Environmental Aspects Identification Procedure

Purpose

To describe the process to identify, analyze, and demonstrate effective control is important for identification of environmental impacts related to SkyVine ITAD activities, products, and services that it can control and can influence, both internal to SkyVine ITAD facilities and through its recycling chain activities. in order to determine those aspects that have or can have a significant impact on the environment.

Responsibility and Authority

The QEH&S Management Representative shall have the responsibility and authority to ensure conformance to the activities described in this procedure.

Procedure

1. The QEH&S Management Representative shall meet with top management consult, when necessary, with internal and/or external parties to determine significant environmental aspects of SkyVine ITAD activities by utilizing a matrix that lists systems listing the causes of environmental impacts by process area. Each process area shall be reviewed considering material inputs, natural resource inputs, product outputs, and waste streams.

2. The QEH&S Management Representative and top management shall also consider any situation including normal and abnormal operations, such as set-up, breakdown or an emergency in determining aspects.

3. Aspects shall be documented on the Environmental Aspect List.

4. Once aspects are identified, the QEH&S Management Representative and top management shall make a determination of those aspects that could have a significant impact on the environment. This process includes a 1 to 5 ranking of the “likelihood” (1 is unlikely, 5 is probable) times the “consequence” (1 is trivial, 5 is severe) of the potential environmental impact, assuming no control mechanisms (IE: documented procedures) are implemented. The resulting “rating” determines the significance. Rankings with a 20 or higher are considered significant.

5. Significant Aspects shall be documented on the Environmental Aspects List and defined further on the Significant EHS Aspects and Hazards Worksheet.

6. Environmental Aspects, including significant aspects and related objectives and targets, shall be reviewed for adequacy at least yearly during Management Review meetings.

7. 
   

8. Ensure downstream vendors of all focus materials control important environmental impacts throughout the recycling chain through ensuring they meet one of the following requirements:

• actively certified to an R2 standard, or

• certified for ISO 14001 standard, or

• sign Addendum A found on the Downstream Vendor Questionnaire document

9. Environmental Aspects shall also be reviewed when;

   1. Any major changes to activities and processes take place,

   2. Any proposed changes to activities and processes are considered,

   3. Any relevant laws or regulations are enacted or revised,

   4. Any changes to the QEH&S Policy are made

Related and Supporting Documents

6.1.3.2-F Environmental Aspects List

6.1.3.3-F Significant EHS Aspects and Hazards Worksheet

8.1.3.3-F Downstream Vendor Questionnaire

Document Revision History

Rev Description of Change Approved Date Approved By

0 New 10-22-2021 C. Vo

6.1.3.1-P Environmental Aspects Identification Procedure - Rev. 0

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