What Are RIOS and EHSMS and How Do they Inter-Relate?
R2:2013 requires that electronics recyclers possess and use an Environmental, Health and Safety Management System (EHSMS) and that the management system be certified to an accredited management system standard (e.g., RIOS or a combination of both ISO 14001 and OHSAS 18001). The ISO and OHSAS certification bodies lack a single standard appropriate to fully certify an EHSMS at an electronics recycling facility. The Institute of Scrap Recycling Industries (“ISRI”) responded by developing the Recycling Industry Operating Standards (“RIOS”), which incorporate the industry-relevant EHSMS elements found in the ISO 9001 (quality), ISO 14001 (environment) and OHSAS 18001 (health and safety) standards, while eliminating the overlap that would occur if all three standards were adopted. The RIOS standard is based on the plan-check-do-act model for continual improvement that forms the basis of the ISO 9001 standard. Rather than incorporate parts of three different standards, scrap recyclers save time and money by adopting the single RIOS standard. R2:2013 has approved RIOS to certify EHSMS for purposes of its R2:2013 Standard.
The Standard requires all recycling facilities to abide by applicable health and safety laws. This includes implementation of appropriate ventilation engineering controls and the development of facility-specific occupational health and safety risk assessments. Additionally, many of the health and safety measures required by R2:2013 go over and above measures that may be required by applicable laws. For example, the Standard requires the implementation of engineering controls including, where appropriate, dust control and capture, and ventilation controls. The Standard also requires a facility-specific identification and assessment of occupational health and safety and environmental risks, including risks associated with exposures to substances. Indeed, the Standard notes that such facility assessments should take into account the unique risks posed by exposure to substances in the recycling industry and lists substances of note (e.g., mercury, lead, beryllium, cadmium, and PCBs). All of these requirements are in addition to blanket protections recommended under the Standard, including safe work practices and medical surveillance.