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Universal Recycling Technologies Environmental, Quality,
Health & Safety Management System Manual

Universal
Recycling
TECHNOLOGIES

RECLAIM + RECYCLE « REINVENT

Universal Recycling Technologies
Environmental, Quality, Health and
Safety Management System Manual

AOICOIPO! Revision Date: 04/18/2016 Page 1 of 27
Last Reviewed Date: 02/05/2018

Universal Recycling Technologies Environmental, Quality,
Health & Safety Management System Manual

Tabie of Contents

1.1. INTRODUCTION
1.2 REFERENCE DOCUMENTS
1.3 DEFINITIONS
1.4 SYSTEM REQUIREMENTS
1.5 CORE BUSINESS PROCESSES

Z ENVIRONMENTAL, QUALITY, HEALTH AND SAFETY POLICY (ISO 14001 4.2, 1SO
9001 5.3)

7

3 PLANNING 7
3.1 ENVIRONMENTAL ASPECTS AND HAZARDS 7
3.2 LEGAL AND OTHER REQUIREMENTS 8
3.3. OBJECTIVES, TARGETS AND PROGRAMS 8
)

9

5

9

naw

3.4 MANAGEMENT SYSTEM PLANNING

4 PROCESS PLANNING
4.1 PLANNING OF PRODUCT REALIZATION

4,2 DETERMINATION OF REQUIREMENTS RELATED TO THE PRODUCT. secscsssecesssssessersurssesonssosensisteeveesesonees
4.3 REVIEW OF REQUIREMENTS RELATED TO THE PRODUCT. sescscsssscssssersssesorsorasecsesasessrsnusaresevsossserereszeres 10
4,4 PURCHASING PROCESS 10
4.5 PURCHASING INFORMATION ( . 10
5 IMPLEMENTATION AND OPERATION Li
5.1 RESOURCES, ROLES, RESPONSIBILITY AND AUTHORITY .assecsssssseseressesosscssssseuseneenessesesecerorsestssasersceres 11
5.2 MANAGEMENT COMMITMENT 11
5.3 CUSTOMER FOCUS 12
5.4 COMPETENCE, TRAINING AND AWARENESS 12
5.5 COMMUNICATION 13
5.6 CUSTOMER COMMUNICATION 13
5.7 DOCUMENTATION AND CONTROL OF DOCUMENTS 13
6& OPERATIONAL CONTROL 14
6.1 OPERATIONAL CONTROL 14
6.2 CONTROL OF PRODUCTION AND SERVICE PROVISION 15
6.3 CUSTOMER PROPERTY 15
6.4 PRESERVATION OF PRODUCT 15
6.5 HEALTH AND SAFETY IN THE WORKPLACE 16
6.6 REUSE AND REFURBISHMENT OF ELECTRONIC EQUIPMENT csssssssssessscsrssssceceserorsssecsesesrssseneanesetsese 18
6.7 Data SECURITY 19
6.8 MANAGING HAZARDOUS E-WASTE AND PROBLEMATIC COMPONENTS AND MATERIALS 1... 19
6.9 ACCOUNTABILITY FOR DOWNSTREAM RECYCLING CHAIN = Auaecsanevssaveee 19
6.10 MATERIALS RECOVERY AND FINAL DISPOSITION 20
6.11 ExPorTATION OF HAZARDOUS ELECTRONIC WASTE 20
6.12 SITE CLOSURE PLANS 20
§.13 INSURANCE REQUIREMENTS 20
7 EMERGENCY RESPONSE PLAN 21
8 CHECKING 21
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Universal Recycling Technologies Environmental, Quality,
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8.1 MONITORING AND MEASUREMENT 21
6.2 VALIDATION OF PROCESSES FOR PRODUCTION AND SERVICE PROVISION ves 21
8.3. IDENTIFICATION AND TRACEABILITY 21
8.4 VERIFICATION OF PURCHASED PRODUCT 22
8.5 CONTROL OF MONITORING AND MEASURING DEVICES 22
8.6 MEASUREMENT, ANALYSIS AND IMPROVEMENT ~ GENERAL sssressssosesesssonsssesssouseessanrareserentecenceenr 23
8.7 CUSTOMER SATISFACTION 23
8.8 MONITORING AND MEASUREMENT OF PROCESSES 22
B.9 MONITORING AND MEASUREMENT OF PRODUCT 23
8.10 Mass BALANCE ACCOUNTING 24
8.141 CENTRAL DATABASE REPORTING 24
8.12 EVALUATION OF COMPLIANCE 24
8.13 CORRECTIVE ACTION AND PREVENTIVE ACTION PROGRAN ..... vesee 24
8.14 CONTROL OF NONCONFORMING PRODUCT 25-26
8.15 RECORDS 26
8.16 INTERNAL AUDITS 26
9 ACT 26
9.1 MANAGEMENT REVIEW 26
9.2 ANALYSIS OF DATA 26
9.3 CONTINUAL IMPROVEMENT 27
Location of documentation is defined in the AO1C01F01 Table of Contents on the
company internal ISO website.
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Universal Recycling Technologies Environmental, Quality,
Health & Safety Management System Manual

