IT-RE / E-waste / Recycling IT Hardware and Equipment

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ITR-05262015-00046

IT-Re, Inc.24 N.E. 51st StreetOklahoma City, OK 73105

Phone: 405-601-0020Main Email: [email protected]

Environmental, Health and SafetyManagement System (EHSMS)IT-Re, Inc. has developed this Environmental, Health & Safety Management System(EHSMS) as an ISO 9001 based system and in compliance with the applicableclauses and requirements of the current versions of ISO 14001 – EnvironmentalManagement Systems – Requirements, the OHSAS 18001 Occupational health andsafety management systems, and the Responsible Recycling (“R2”) Standard.

NOTICE: The EHSMS of IT-RE, Inc. is an electronic system.The electronic version is the controlling document and any printed copies are to beconsidered for reference only unless distributed under control in accordance with thePRO-05 Documentation and Data Control.

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Environmental Management Representative (EMR) and Contact:John MegeheeTitle: CEOPhone: 405-601-0020, ext 1000 (Cell) 405-323-9296Email: [email protected]

Health and Safety Management Representative (HSMR) and Contact:John MegeheeTitle: CEOPhone: 405-601-0020, ext 1000 (Cell) 405-323-9296Email: [email protected]

Company Overview:Established in 2010, IT-Re, Inc. provides a full array of asset recovery, recycling and datadestruction services for all types of Information Technology equipment. With over 30 years ofcombined experience in all facets of computer recycling and asset recovery, we offer disposalservices across the continental U.S. to business, government agencies, charities, schools,universities and hospitals. We handle all types of Information Technology equipment; from cellphones and tablets to servers and mainframes. If it is an electronic device and is managed by anI.T. Director, we take it. We perform on-site picking and packing services and arrange for andcoordinate all movement of materials from the client's facility to ours. We offer secure datadestruction services by means of a NIST 800-88 compliant wiping software or physicaldestruction of data containing devices. We provide environmentally responsible disposal of non-working equipment, e-waste and equipment beyond its usable shelf life. We are as committed toprotecting our client's reputation and data as we are our own. We are critically aware of ourresponsibility to both our client and the environment and committed to the safe and properdisposal of all equipment.Scope of EHSMS:IT-Re, Inc. performs the following: Sorting, de-manufacture, data destruction, refurbishing,palletizing, shipping, and resale. This scope encompasses all electronics recycling activities at thefacility identified as 24 N.E. 51st St., Oklahoma City, OK 73105.This scope includes all activities that may potentially interact or impact the environment.Additionally, the scope includes the health and safety of all persons that work for, or may bewithin the facility from time to time.

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Organization Chart:

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The IT-RE, Inc. Environmental Policy:We at IT-Re, Inc. accept environmental responsibility for our activities andprocesses. We are committed to sound environmental practices and theprevention of pollution with the aim of attaining our environmental targetsand objectives.IT-Re, Inc. adheres to a policy for managing used and end-of-life electronicequipment that is based on a “reuse, recover, dispose” hierarchy ofresponsible management strategies.IT-Re, Inc. and its personnel are committed to complying with theapplicable environmental requirements of the relevant legal authority, aswell as the industry and any additional requirements to which the companysubscribes; including the Responsible Recycling (“R2”) Standard.Furthermore, IT-Re, Inc. is committed to the review and continualimprovement of our EHSMS and activities to minimize impact on theenvironment.IT-Re, Inc. will prohibit the use of prison labor for the processing ofHazardous e-Waste throughout the Recycling Chain.This policy is to be communicated to all persons working for, or on behalf of,IT-Re, Inc.

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The IT-RE, Inc.’s Health and Safety Policy:

IT-Re, Inc. is committed to the Occupational Health & Safety (OH&S) of all personswithin its facility.The OH&S contributes to all aspects of business performance as part of IT-Re, Inc.’scommitment to continual improvement and the development of human factorsincluding the culture, attitude and beliefs within IT-RE, Inc.IT-Re, Inc.’s top management has set in place procedures to define, document andendorse this OH&S policy and includes its commitment to protecting the safety andhealth of persons at work and others who might be affected by their work activities.This policy will be achieved by:Adherence to all relevant International, Federal, State and local OH&S treaties,legislations and regulations;Recognizing and implementing OH&S as an integral part of improving businessperformance;Achieving a high level of OH&S performance, and a commitment to continual cost-effective improvement in performance;Minimizing risk and the prevention of injury, ill health, diseases and incidents;Acknowledging that people are the key resource and promoting the general healthand safety of employees;Providing adequate and appropriate resources to implement the policy includingaccess to competent specialist advice where necessary;Setting and publishing OH&S objectives at a minimum by internal notification;Placing management of OH&S as a prime responsibility of line management frommost senior executive to first-line supervisory level;Ensuring its understanding, implementation and maintenance at all levels in theorganization;Ensuring employee involvement, participation and consultation to gain commitmentto the policy and its implementation;Ensuring that employees at all levels receive appropriate training and are competentto carry out their duties and responsibilities;Periodically reviewing the policy, the management system and audit of complianceto policy, as a driver of continual improvement;Periodically reporting OH&S management performance internally and to externalparties where relevant.

