Up to standard

How does a facility become certified by the Recycling Certification Institute (RCI)? This is an often-asked question that needs context for its answer. The reason for this is because, frequently, there are other related questions and drivers for the question being asked in the first place.

The Milwaukee-based Construction and Demolition Recycling Association (CDRA), through its members and other stakeholders, like the U.S. Green Building Council (USGBC) and U.S. Environmental Protection Agency (EPA), both based in Washington, had received comments, inquiries and concerns regarding accuracy of the numbers reported by construction and demolition (C&D) recycling facilities.

With many local and state jurisdictions measuring the recycling/diversion rates as well as the USGBC’s Leadership in Energy and Environmental Design (LEED) program awarding credits for C&D recovery and recycling, the importance of ensuring a high level of confidence in the accuracy of the recycling and recovery rates reported by the C&D facilities became a key issue that required addressing.

The CDRA responded by engaging these and other industry stakeholders to develop a process that would professionally review and certify the recycling/recovery rates of these operations. The Certification of Recycling Rates (CORR) Protocol was developed to International Organization of Standardization (ISO)-level standards and the RCI, with offices in Sacramento, California, was created to meet the growing need for reliable recycling and recovery reporting by C&D facilities, which are verified and certified through the CORR Protocol.

following the steps

The first step in becoming certified is registration. RCI website”, www.recycling certification.org, provides information on process and requirements. One of the key requirements is that a facility must have certified scales.

While that may seem obvious, in plenty of instances, C&D facilities may be legally operating under their state or city permits without scales. It is not unreasonable for them to assume they could be certified under RCI’s program. However, the CORR Protocol does require scales because it produces a set of records that can be audited and verified, and scale weights are more accurate and reliable than estimated volumes.

The operator identifies the facility name and location and provides contact and payment information. Following the initial submittal, RCI may contact the facility and conduct a brief interview to determine eligibility and provide some assistance to the facility going forward.

Once RCI approves the establishment of the account, the facility can then enter more information about the operation. Information could include hours of operation, materials accepted and permits. The operator then enters the most recent month of data for materials received and shipped from the facility.

RCI reviews the initial data submittal and how the materials have been characterized for recycling and/or disposal. It is known that facilities and regions may characterize materials differently, so RCI wants to ensure the same definitions and terminologies are used for a standardized approach to material characterization.

Once RCI approves the account, the facility is displayed on RCI’s registered facilities webpage. The facility will then enter the previous 11 months of data so a full year is represented. The information posted by the facility has yet to be audited and verified. The facility must also make substantive progress toward certification to maintain its status on the registered facilities page.

submitting the application

The next step is submitting the application for certification. This application contains detailed information about the facility or line that is to be certified and can be found on RCI’s resources webpage.

The application can expand based on the amount of information a facility may need to enter. This form allows for the provision of information that was not included during registration, and can be kept confidential if the company does not wish to post the information to the website. It also provides more detail for the institute to review during the verification process.

Submittal of the application for certification initiates the official engagement and prequalification process. This process serves as the initial desk audit to ensure the validity and accuracy of its data and operations in accordance with its permits and applicable laws and regulations. Following the desk audit and prequalification, RCI will dispatch one of its trained evaluators to conduct on-site verification of the information provided.

In addition to the information in the application, the facility will submit two other documents critical to the review and prequalification process.

The first document is a data file that consists of the most recent 12 months of inbound and outbound materials. The template communicates which data sets and categories RCI requires, but facilities may also define any material codes they may use so that RCI can more easily compare and verify this data with what was submitted through the facility’s webpage report. These data files remain confidential between RCI and the facility.

The second document is a narrative about the facility/operation. The narrative describes the operation by providing information on scales, unloading/inspection, separation, screening, storage and processing. It provides information on equipment and buildings and describes the process of how materials move through the facility and what materials are produced for market.

This narrative is important for several reasons. It demonstrates that the operator has a documented working knowledge of the facility, and it establishes a baseline for the certification. Also key to the narrative is it creates a picture of the operation so RCI knows what to expect before stepping foot on-site to conduct the evaluation. If the facility is using proprietary technologies or processes, it may identify them as such and request confidentiality.

the evaluation

RCI trains C&D industry professionals on the CORR Protocol and evaluation methodologies. Once a facility has achieved prequalification, a RCI evaluator will contact the facility to coordinate an on-site visit, which typically takes a full day. The evaluator will develop an evaluation plan based on the information provided by the facility. The evaluation consists of observation of operations and a review and audit of records.

The main purpose of observing the operation is to verify the information the facility submitted, ensuring the facility is operating in conformance with its permits and has appropriate signage, properly trained employees wearing personal protective gear and to investigate any potential risks.

The second half of the site visit is primarily focused on document review and verification. This entails reviewing key documents such as permits, training manuals and records, scale certificates and inspection records. The evaluator also will sample weight and sales tickets to verify accuracy or investigate any errors or inconsistencies.

It is common for the evaluator to observe and ask questions of the scale, load checking and data management staff regarding their responsibilities and functions related to process and the collection, use and management of data.

In the end, RCI must be able to make affirmative statements about the facility in several key areas. These include regulatory compliance; use of scales; supporting data for rate estimates; data transcription and management; employee training; and performance standards. The evaluator will review his or her findings from the site visit and develop an evaluation report.

The evaluator first submits the report to the facility for review and, barring no objection and assuming the facility is qualified, the evaluator will then submit the report with a recommendation for approval of certification.

Upon review and approval, RCI’s executive director designates the facility as a certified facility and it listed on the certified facilities webpage. The facility’s evaluation report is included for transparency.

benefits

While becoming certified under the CORR Protocol may take some effort, there are some clear and overwhelming benefits. A facility certified under the CORR Protocol meets the requirements of the USGBC’s LEED pilot credit (MRpc87). This means that LEED projects taking C&D materials to a facility certified by RCI automatically qualify for an extra point regardless of the facility’s recycling rate. This additional point is a bonus of certification, especially for those facilities where recycling rates may have declined because alternate daily cover no longer is counted under LEED v4.

Some facilities have recognized after completing the certification process that they have participated in what amounts to a business process and integrity audit. They have used this outside perspective and newly gained insights about their operations to implement improvements.

Finally, certification under this national standard program leads to accuracy, credibility and transparency. And with a CORR Protocol certification, facilities are able to promote their recycling and recovery performance as “real, verifiable, reproducible and reliable.”

Stephen Bantillo is executive director of the Recycling Certification Institute (RCI), Sacramento, California. More information on the certification process is available at www.recyclingcertification.org.