September/October 2003
Imagine a quality, environmental, health, and safety management program designed specifically for the scrap industry. ISRI’s SCRAP3 program could make that dream a reality.
Scrap recyclers face a host of challenges as they strive to operate their businesses safely, environmentally, efficiently, and profitably. The quality and consistency requirements of scrap consumers continue to rise, particularly for domestic consumers facing stiff overseas competition. Government regulations—especially in the areas of environment, health, and safety—steadily raise the compliance bar. The scrap industry’s image can also be a concern as scrap processors seek to be viewed and accepted as valued corporate citizens in their communities. To help meet these and other challenges, ReMA is developing a quality, environmental, health, and safety management system specifically for the scrap recycling industry. Among its potential benefits, the new system—tentatively called SCRAP3—can increase consumers’ confidence in your scrap products, aid your firm’s regulatory compliance, yield a more committed work force, improve the industry’s image, and—ultimately—enhance your bottom line. The following Q&A explains what SCRAP3 is all about and why it’s critical for your company to participate.
Q What is SCRAP3?
A An integrated management program being designed by ReMA specifically to help scrap processors manage quality, environmental, health, and safety issues in their businesses. The program will be user-friendly and will include all the tools a company needs to put the system into practice at its own pace. SCRAP3 will be designed for companies of every size, with a special sensitivity to the needs of smaller scrap processors. This program can also be certified just like ISO 9000 and ISO 14000.
Q Why is ReMA developing SCRAP3?
A The role of an association is to find ways to assist and improve its members and to speak for its industry with one voice, especially to regulatory and legislative bodies. There’s a need for improved industry professionalism to deal with increasing government regulation, particularly in the areas of environment, health, and safety. In addition, to remain competitive, scrap companies must constantly enhance their productivity and the quality of scrap being shipped to consumers. SCRAP3 is being designed to lead participating companies to higher performance in each of these areas.
Q How will SCRAP3 differ from existing certification programs?
A ISO 9000 is a quality standard. ISO 14001 is an environmental standard. OHSAS 18001 and ANSI Z10 are being developed as health and safety standards. SCRAP3 will offer an integrated program that marries these standards into one program specifically for the scrap industry. The result will be a streamlined program that makes sense for small, medium, and large scrap recycling companies. For instance, SCRAP3 will be a quality management program to assist processors in giving their customers what they want and need regarding the scrap they buy. It will be an environmental management program to help processors meet their compliance obligations while establishing or enhancing their image as good citizens in their communities. SCRAP3 will be an occupational health and safety management program to ensure that processors protect the health and safety of their employees, suppliers, and visitors in their facilities.
These three components of the SCRAP3 program—quality, environmental, and health/safety—will have the following eight elements in common:
- A stated policy and goals for the company
- Defined responsibilities and authority
- Specific procedures for those activities most likely to affect quality, safety, or environmental matters
- Recordkeeping guidelines
- Employee training
- Self-checking requirements to ensure compliance
- Continual improvement processes
- Management involvement to make sure the system is working.
Q Does this make SCRAP3 easier and less expensive to implement than existing ISO programs?
A Yes. A single standard means a single set of procedures, audits, records, management reviews, and corrective-action reports. Better integration eliminates redundancy and improves efficiency. An industry-specific standard will eliminate requirements that have no impact on the scrap industry while adding items essential to the industry.
If a company implemented quality, environmental, and health/safety programs to meet separate standards, there would be tremendous repetition. There would also be higher costs due to the multiple third-party certifications and recertifications that would be necessary under separate programs. Integrating the standards into one eliminates such duplication and reduces costs. SCRAP3 will also integrate with the operational practices of the scrap industry, so it will truly fit the realities of scrap processing operations.
Q What will be the main requirements for a processor under SCRAP3?
A SCRAP3 will be a systematic approach requiring a written policy that describes what the company seeks to accomplish in its quality, environmental, health, and safety management objectives. Job responsibilities within the company must be defined so there’s no doubt about individual duties. Monitoring systems must be developed that track the scrap processing cycle in your operation as well as the adherence to quality, environmental, health, and safety standards. SCRAP3 will include all the tools necessary to walk a processor through each step of the program.
Q Can a company use its ISO certifications with the SCRAP3 program?
A Yes, the programs are compatible and should integrate extremely well. If a company has an ISO 9000 and/or ISO 14001 certification, it has already completed about a third to two-thirds of the work required under SCRAP3. Also, ReMA will seek recognition of the SCRAP3 program by the National Registrars Accreditation Board and the International Association of Accredited Registrars as a management system standard to which its members can seek compliance. This will provide national acceptance of the standard as well as international recognition of SCRAP3 as an equivalent of ISO.
Q What will be the benefits of SCRAP3?
A Overall, a better-run company. Most companies that have implemented any type of management-system program such as ISO have gained insight into how they operate and how to monitor their operations to identify and solve problems more quickly. By the second year of their programs, these companies have also realized cost savings by eliminating waste. Experience shows that such savings have more than paid for the program.
With SCRAP3, projected benefits could include:
- Better visibility into and control over what you do
- Measurable continual improvement in operational performance
- Compliance with applicable laws and regulations
- The possibility for reduced regulatory fines, monitoring, and permitting time
- Lower accident and injury frequency rates and, hence, lower insurance costs
- Reduced short- and long-term liabilities
- Enhanced insurability potential
- More consistent processes and products
- Reduced costs and cycle times
- More satisfied customers
- Recognition from regulators and consumers that your company is a compliant, safe, quality-conscious entity
- Greater profitability.