System Overview
1.1 introduction/Scope

Universal Recycling Technologies (URT) Environmental, Quality, Health and Safety
Management System (EQHSMS) Manual was developed for reducing URT's impacts on
the environment, reducing worker health and safety risks and to meet customer's
requirements and expectations as a result of its operations and activities. This EQHSMS
Manual is intended to meet the requirements of the ISO 14001:2004 and ISO 9$001:2008
International Standard as defined by the International Organization for Standardization
(ISQ), based in Geneva, Switzerland and e-Stewards Standard for Responsible
Recycling and Reuse of Electronic Equipment v.1.0.

Universal Recycling Technologies, LLC is a privately held electronics processing and
recycling center headquartered at 2535 Beloit Ave., Janesville, WI, and operates
electronics operations located in several states. The scope of URT’s EQHS
management system is for the processing of electronic waste for reuse and recycling,
data destruction, bulb recycling and recycling of universal wastes and asset recovery.
The URT corporate level supports the local outlying facilities in the following functions,
including but not limited to: vendor selection, iegal and other requirements, EHS support,
purchasing, sales, customer set-up and document control. URT's outlying facilities
include: 120 E. Burbank Ave, Janesville, WI; Fort Worth, TX; Dover, NH and Clackamas,
OR. URT, LLC is a fully approved and permitted recycling facility receiving obsolete
electronic equipment from general industry, environmental service providers, and
medical facilities

-

URT, LLC handles all types of electronic equipment including, but not limited to:

Monitors Televisions Desktop or Tower Computers
Laptops Server Macintosh computers with Screen
Printers Scanners Docking Stations

Keyboards Terminals Mainframes

UPS Typewriters Fax Machines

Photocopiers Cellular Phones Refrigeration Equipment

1.2 Reference Documents

Documents referenced in this EQHSMS Manual are as follows:

ISQ 9001, Quality management systems-Requirements, 2015
ISO 19011, Guidelines for quality and/or environmental management systems auditing;

e-Stewards Standard V.3 (which fully incorporates ISO 14001-2015)

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Universal Recycling Technologies Environmental, Quality,
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1.3 Definitions
Terms used in this EQHSMS Manual are defined as follows:
Asset Recovery — The sale of useable/working equipment, components or parts

Commodity - Material generated by the dismantling of electronic equipment that will be
ultimately sold into domestic or foreign commodity markets

Contractor - Persons and organizations that are a subset of suppliers who provide on-
site services.

Cuilet - Broken CRT glass.

Customer - Persons and/or organizations that URT supplies a service or product.
Dis-assembly- The manual dismantling of electronic equipment for recycling
Downstream Vendor - are defined as buyers of commodities, equipment or products
used to generate revenue or downstream vendors that provide a service to dispose of
non-saleable commodities for final disposition.

