Workshop on E-waste Recycling and Refurbishing Environmentally Sound

Workshop on E-waste Recycling and Refurbishing: Environmentally Sound Management Practices Overcoming Challenges faced by SMEs Meeting the Challenges of Recycling Doing it Right ! Mitchell Rothstein Vice President Environment, Conformance & Business Development - FCM Recycling Guadalajara, México February 15– 16

Object of the Presentation § FCM History § Where Are We § Audits Process § Processor Challenges § Summary

FCM History • FCM founded in 1992 as RMP Recyclage • • • Started as a small scrap recycler 1994 started recycling electronics 18 years existence • 2006 – Became – FCM Recycling / Recyclage Inc • Current location & EPSC / ERS approved facilities * • * Lavaltrie (suburb of Montreal) – 30, 000 Sq Ft – Electronic Recycling • Lavaltrie (suburb of Montreal) - 28, 000 Sq Ft – Electronic Recycling • * Cornwall – 55, 000 Sq Ft – Electronic Recycling • * Halifax – 30, 000 Sq Ft – Electronic Recycling • Toronto (Negotiation)- Storage warehouse / Office Space • Western & Central Canada – Recyclers - Business affiliations

FCM History • FCM was first introduced to - Processes of Standards ? • First requested by Industry Canada – Industry Canada Project – Computer for Schools – CFS Year 2005 » One of 26 responses » One of 3 on short list » Associated with the Mo. E – Quebec / Recyc-Quebec Provincial Assessment Recycling Program • Based on EPSC (Electronic Product Stewardship Canada) • ERS – Electronic Recycling Standards • Approved as Primary & Secondary Processor - Provincial Programs • Ontario • Nova Scotia • Prince Edward Island • Alberta • Quebec (Primary Operations)

Audit Requirements • Air & Swipe Tests - Lead & Mercury Testing • Environmental Conformance – 55 Environmental Regulations • Ministry of Environmental - Application for Certificate of Approval • Ministry of Labour • Audit § Health & Safety § Process § Tracking & Traceability • Recycling Rate Audit § Downstream Verification § Mass Balancing § Recycling Rate Efficiency

Air and Swipe Tests Lead, Mercury and 20 Other Metals § Conducted through a 3 rd Party Environmental Engineer / Industrial hygienist § § Collected 3 AIR samples each - lead & mercury for analysis Collect 2 sets of 6 SWIPE samples from selected surfaces - lead & mercury for analysis Observed work activity and number of units processed / broken during test period Prepare report of test findings Other Metals Include: • • • Manganese (Mn) Mercury Molybdenum (Mo) Nickel (Ni) Selenium (Se) Strontium (Sr) Thallium (Tl) Tin (Sn) Uranium (U) Vanadium (V) Zinc (Zn • • • Aluminum (Al) Antimony (Sb) Arsenic (As) Barium (Ba) Beryllium (Be) Cadmium (Cd) Chromium (Cr) Cobalt (Co) Copper (Cu) Iron (Fe) Lead (Pb)

Audit Requirements Ministry of the Environment • Ministry of the Environment - Certificate of Approval § Applications • Environmental Bill of Rights Registry • Design and Operations Report § Based on Provincial Guidelines • Financial Assurance Report & Obligation • Site Owner Authorization • Qualifying Neighbour Notice & Acceptance • Municipal Zoning • Well Water Disbursement Analysis

Audit Requirements Ministry of Labor § Ministry of Labour - Approval / Verification § § Reports – Air / Swipe Testing Annual Employee Physical Test Employee Medical History Training • • Processes & Procedures Substances of Concern • • • Good Hygiene Written Procedures Blood Testing § For every Permanent Employment Opening • • • For every 15 Calls requesting interviews For every 10 Interviews For every 8 Hired For every 5 starts (after police checks) We have 2 employees that work for more than 1 month

Additional Audit Requirements § Liability Insurance $5, 000 per facility § Provincial Workman Safety Insurance Boards § WSIB – Ontario § CSST – Quebec § WSB – Nova Scotia § Environmental Policy Statement – Commitment § Environmental Aspect § § Impact Assessment § § Procedures Analysis Job Analysis Fire Emergency Procedure / Evacuation Plan (Incident Emergency Plan) § Emergency Plan Natural Gas

Requirements, Mass Balancing § Mass Balance calculation verification § § § § Received Product - Gross / Tare / Net weights Electronics Inventory Shipped Wood shipped / Recycled Cardboard boxes / Pallets / Shrink Wrap / Garbage Current inventory - Gross / Net 120 day turnaround Downstream evaluation § § § ERS guidelines / Environmental Permits Insurance / Certifications On-Site Visits § 5 year record keeping § Recycling rate Record - FCM & Downstream processor

Audit Requirements, Employees § Employee Orientation, Training & Responsibilities § § § § § Safety equipment Health & Safety PPE usage (Personal Protection Equipment) Work Accountability Cleaning Procedures Emergency Evacuation Forklift Training & Certification MSDS (Material Safety Data Sheets) WHMIS (Workplace Hazardous Material Information System – Canada) TDG (Transportation of Dangerous Good – Canada)

Requirements, Recycling § Recycling Rate Audit • Tracking • • • Receiving / Sorting Dismantling / Shredding Inventory – Unprocessed versus Processed / Program • Administration • • Weight Confirmation = Bill of Lading / Invoicing / Certificate of Destruction Downstream » Receipt Confirmation » Monthly Weights Received • Recycling Rate Efficiency • • Process Verification Controlled Testing - both manual and mechanical processes

Summary § This is a BALANCING ACT § From humble beginnings as a scrap company to one of Canada’s leading electronic recyclers § An Industry in Flux § What is the true cost of doing business / recycling ? § Are WE truly prepared to pay for a realistic program for End-to-End Life Cycle Electronic Recycling ? ? § Our planet has no price

Thank you