Search

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

4.3 Review of requiremenis reiaied to the product

URT shall review the requirements related to the product. This review shall be
conducted prior to URT's commitment to supply a product/service to the customer and
shall ensure that.
a) product/service requirements are defined,
b) contract or order requiremenis differing from those previously expressed are
resolved, and
¢) the organization has the ability to meet the defined requirements.

Records of the results of the review and actions arising from the review shall be
maintained.

Where the customer provides no documented statement of requirement, the customer
requirements shall be confirmed by URT before acceptance. Where product
requirements are changed, URT shall ensure that relevant documents are amended and
that relevant personnel are made aware of the changed requirements.

Related and Supporting Documents
A04C07P01 Sales & Marketing

44 Purchasing process

URT shall ensure that purchased product conforms to specified purchase requirements.
The type and extent of contro! applied to the supplier and the purchased product shall be
dependent upon the effect of the purchased product on subsequent product realization
or the final product.

URT shail evaluate and select suppliers based on their ability to supply product in
accordance with the URT's requirements. Criteria for selection, evaluation and re-
evaluation shall be established. Records of the results of evaluations and any
necessary actions arising from the evaluation shail be maintained.

Related and Supporting Documents
A04C06PO1 Purchasing Process

4.5 Purchasing information

Purchasing information shall describe the product to be purchased, including where
appropriate:

a) requirements for approval of product, procedures, processes and equipment,
b) requirements for qualification of personnel, and
c) EQH&S management system requirements.

URT shall ensure the adequacy of specified purchase requirements prior to their
communication to the supplier.

A01COIPO! Revision Date: 04/18/2016 Page 10 of 27
Last Reviewed Date: 02/05/2018

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

Related and Supporting Documents
AQ4CO06POCi Purchasing Process

5 Implementation and Operation

5.1 Resources, Roles, Responsibility and Authority

Roles, responsibilities and authorities have been defined and documented in this
EQHSMS Manual, URT Procedures, and the Organization Chart documents and are
communicated to those affected individuals.

URT management shall ensure the availability of resources essential to establish,
implement, maintain and improve the environmental, quality, health and safety
management system and to enhance customer satisfaction by meeting customer
requirements. Resources include human resources and specialized skills, organizational
infrastructure, technology and financial resources.

URT management shall ensure the infrastructure and work environment needed to
achieve conformity to product requirements. Infrastructure includes buildings,
workspaces, associated utilities, process equipment {both hardware and software} and
supporting service such as transport, communication and information systems.

The President has designated the EHS Director as the (EMR/QMR where applicable)
who will assume all roles, responsibilities, and authorities defined throughout the
EQHSMS including ensuring that the EQHSMS is established, implemented and
maintained in accordance with the requirements of these standards and reporting to
URT's top management on the performance of the EQHSMS, including
recommendations for improvement.

Related and Supporting Documents

A03CO2W01 Organization Chart Work Instruction
A03C02F01 Organization Chart

AO03C02F02 Job Title and Employee List

§.2 Management commitment

Top management of URT ensures that all employees are aware of the need to meet
customer and regulatory requirements and that the necessary resources are available.
An EQH&S Policy and EQH&S objectives have been established and management
reviews are conducted on a regular basis.

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

AO03CO01P01 Objectives and Targets
ACQ3C02P01 Roles and Responsibility
AGSCO1P01 Management Review

AOQICOIPOL Revision Date: 04/18/2016 Page 11 of 27
Last Reviewed Date: 02/05/2018

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

5.3. Customer focus

Top management of URT ensures that customer requirements are determined and
fulfilled to meet customer satisfaction.

Related and Supporting Documents
A04C07P01 Sales & Marketing

AO08C03P01 Monitoring and Measurement
AO8CO3WV03 Customer Survey Procedure

5.4 Competence, training and awareness

URT shall ensure any person(s) performing tasks for it on its behalf that:
4. Could affect conformity to product requirements, or
2. have the potential to cause a significant environmental impact(s) or
3. whose work involves health or safety hazards,

are identified by the organization and are competent on the basis of appropriate
education, training or experience, associated records are retained.

URT has established and maintains procedures and associated training materials for its’
permanent and temporary employees and vendors associated with its product and
customer requirements, environmental aspects and the EQHSMS, and shail retain
associated records. URT shall evaluate the effectiveness of the trainings.

URT has established, implemented and maintains a procedure to make persons working
for or on its behalf aware of:

a) the importance of conformance. with the environmental, quality, health and safety
policy and procedures and with the requirements of the EQHSMS;

b) the relevance and Importance of their activities and how they contribute to the
achievement of EQH&S objectives.