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The Environmental Policy and the Health and Safety Policy were established by the TopManagement of IT-Re, Inc. and approved by the CEO through the Management Review Process.The Environmental Policy and the Health and Safety Policy is posted in public places and availableto interested parties.

Environmental, Health and Safety Targets and Objectives:Environmental, Health and Safety Targets and Objectives reflect:

The regulatory health of IT-Re, Inc. relevant to its compliance with local, state and Federalenvironmental laws and regulations, The regulatory health of IT-Re, Inc., relevant to its compliance with local, state andFederal health and safety laws and requirements, The health of the systems for accomplishing the environmentally sound recycling ofmaterials and/or product in a safe and healthy manner, The health and safety of IT-Re, Inc.’s personnel, equipment and processes, and The client’s and community’s perception of IT-Re, Inc.

Environmental, Health and Safety targets and objectives are determined by Top Managementand defined using metrics to track performance. Environmental, Health and Safety targets andobjectives are established and reviewed as part of the Management Review Process.

Environmental, Health and Safety Manual - General:This Environmental, Health and Safety Manual, the Processes, the Supplemental Processes, theProcedures, and the associated instructions, forms and records define the Environmental, Healthand Safety Management System (EHSMS).

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Overall System Description:The EHSMS was developed taking into account the requirements established by external entitieswith oversight and/or certification responsibility. These external requirements were used by IT-Re, Inc. to develop the EHSMS and ensure the continual improvement loop. This ensures thatthe outputs are incompliance with the requirements and legal obligations.

Continual Improvement Loop

INPUTS ENVIRONMENTAL:Federal (EPA), state and localenvironmental regulations. ISO 14001requirements, R2.

INPUTS RECYCLING:Federal (EPA), state and localrecycling regulations, R2.

INPUTS HEALTH & SAFETY:Federal (OSHA), state and local health& safety regulations, OHSAS 18001,R2.

ENVIRONMENTAL, HEALTH and SAFETY MANAGEMENTSYSTEM (EHSMS):Policies, processes, procedures, instructions, forms & records incompliance ISO 14001, OHSAS 18001, R2.

PLANNING: Facility, Process &Downstream Vendors.

AUDITS: Internal Audits andCertification Body Audits.

RISK ANALYSIS: Aspects,Impacts, AIRA, FM ManagementPlan and Mitigation Activities

ACTIONS: Corrective Actions andPreventive Actions.

REVIEWS: Management Review,Targets, Goals and Objectives.

IMPROVEMENTS: ContinualImprovement Activities.

OUTPUTS: Internal Compliance Records, Federal, State and Local ReportingRecords, Permits and Licenses. Certification to ISO 14001, OHSAS 18001 andR2.

INPUTS EXPORT:National and InternationalImport/Export laws and regulations,R2.

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Material Processing Flow:

Materials Sent orPicked-up From Client

Cell Phones, Tablets, PCs, TVs,Computer Peripherals,

DVR/DVD/CD Players, AudioEquipment, Digital Cameras, etc.

Materials Derived fromConsumer Good:

Circuit Boards, Batteries,Plastic, LCD Screen, Metal

Printers, Scanners, FaxMachines, Office Phones, PaperShredders, Overhead Projectors,

Labelers, etc.

Materials Derived fromOffice Electronics:

Circuit Boards, Plastic,Screen, Glass, Metal

Refurbish, Sort, Demanufacture (dismantle), and/orData Destruction

Items for ResaleMaterials sent to Recyclers

(for downstream vendors, refer to theFM Management Plan)

OFFICE ELECTRONICSCONSUMER GOODS BATTERIES

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Processes and Interactions:The general description of the processes and interactions of the Environmental Health and SafetyManagement System (EHSMS) are described below. The processes are arranged in the logicalorder that processing occurs, beginning at concept through delivery to the downstream vendor orcustomer. For specific detail and further description of interactions, see the specific Processand/or Supplemental Process by clicking on the appropriate hyperlink below.

