RCI’s Certification Process Featured in Construction & Demolition Recycling magazine
Posted on August 9, 2017
Today’s post is a two-fer…
Part One: Kristin Smith, editor of Construction & Demolition Recycling magazine, posed the question, “How does a facility become certified by the Recycling Certification Institute (RCI)?” While every facility is different, the CORR Protocol follows a basic set of compulsory elements while being flexible enough to accommodate a variety of business and operational models. The article talks about the process from a relatively high level, so please feel free to contact us and we would be happy to discuss in greater detail how an RCI-Certification can work for your facility.
Part Two: The second part is actually an article within an article, modified to fit this format. Kristin Smith and Meri Soll talk about StopWaste‘s goal of leveling the playing field in C&D facility recycling performance reporting. StopWaste is a public agency in Alameda County responsible for a variety of successful resource management policies and programs in their community. Through StopWaste’s collaborative efforts, numerous cities have signed on in support of StopWaste’s program that provides incentives for certain C&D facilities to become third-party certified to meet the requirements of the participating cities, CalGreen (State of California), and USGBC’s LEED Pilot Credit criteria (MRpc87).
Thank you to Kristin for the opportunity to explain our process and to StopWaste for their ongoing support of a level playing field through a National Standard for third-party certification.
You can read the stories in their original format in the July 2017 edition of Construction & Demolition Recycling magazine or check out the modified text version below.
Up to standard
Receiving a certification from the Recycling Certification Institute requires a number of steps, including data gathering and documentation.
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.
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.
Leveling the playing field
By Kristin Smith
StopWaste, based in Oakland, California, is a public agency that helps Alameda County’s businesses, residents and schools waste less, recycle more and use water, energy and other resources efficiently. Construction and demolition debris (C&D) is no exception.
About seven years ago, cities within the county passed ordinances requiring a minimum of 50 percent diversion of C&D materials generated from construction projects. Many staff members in the cities were unclear on how to implement the ordinance; specifically how to assess a facility’s recycling rates. As a result, StopWaste’s Deputy Executive Director Tom Padia and Senior Program Manager Meri Soll compiled a list of facilities that were processing mixed C&D materials from construction projects in Alameda County.
“StopWaste and City staff worked together to compile a list of facilities, incorporating facilities most utilized by Alameda County contractors. We developed a reporting form for the facilities to complete and then conducted a site tour” says Soll. “We utilized their self-reported data at their word and put a list together that incorporated recycling rates for cities to utilize.”
At first the list helped cities implement the C&D ordinance, but as building code became more stringent and Leadership in Energy and Environmental Design (LEED) certification increased in prevalence, Soll says the list became used in ways that was never intended.
According to Soll, “It became a convenient list for contractors trying to meet LEED requirements. It was being referred to in ways not originally intended, and the data wasn’t certified [by a third party]. At the end of the day, this list was just self-certified recycling rates.”
She says StopWaste wanted to “get out of the C&D facility list business” and was looking for entities that provided third party certification programs that could be used regionally, to reduce or eliminate the redundancies, inconsistencies and inefficiencies of multiple rating and audit reviews.
The agency was part of initial discussions with the Construction & Demolition Recycling Association (CDRA), Milwaukee, and the U.S. Green Building Council, Washington, when the Certification of Recycling Rates (CORR) program was developed as a way to “help certify facility recycling rates utilizing one standard.”
In the push to have the certification adopted regionally, the needle wasn’t moving according to Soll. On the municipal level some officials felt the cost was too high (about $7,000 per year) to impose on the facilities and therefore were not willing to participate in a regional program. Feedback from facilities, she says, was that they didn’t see the need for certification if cities were not requiring it. Cost wasn’t so much a factor from the facilities’ perspective, she adds.
Soll says she circled back with all the cities in Alameda County asking them to require the certification in order for the program to move forward. The Alameda County cities of Hayward, Alameda, Berkeley as well as the County’s largest city, Oakland, signed on to require contractors to take mixed C&D materials to a third party certified facility that meets the LEED standard (currently only RCI meets the LEED standard). She says these communities recognize the importance of verifying a facility’s recycling rate as accurate rather than simply requiring a facility to meet a certain minimal recycling rate. “A facility’s recycling rate goes up and down based on markets, so requiring a certain recycling rate for a facility isn’t really that helpful,” Soll says. “Requiring a facility to get certified by a third party entity that assesses the facility’s ability to recover is a better marker than meeting a minimal recycling rate”.
The four cities that have currently signed onto the program represent about half of the population in Alameda County, with other cities poised to join. Soll says she thinks the certification program will get traction from the facility-level. “These cities’ commitment to requiring contractors to take their mixed C&D materials to a certified facility should be enough to get 10 to 12 of the heavily utilized mixed C&D facilities certified. When that happens then we have done our job,” says Soll.
Another factor affecting mixed C&D recycling facilities is the large increase in new construction in the Bay Area. Contractors are travelling far distances from their main offices and the destination of mixed C&D materials is changing. Many contractors are hauling their materials on the way back to the office and are utilizing facilities that both Alameda County city staff and StopWaste staff are not aware of. Many cities utilize the software Green Halo, which is a web-based waste management tracking tool. Green Halo utilizes recycling rates provided by RCI, or if not certified, a self-reported rate is utilized. StopWaste monitors the facilities utilized in Green Halo. Soll says she gets calls about once a week asking for a facility to be inputted into the Green Halo system, claiming as high as a 92 percent recycling rate. She says rates that high are suspect, especially when she knows facilities that have invested millions of dollars in infrastructure and have had their rates certified are achieving closer to 75-80 percent diversion rates.
“I do feel for these facilities that have millions of dollars in infrastructure that are constantly being scrutinized by their local environmental agencies and their cities to make sure they are operating by their permit,” she says. “It is unfair competition when someone else can say they are getting a 90 percent recycling rate and not doing much sorting, and taking materials and transferring them to a facility for ADC (alternative daily cover).”
She concludes, “We would love to level the playing field and for every city in our area to say, ‘ You must take your mixed C&D materials to a certified C&D facility where the recycling rate has been verified by a third-party entity that meets the LEED standard.’ That is the big goal a goal we have been working toward for a long time.”