¢) the significant environmental aspects and health and safety hazards and the
related actual or potential impacts associated with their work, and the EQH&S
benefits of improved personal performance;

d) their roles and responsibilities in achieving conformance with the EQH&S policy
and procedures and with the requirements of the EQHSMS, including emergency
preparedness and response requirements; and

e) the potential consequences of departure from specified operating procedures.

Related and Supporting Documents
AO05C03P01 Competence, Training and Awareness

A04C04P01 Facility Infrastructure Security

ADICOIPOI Revision Date: 04/18/2016 Page 12 of 27
Last Reviewed Date: 02/05/2018

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

5.5 Communication

With regard to its product requirements, environmental aspects, health and safety risks
and EQH&S management system, URT shall establish, implement and maintain a
procedure for
a) Internal communication among the various levels of the organization
b) Receiving, documenting, and responding to relevant communication from
external interested parties

URT made a decision on June 24”, 2010, not to communicate its significant
environmental aspects to external parties. URT operates proprietary equipment and
processes. Communicating significant environmental aspects may jeopardize the
competitive advantage URT has established in the industry.

Related and Supporting Documents
AO5C02P01 Communication

§.6 Customer communication

URT shall establish, implement and maintain a procedure for communicating with
customers in relation to;

a) Product information,

b) Inquiries, contracts or order handling, including modification, and

c) Customer feedback, including complaints

Related and Supporting Documents
AOQ5C02P01 Communication

A08CO3WO03 Customer Survey Procedure
§.7 Documentation and Control of Documents

The Environmental, Quality, Health and Safety Management System documentation
shail consist of this EQHSMS Manual and all associated documentation including:

a) the environmental, quality, health and safety policy, objectives and targets,

b) description of the scope of the Environmental, Quality, Health and Safety
Management System, and justifications for exclusions.

c) description of the main elements of the Environmental, Quality, Health and
Safety Management System and their interaction, and reference to related
documents,

d) documents, including records, required by this standard, and

e) documents, including records, determined by URT to be necessary to ensure the
effective planning, operation and control of processes that relate to significant
environmental aspects, health and safety risks and product requirements.

URT has established, implemented and maintains a procedure to:

a) approve documents for adequacy prior to issue,
b) review and update as necessary and re-approve documents,

AOICOIPOL Revision Date: 04/18/2016 Page 13 of 27
Last Reviewed Date: 02/05/2018

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

¢) ensure that changes and the current revision status of documents are
identified,

d) ensure that reievant versions of applicable documents are availabie on the
companies shared Q drive within the ISO Folder, or other appropriate
controlled location, such as the URT Sharepoint,

e) ensure that documents remain legible and readily identifiable,

f} ensure that dacurnents of external origin determined by organization to be
necessary for the planning of operation of the Environmental, Quality, Health
and Safety Management System are identified and their distribution controlled,
and

g) prevent the unintended use of obsolete documents and apply suitable
identification to them if they are retained for any purpose.

Documents controlied outside of ISO:
Documents determined to be of importance, but not required to be managed through the
ISO process, are managed by the department who owns them.

a) The Departments within URT that control documents outside of ISO are: EHS,
HR and Finance and Operations.

b) The Departments are held to the same procedure requirements a) through e)
above.

Related and Supporting Documents
A05C01P01 Document Control

6 Operational Control

6.1 Operational Control

URT has identified and planned those operations that are associated with
Environmental, Quality, Health and Safety and the identified significant environmental
aspects consistent with its policy, objectives and targets, in order to ensure that they are
carried out under specified conditions by:

a) establishing, implementing and maintaining documented procedures to cover
situations where their absence could lead to deviations from the
environmental, quality, health and safety policy and the objectives and
targets;

b) stipulating operating criteria in the procedures; and

c) establishing, implementing and maintaining procedures related to the
identifiable significant environmental aspects of goods and services used by
the organization

d) communicating relevant procedures and requirements to suppliers ana
contractors.

URT has ensured that the appropriate documented procedures are established,
implemented and maintained.

ADICOIPO! Revision Date: 04/18/2016 Page 14 of 27
Last Reviewed Date: 02/05/2018

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

All Contractors must sign in and out at the front desk and must agree to abide by URT’s
Visitor Entry Log. The URT employee, whom the Contractor is reporting to, has the
responsibility to ensure the sign in log is complete and the Contractor has agreed to the
Visitor & Contractor Safety and Environmental Requirements.