Fines — Small particles generated by one of URT’s processes

Recycling - Process, by which materials that would otherwise become solid waste are
collected, separated or processed and returned to the economic mainstream to be
reused in the form of raw materiais or finished goods.

Scrub — Mechanically clean all surface

Shakeout — The process of mechanically separating cullet by size

Supplier - Persons and organizations that supply goods and/or services that are used in
URT's recycling operations, and/or the facilities.

Upstream Suppliers — defined as providers of products to sell, dispose, use and/or
dismantle

Visitor - Persons and organizations that visit the site that did not meet any of the above
definitions.

1.4 System Requirements

URT has established, decumented, implemented, maintains, continually improves, a
written Environmental, Quality, Health and Safety Management System in accordance
with the requirements of the e-Steward's, (ISO 14001) and ISO 8001 standards and has
determined how it will fulfill these requirements.

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Universal Recycling Technologies Environmental, Quality,
Health & Safety Management System Manual

URT shall:
a. Identify the processes needed for EQHS management throughout the
organization,
b. Determine the sequence and interaction of these processes, reference URT
Documentation Key Process Flow,
c. Determine the criteria and methods needed to ensure that both the operation and
control of these processes are effective,
d. Ensure the availability of resources and information necessary to support the
operation and monitoring of these processes,
Monitor, measure where applicable and analyze these processes, and
implement the actions necessary to achieve planned results and continually
improve these processes.

mh @

URT has modeled the health and safety requirements of this EQHSMS after the
principles of OHSAS 18001.

URT has defined and documented the scope of its environmental, quality, health and
safety management system as follows:

System scope:

URT Headquarters and associated facilities does the collection, transportation,
segregation, refurbishment of electronics equipment and processing of electronic waste
for reuse and recycling, data destruction, bulb recycling, and recycling of universal
wastes and asset recovery. URT Corporate evel supports the local outlying facilities in
the following functions including, but not limited to: vender and downstream selection,
legal and other requirements, EHS support, purchasing, sales, customer set-up and
document control.

Reference the URT iocations in URT Facility Listing - A01CO1F03

Related and Supporting Documents
AQ1C01F02 URT Documentation Key Process Flow

AQ1C01F03 URT Facility Listing
1.5 Core Business Processes

URT has defined a number of core business processes that were designed to efficiently
and effectively meet customer expectations while minimizing impacts to the environment
and protecting worker health and safely. URT's core business is to collect and safely
process obsolete electronic equipment and provide assurance to our customer base that
the equipment is managed in a secure environment within the US.

URT has identified its core business processes and their interactions through description
in this manual and process flow diagram, including; ithe URT Process Flow Diagram and
the Process Descriptions are located in section “Operations Processing (formerly section
A086).

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Universal Recycling Technologies Environmental, Quality,
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in order to ensure that these processes are operating effectively, URT has defined the
controi mechanisms and monitoring requirements which are specified in the appropriate
procedures or appropriate sections of this manual.

Outsourced process:
None of the processes used to meet the ISO 9001 standard requirements are

outsourced by URT, with the exception of certified scale and certified laboratory testing.
Any other processes that could be outsourced will be reviewed against the ISO 9001
standard requirements, which must be met prior to implementation.

Exclusions:

The following requirements of ISO 9001 are excluded from the environmental, quatity,
health and safety management system as these functions are not performed at the URT
facility.

7.3 Design and development

Related and Supporting Documents
AOSCO6P01 Operation Processing

2 ‘Environmental, Quality, Health and Safety Policy

URT’s top management has defined URT’s Environmental, Quality, Health and Safety
Policy and has ensured that, within the defined scope of its environmental, quality,
health and safety management system, it is documented, implemented, maintained,
reviewed for continuing suitability, communicated to all persons working for or on behalf
of URT and is available to the public via the URT website located at: htto//www.
URTsolutions.com

URT's top management has defined the Environmental, Quality, Health and Safely
Policy.

