherwise,
- Materials Recovery – LifeSpan shall separate as appropriate, through manual dismantling and/or mechanical processing, the materials in equipment and components that are not directed to reuse and direct them to properly-equipped materials recovery facilities when technically and economically feasible.
- Energy Recovery or Disposal – LifeSpan shall direct remaining material to properly-equipped energy recovery and/or disposal facilities. LifeSpan will not utilize energy recovery, incineration, or land disposal as a management strategy for FMs or equipment and components containing FMs. However, if circumstances beyond our control disrupt its normal management of an FM, we may consider these technologies to the extent allowed under applicable law.
LifeSpan will comply with all relevant local, state, federal, and international environmental legislation and regulations. More specifically we will comply with all relevant regulations of the countries importing equipment, components, or materials containing FMs that have passed through our facility or control.
LifeSpan will package, transport, and store all materials so as to prevent release into the environment.
LifeSpan will track by project number the origin and destination of all processed materials. In addition, Lifespan will reconcile all shipping and receiving documentation in order to ensure that all in-bound quantities match outbound shipments.
LifeSpan will exclusively utilize recycling and resale facilities that contractually commit to comply with all environmental laws and FM plans. All universal waste, hazardous waste, and FM downstream facilities are audited and will be reviewed on an annual basis.
When authorized by our customers, LifeSpan may sell complete systems or electronics components when the product has been tested and confirmed to be working in its original intended purpose. If equipment does not function, it is evaluated for refurbishment and reuse value. If it is not reusable then it is demanufactured. Certification body (CB) reuse principles and LifeSpan’s Reuse Policy will be followed.
In order for LifeSpan to sustain this Environmental Policy, the requirements of the QEHS apply to all activities, equipment, raw materials, and employees.
LifeSpan’s Health and Safety Policy
LifeSpan Technology Recycling is committed to maintaining a safe and healthy work environment. LifeSpan will take all reasonable actions to safeguard the health and safety of their employees and maintain documentation to be able to show we are doing so.
LifeSpan will:
Comply with applicable Health and Safety regulations
- Manage the certification body defined focus materials that pass through our facility or control in a manner protective of worker health and safety, public health and the environment;
- Prevent workplace injuries by providing a safe environment for employees, contractors, visitors, volunteer workers, temporary workers and anyone else performing activities under our direction;
- Investigate any workplace accidents, illnesses and near-misses, and promptly correct any unsafe condition or practice,
- Annually perform Hazard Assessments on our facilities
- Once identified, minimize (or eliminate) hazards in the workplace. Furthermore, we will perform corrective actions within a reasonable and time appropriate manner
- Provide clear access to injury statistics, MSDS, regulatory requirements and other QEHS documents to all employees
- Provide source control so upstream shipments are packaged safely, and without unknown wastes or are rejected
Safe work environments do not occur without thoughtful attention by all employees. Managers, supervisors, and employees all share the same responsibility of maintaining a safe and healthy work environment. Every LifeSpan employee is encouraged and required to be proactive in supporting this policy.
QEH&S Policy with Certification Body (CB) Requirements
The nature of LifeSpan Technology Recycling’s operations has a positive impact on the environment through the conservation of metals, plastic and other non-renewable resources and the proper management of used and end-of-life electronic equipment. Consistent with these core operations, it is LifeSpan Technology Recycling’s overall goal to accomplish its business objectives while striving for an injury-free workplace, minimizing pollution, and providing quality products to our customers.
It is our intention to:
- Develop and maintain quality, environmental, health & safety and security programs that conform to the best practices within the scrap and electronics recycling industry;
- Comply with all relevant environmental, health & safety laws and regulations, including federal, state and local and other requirements;
- Comply with all relevant regulations of the countries importing equipment, components, or materials containing FMs that have passed through our facility or control;
- Comply with customer and product requirements and industry guidelines, including the Responsible Recycling (R2) and E-Stewards practices;
- Manage used and end-of-life electronics equipment, components and materials based on a hierarchy of first, reuse/refurbish; second, materials recovery; and finally, energy recovery/disposal;
- Manage CB focus materials that pass through our facility or control in a manner protective of worker health and safety, public health and the environment;
- Prevent workplace injuries by providing a safe environment for employees, contractors, visitors, volunteer workers, temporary workers and anyone else performing activities under our direction;
- Investigate any workplace accidents, illnesses and near-misses, and promptly correct any unsafe condition or practice,
- Promote prevention of pollution in all of our operations, including the elimination of electronics waste from landfills;
- Work with our entire recycling chain including downstream vendors, suppliers, customers and contractors to fulfill our environmental, health & safety goals; and
- Continually improve our quality, environmental, and health & safety programs and resulting performance.
We recognize that the responsibilities for quality, environment, health & safety and security are shared, requiring cooperation, not only between employees and their supervisors, but among and between all those who assume the various roles within the company.
LifeSpan Technology Recycling will continually improve its QEH&S system and performance. This will include the setting of QEH&S goals, taking into consideration our QEH&S footprint and our business, financial, operational and legal requirements as well as the views of interested parties.