Related and Supporting Documents

A04C03P01 Environmental Aspects identification Procedure
AO4CO3E01 Environmental Aspects Worksheet

AO04CO4P01 Facility and Infrastructure Security

6.2 Control of production and service provision

URT shall plan and carry out production and service provision under controlled
conditions. Production is controlled through product specifications and work instructions.
Suitable equipment is used and properly maintained. Monitoring and measurement
equipment is available and utilized. Product release, delivery and post-delivery
processes are defined.

Related and Supporting Documents
AO4C05P01 Process Planning and Control
AOBC03P01 Monitoring and Measurement

6.3. Customer Property

URT exercises care of Customers’ property while it is under their control. Procedures
are in place for the identification, verification; protection and preservation of Customers’
property, inciuding intellectual property and personal data. The loss, damage or
unsuitability of such property shall be reported to the Customer and records maintained.

Related and Supporling Documents
AD4COS5P01 Process Planning and Control

ACBCOZP01 Asset Material Management Procedure

6.4 Preservation of Product

URT preserves the product during internal processing and delivery to the intended
destination in order to maintain conformity to requirement. The preservation shall
include identification, handling, packaging, storage and preservation. Preservation shail
also apply to the constituent parts of a product.

Related and Supporting Documents
A04C05P01 Process Planning and Control

A01CO1PO1 Revision Date: 04/18/2016 Page 15 of 27
Last Reviewed Date: 02/05/2018

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

6.5 Health and Safety in the Workplace

URT has estabiisned, impiemented and maintains environmental, health and safety
programs that protect worker health and safety and the environment that are outlined in
the procedures of the Environmental Health and Safety Systems.

a.

The Director of EHS is responsible for developing and maintaining appropriate
site specific environmental, health and safety programs to meet all federal, state
and focal health and safety requirements.

URT shall conduct a full occupational, heaith and safety inspection on ail
company operations, at least once every three years. The results shall be
reviewed at the next management review meeting or senior management weekly
meeting. Any identified non-conformances shall be documented in the
Corrective and Preventive Action process.

URT shall obtain and maintain documentation to identify what hazardous
substances are present in e-waste materials and products used in its operations
that require the necessary documentation by OSHA regulations (such as lead or
cadmium). URT documents this information in the Right to Know/Hazard
Communication Program, including, but not limited fo the use of Safety Data
Sheets (SDS) sheets.

URT has developed plans for managing specific electronic waste based on the
technologies utilized at URT.

URT shall conduct an ergonomic evaluation on company operations. The results
shall be reviewed at a management review meeting, or senior management
weekly meeting, as required. Any identified non-conformances, as defined by a
specific regulatory requirement, shall be documented in the Corrective and
Preventive Action process.

URT shail outline the health and safety controls for managing each type of
Hazardous e-Waste in the Hazardous e-Waste Management Pian with the goal
to reduce and eliminate workplace exposure and hazards. Analysis includes
what processing technologies are utilized and what additional hazards are
introduced as a result of using the processing technology.

URT shall utilize monitoring and sampling protocols to provide assurances that
the practices it employs are effectively and continuously managing the risks it
has identified. This includes complying with all applicable Federal or State OSHA
standards anc permissible exposure limits (PELs) for sampling and/or
monitoring.

URT shall conduct employee exposure sampling to determine, implement and
monitor the appropriate required programs including hearing protection, personal
protective equipment (PPE), air sampling and medical surveillance.

AQ1CO1PO1 Revision Date: 04/18/2016 Page 16 of 27

Last Reviewed Date: 02/05/2018

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

i. URT conducts monthly safety committee meetings. A facility management
representative conducts the meetings and has the authority to implement actions
for worker health and safety. Employees are encouraged to communicate health
and safety concerns at that time or any other time as deemed necessary.
Appropriate actions shall be taken to identify the workplace hazards and
communicated to all appropriate parties for resolution to the hazard ina timely
manner, using severity of the hazard or risk to the workers and organization as a
guide in implementing priorities.

j. URT has established a formal process for investigation and resolution of health
and safety complaints as outlined in the URT Employee Allegation Resolution
Policy. |

k. URT identifies and assesses occupational hazards through its full risk
assessment of the operation.