Related and Supporting Documents
A02C01P01 Environmental, Quality, Health and Safety Corporate Policy

3 ~=Ss- Planning

3.1. Environmental aspects and hazards

URT has established, implemented and maintains a procedure to identify the
environmental aspects and hazards of its activities, products and services within the
defined scope of the environmental, quality, health and safety management system that
it can control and those that it can influence taking into account planned or new
developments, or new or modified activities, products and services, and to determine
thase aspects that have or can have significant impact(s) on the environment.

URT shall document and keep this information up to date.

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Universal Recycling Technologies Environmental, Quality,
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URT shall ensure that the significant environmental aspects and are taken into account
in establishing, implementing, and maintaining its Environmental, Quality, Health and
Safety Management System.

Related and Supporting Documents Attached
A04C03P01 Environmental Aspects Identification

3.2 Legal and other requirements

URT has established, implemented and maintains a procedure to identify and have
access to the applicable legal requirements and other requirements to which URT
subscribes related to its environmental aspects, health and safety hazards, requirements
related to the product, data security and privacy requirements and regulations covering
specific operations, ‘imitations and controls. URT shall ensure that these applicable
legal requirements and other requirements to which URT subscribes are taken into
account in establishing, implementing and maintaining its environmental, quality, health
and safety management system.

Related and Supporting Documen:
A04C01P01 Legal and Gther Requirement identification

3.3 Objectives, targets and programs

URT has established, implemented and maintains documented environmental, quality,
health and safety objectives and targets, at relevant functions and levels within URT.

URT's objectives and targets shall be measurable, where practicable, and consistent
with the environmental, quality, health and safety policy.

When establishing and reviewing its cbjectives and targets, URT shall take into account
the legal requirements and other requirements, to which URT subscribes, and its
significant environmental aspects, its health and safety hazards and product
requirements. It shail also consider its technological options, its financial, operational
and business requirements.

URT has established, implemented and maintains programs for achieving its objectives
and targets documented in Objectives and Targets. The programs shall include the:
a) designation of responsibiity for achieving objectives and targets at relevant
functions and levels and
b) the means and time-frame by which objectives are to be achieved.

Objectives and Targets shall be reviewed at least once a year during Management
Review meetings.

Related and Supporting Documents
A03C-01P01 Objectives & Targets

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Universal Recycling Technologies Environmental, Quality,
Health & Safety Management System Manual

3.4 Management System Planning

URT has established that all relevant functions and levels within URT have clear,
measurable EQH&S objectives that are consistent with URT’s EQH&S Policy and
product requiremenis.

The integrity of the EQH&S Management Systems is maintained when changes to the
EQH&S System are planned and implemented.

Related and Supporting Documents
AQ3C01P01 Objectives & Targets

4 =~Process Planning
4.1 Planning of product realization

URT shall plan and develop the processes needed for product realization. Planning of
product realization shall be consistent with the requirements of the other processes of
the EQH&S management system

in planning product realization, the organization shall determine the following, as
appropriate:
a) EQH&S objectives and requirements for the product,
b) the need to establish processes, documents, and to provide resources specific to
the product;
c) required verification, validation, monitoring, measurement, inspection and test
activities specific to the product and the criteria for product acceptance;
d} records needed to provide evidence that the realization processes and resulting
product meet requirements

The output of this planning shall be in a form suitabie for the organization's method of
operations.

Related and Supporting Documents
A04C05P01 Process Planning and Control

4.2 Determination of requirements related to the product

URT shall determine:
a) requirements specified by the customer, including the requirements for delivery
and post-delivery activities,
b) requirements not stated by the customer but necessary for specified or intended
use, where known, and
c) statutory and regulatory requirements applicable to the product
d) any additional requirements determined by the organization

Related and Supporting Documents
A04C07P01 Sales & Marketing

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