Page 27 - North American Clean Energy May/June 2020 Issue

Developing and implementing strategies to deal with e-waste is essential for companies of all size and in all industries. Minimizing waste, recycling electronics, managing the risks of disposal, and complying with regulations at the local, state, federal, and international levels are all important considerations. Compliance with appropriate regulations means knowing and understanding which laws and treaties apply to the particular waste in question, keeping proper records, and meeting permitting requirements.
Companies working with vendors to handle their e-waste can avoid liability by assessing vendors at the onset, and auditing them throughout the disposal process. Vendors should be required to provide assurance as to their ability to meet regulatory requirements, and present evidence that requisite permits and certifications are in place. To deal with these complexities, organizations may want to seek help from a provider with expertise in health, safety, and environmental compliance services. For e-waste, those services can include assessing the waste to determine proper handling; providing guidance on waste management and disposal; and evaluating disposal vendors to ensure they have proper certifications and valid permits (as well as reveal any past violations).
To avoid compliance lapses, companies may want help in reporting and record keeping requirements. Training, written program development, R2 Certification, EICC conformance, auditing, and permitting are other valuable services that companies may want to consider. As they work to optimize their e-waste management strategies, companies should seek to confirm that their insurance program provides the appropriate coverage for e-waste exposures that cannot be avoided by their proactive risk management efforts. Premises pollution liability policies can provide coverage
for environmental risks on a particular site (including remediation when necessary), as well as coverage for liability arising from releases during transportation of e-waste, and releases from properly permitted third-party disposal sites. Companies may
want to consider a policy that provides coverage for their entire business operations, whether on their own premises or at third-party locations. Also, for firms involved in e-waste management, contractor’s pollution liability coverage can provide insurance for environmental risks at project sites owned by another entity – whether it be a government body or private company.
Responsibly disposing of solar panels has become a complicated business. Previously unregulated e-waste management practices have become subject to new and evolving regulations. Best practices dictate enlisting the help of experts in this rapidly evolving field. Check with your insurer - they may be willing to pay for associated auditing, training or other risk management services tailored for e-waste as part of a comprehensive coverage program. Safety is paramount, for both your company and the environment.
AJ Orben is Vice President, and Dwight Clark is Director of Compliance and Recycling Technology at We Recycle Solar, a single-source disposal provider for excess, recalled, and end-of-life solar products.
We Recycle Solar /// werecyclesolar.com
North American Clean Energy
27