Process Supplemental ProcessP01 - FeasibilityP02 - Processing Planning SP01 - Process ChangesP03 - Identification of Legal and OtherRequirementsP04 - Determining Environmental, Healthand Safety Aspects, Impacts andRisksP05 - Developing the Focus MaterialManagement PlanP06 – Developing Control (Quality) Plans SP04 – Validation and VerificationSP05 - CalibrationP07 - Filing for Licenses and/or Permits,etc. SP02 – Purchasing

P08 - Receiving SP03 - Handling, Preservation andStorageP09 - Processing Materials - General SP03 - Handling, Preservation andStorageP09-A - Processing Materials – SecureData Destruction SP03 - Handling, Preservation andStorageP10 - Monitoring and Reporting SP02 - PurchasingSP04 - Validation and VerificationSP05 - CalibrationP11 – Packaging and Labeling SP03 - Handling, Preservation andStorageP12 – Shipping SP03 - Handling, Preservation andStorage

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Environmental, Health and Safety Related Procedures:Below are the procedures. For specific detail and further description of interactions, see thespecific Procedure by clicking on the appropriate hyperlink below.

Identifier Procedure TitlePRO-01 AEHSPP, AIRA and FMMP DevelopmentPRO-02 Continual ImprovementPRO-03 Contractors CompliancePRO-04 Control of Nonconforming MaterialsPRO-05 Documentation and Data ControlPRO-06 EHS Internal and External Audits and AssessmentsPRO-07 EHS Records Identification, Storage and RetentionPRO-08 Emergency Preparedness and ResponsePRO-09 Facility Closure – Extended or PermanentPRO-10 Internal and External EHS CommunicationsPRO-11 Management ReviewPRO-12 Nonconformance, Corrective and Preventive ActionsPRO-13 Secure Data DestructionPRO-14 SecurityPRO-15 Supplier Selection Control and EvaluationPRO-16 Training and CompetencePRO-17 Vetting Downstream VendorsPRO-18 Visitor Environmental, Health and Safety Policy

Environmental, Health & Safety Documentation and Data - Hierarchy:Level I documents establish the requirements to be fulfilled.Level II documents define the methods used to fulfill the requirements.Level III documents define the accomplishment of specific methods or tasks.Level IV documents define the forms and records used for reporting the accomplishment.See the specific Level Documents by clicking on the appropriate hyperlink below.

Document or Data LevelStandards, Legal and Other Requirements Level IEnvironmental, Health & Safety Manual Level IIProcessesSupplemental ProcessesProcedures Level IIIInstructionsJob DescriptionsForms Level IVRecords (as designated within each Process, Supplemental Process,Procedure and/or Instruction)

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Reuse, Recover, Dispose Hierarchy of Responsible Management Strategies:IT-Re, Inc. has developed and adheres to a policy for managing used and end-of-life electronicequipment that is based on a “reuse, recover, dispose” hierarchy of responsible managementstrategies.

Unacceptable Management Strategies:Red on the diagram above designates that energy recovery, incineration, or land disposal areNOT to be considered unless mandated by law or in extreme emergency short term situations.

Normative References:External Documents Folder Link

ISO 14001: 2004 Environmental management systems – Requirements with guidance foruse. ISO 19011: 2011 Guidelines for auditing management systems. OHSAS 18001: 2007 Occupational health and safety management systems - Requirements. Responsible Recycling (“R2”) Standard: July: 2013

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Regulatory Resources: City of Oklahoma City, OK - http://www.okc.gov/# Oklahoma County, OK - http://www.oklahomacounty.org/ State of Oklahoma Department of Environmental Quality -http://www.deq.state.ok.us/index.htm State of Oklahoma Department of Labor - http://www.ok.gov/odol/ United States Environmental Protection Agency -http://www.epa.gov/wastes/conserve/materials/ecycling/rules.htm Occupational Health and Safety Administration (OSHA) –http://www.osha.gov/pls/oshaweb/owasrch.search_form?p_doc_type=STANDARDS&p_toc_level=1&p_keyvalue=1910

Revision History:Revision Date Rev. # Revision Description/Details Approved by:07/01/2015 Release New System Release to:

ISO 14001: 2004 Environmental managementsystems – Requirements with guidance for use, Responsible Recycling (“R2”) Standard: July 2013, OHSAS 18001 Occupational health and safetymanagement systems - Requirements: 2007.

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IT-RE / E-waste / Recycling IT Hardware and Equipment

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