URT shall manage physical hazards, ergonomic and other workplace hazards using
an appropriate combination of strategies, including but not limited to (1-3 below are
in order af priority, per OSHA regulations):

6.5.1. Engineering controis such as (A-F below is in order of priority, per OSHA
regulations):
a) Substitution (e.g., replacing a toxic solvent with one less toxic),
b) Isolation (¢.g., automating a process to avoid employee
exposure), or
c) Ventilation and, if appropriate, capture (e.g., fume hood),
d) Dust control, capture, and clean up, and
e) Emergency shut-off systems, and
f) Fire suppression systems

6.5.2 Administrative and work practice controls, including appropriate
combinations of:

a) Regular, documented health and safety training that covers
information from the hazards assessment, as well as safe
management handling, spill prevention, engineering controls,
equipment safety, and use and care of personal protection
equipment; with training for new hires and refresher courses
for all employees that is understandable to them given
language and level-of-education considerations,

b) Job rotation as feasible given workforce size,

c) Safe work practices,

d) Medical surveillance, and

e) Safety meetings

6.5.3 Personal protective equipment, including respirators, protective eyewear,
cut-resistant gloves, etc., as appropriate for the risks involved in the tasks
being performed.

AQ1CD1P01 Revision Date: 04/18/2016 Page 17 of 27
Last Reviewed Date: 02/05/2018

Comment [TP4]: Do we still have this? Is itstill |
called this, and do employees know i? |

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

|. URT provides health and safety training for all employees in a language and
format understandable by the employee. Training programs include, but is
certainly not limited to:
7. New Hire Health and Safety Training
2. Hazard Communication/ Right to Know Training
3. Respirator Training, if applicable
4. Personal Protective Equipment Training

m. URT has established and maintains workplace hygiene and cleaning program to
minimize employee exposure as outlined in the Written Housekeeping & Hygiene
Program.

n. URT has established and maintains a written Emergency Action Plan and
Emergency Procedures.

a. Medical surveillance programs are outlined in applicable heaith and safety
programs and implemented as necessary or appropriate to the policy.

Related and Supporting Documents
Employee Allegation Resolution Policy (Employee Handbook)

Hygiene Program

AO8C04P01 Nenconformance, Corrective and Preventive Action
AO06C01P01 Hazardous 6-Waste Management Plan
AQ8CO3P01 Monitoring and Measurement

A04C03P01 Environmental Aspects Identification

A07C01P01 Corporate Contingency and Emergency Action Plan
AC6C04P04 Injury & {llness Prevention Program

6.6 Reuse and Refurbishment of Electronic Equipment

URT shall donate, recycle or sell for reuse, electronic equipment (designated as or
containing e-waste or problematic materials). All scrap generated from the
refurbishment process shall be managed according to this standard.

URT shall test electronic equipment that contains or consists of hazardous electronic
equipment according to the Asset Material Management.

Related and Supporting Documents
AQ6C02P01 Asset Material Management

6.7 Data Security

URT assumes responsibility for the data security of customer's material and shail hoid
appropriate insurance to cover data security liabilities. Responsibility and data security
policies and processes are communicated to customers through the contracts, the URT
website, and postings at customer drop off and collection events — reference Asset

AGICOIPO] Revision Date: 04/18/2016 Page 18 of 27
Last Reviewed Date: 02/05/2018

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

Management procedure and Facilities & infrastructure Security procedure. URT takes
control of the materials as it is received inte a URT facility.

URT has established, implemented and maintains data destruction procedures which
outline the handling, physical security, physical destruction and wiping methods of data
containing devices, as well as procedures in the event of a breach of security.

Related and Supporting Decuments
A0Q4T04P01 Facility & Infrastructure Security
A06CO02P01 Asset Material Management
A06CO2WO2 Data Destruction

6.8 Managing Hazardous e-Waste and Problematic Components and Materials

URT shall plan for the disposition of Electronic Equipment, components, and
materials, based on the following hierarchy of management strategies:
a. Direct Reuse of tested, working equipment and parts;
b. Refurbishment and Repair for Reuse;
Materials Recovery (including plastics);
c. Disposal, including Waste to Energy Recovery, Landfills or
incinerators

URT shall manage Hazardous e-Waste and Problematic Components and Materials,
both on-site and under URT’s control, with practices and procedures protective of human
health and the environment.

Related and Supporting Documents
AQ6C01P01 Hazardous e-Waste Material Management

6.9 Accountability for Downstream Recycling Chain

URT shail be accountable for the management of e-Waste through the entire recycling
chain to final disposition. URT has established, implemented and maintains a
downstream vendor qualification program which outlines the requirements for initial due
diligence, contracting or communicating requirement with downstream vendors, assuring
on-going conformance, verifying shipment and providing transparency.

URT shall provide customers with access to information, records and documentation on
downstream vendors upon reasonable request.

Related and Supporting Documents
AOBCO3P01 Downstream Vendor Qualification Program

AODTCOLPO! Revision Date: 04/18/2016 Page 19 of 27
Last Reviewed Date: 02/05/2018