Companies can also expect to be more confident that they’re in compliance with applicable regulations and, therefore, less likely to be fined. Over time, companies should see a substantial reduction in workers’ comp insurance premiums because their loss history should improve. In addition, the SCRAP3 program can enhance the company’s image as well as the self-worth and productivity of employees by increasing their involvement in the company.
Q Will scrap consumers that require ISO 9000 and ISO 14001 accept SCRAP3 in lieu of those standards?
A ReMA believes that consumers will eventually accept SCRAP3 in lieu of those standards, though this may take some time. The basis for this opinion is that SCRAP3 will be based on ISO 9000 and ISO 14001, and it should produce the same results as those programs. Once SCRAP3 is marketed to scrap consumers, they will come to recognize that it incorporates the key elements of and will produce results similar to ISO programs. However, SCRAP3 will likely do it better because it is an industry-specific, integrated management system.
Q Will being certified under SCRAP3 mean that a processor’s scrap is going to be worth more money?
A If the quality of a processor’s scrap improves such that it has more consistency in its chemistry and yields, the scrap should have more value whether the processor is SCRAP3 certified or not. However, SCRAP3 should help a processor improve scrap quality more readily and, therefore, boost its value to consumers. It’s what the processor does with SCRAP3 to improve scrap quality that counts, not SCRAP3 itself. Don’t look at SCRAP3 certification as a guarantee of increased scrap prices. Look at what SCRAP3 can do to improve scrap quality.
Q Can a company achieve certification itself, or will it have to hire a consultant or third party?
A If the company has staff who are familiar with quality programs, it could implement the program and self-certify SCRAP3 compliance. There’s a significant difference, however, between a company that simply says it complies and a company that’s certified to be in compliance by an independent third party. Each company will have to evaluate the three levels of certification—self-certification, second-party certification (that is, by the company’s implementation consultant), or third-party certification—and determine which best meets its needs. To have the maximum recognition and realize the greatest benefit, a company would likely need a third-party audit.
Q How long will it take to become certified under SCRAP3?
A That depends. Most companies should allow six months to a year for implementation, depending on what management systems or components are already in place. Companies with established management structures will find implementation smoother than those without such structures.
Another important factor is a company’s level of commitment to achieving certification. In short, management commitment is essential to success and will determine the time it takes to implement the program.
Q How much time will it take employees to make SCRAP3 work?
A SCRAP3 is being designed to minimize the amount of effort and paperwork required. That said, the amount of staff time to achieve SCRAP3 compliance will depend, in part, on whether a company uses outside help during implementation. If the company manages its certification efforts in a structured way, employees will require little additional time. A less-structured company may find several hours a week in additional work for some key employees. Another factor is the attitude of management. If a company’s management wants to streamline the business to produce a better product and make more money, that attitude needs to be conveyed to employees. The key is for employees as well as management to take SCRAP3 to heart and make it a part of their day-to-day activities. That will guarantee positive results.
Q How is SCRAP3 being developed?
A The program is in conceptual form with an outline of what it will look like. The total estimated cost to ReMA for developing the SCRAP3 program is $300,000 to $350,000, which will include development of the standard and the “introductory package” that will be provided to participants to streamline implementation. This cost will be paid by funds from scrap companies that sign up for SCRAP3 certification—hence, the more companies that sign up, the lower the cost per company. Once enough companies have enlisted, a subcontractor will be selected to develop the full SCRAP3 program.
Q How much will SCRAP3 cost an individual company?
A An ReMA task force has developed a pricing structure (see table above) and
is encouraging members to sign up by October 2003. The highest cost will be in the first and second years of implementation, while costs in subsequent years become nominal. As with its storm water program, ReMA is working to create SCRAP3 so that its cost can be spread among participating members. The association’s goal is to develop the best program and make it available to members at the lowest possible price. Again, the more companies that participate, the lower the cost per company.
Q Is SCRAP3 only for ReMA members?
A Initially, yes. Though the program would work for all scrap companies, ReMA members will be the first to have an opportunity to take advantage of SCRAP3’s numerous benefits. Once the program is operating, it’s likely that nonmembers will be allowed to participate, but at a higher cost.
Q Who will be making such decisions about the program?
A It has been proposed that a wholly owned, not-for-profit organization be established that would have its own board of directors with nine voting members. Seven of these members would be appointed by ISRI’s national chair from companies in the SCRAP3 program. Of the two other board members, one would be elected by ISRI’s standing committees and one would be elected by representatives of associations from outside the scrap industry. None of this has been finalized as yet.
Q What is the timetable for implementing SCRAP3?
A The cost/fee structure will be finalized in October 2003. In January 2004, the SCRAP3 task force will hire a subcontractor to develop the program. A draft program will be sent to the ReMA operations committee in April 2004. By July 2004, the program will be finalized, implementation materials will be drafted, and contractors will be selected. The first SCRAP3 participating company will begin the program in
October 2004.
Q What if enough members don’t sign up for SCRAP3 by October 2003?
A Since SCRAP3 provides such an outstanding opportunity for scrap processors to have an industry-specific program that offers untold benefits, it’s difficult to imagine that signup will
be a problem.
Q The value of SCRAP3 is obvious. How do I sign up?
A Contact John Hayworth, ISRI’s director of environmental compliance, at 202/662-8533 (fax, 202/626-0933), or johnhayworth@isri.org. The ReMA Web site at www.isri.org also provides background and signup information. •
Imagine a quality, environmental, health, and safety management program designed; specifically for the scrap industry. ISRI’s SCRAP3 program could make that dream a reality.