The e-Stewards Standard for Ethical and Responsible Reuse, Recycling, and Disposition of Electronic Equipment and Information Technology originated in 2009 to provide a comprehensive standard for recycling, reusing, and disposing of used electronics globally. The standard was developed by the Basil Action Network (BAN), a non-profit organization named after the 1989 UN Basil Convention. It aims to control the movement of hazardous wastes and their disposal from developed countries to less developed ones. The standard supports a circular economy, promotes responsible reuse of electronics, protects the environment, takes into consideration human health, ensures data security, and promotes conformity with the Basil Convention (International waste trade law).
The e-Standards certification is important for recyclers, re-furbishers, and IT asset disposition companies that want to showcase their commitment to following the highest standards of data security to protect customer data and privacy, as well as their adherence to ethical, sustainable, and responsible practices in managing the disposal and reuse of electronic equipment.
Rising E-Waste Problem & the Need for e-Stewards Standard:
Rapid digitalization, growth of IoT devices, cloud services, and humongous data growth have led to a surge in the production of e-waste, which has become a serious environmental and health concern. As per the Global E-Waste Monitor, globally 62 Million tons of e-waste was generated in 2022 alone, out of which only 22% was known to be collected and recycled in an environmentally sustainable way. However, the generation of e-waste is outpacing recycling by almost 5 times. E-waste is dangerous, non-biodegradable, and pollutes land, air, and water directly contributing to more than 70% of the hazardous material found in landfills.
The e-Stewards standard was established in response to the growing concerns over the improper disposal of e-waste that poses significant threats to both the environment and human health. The standard has specific operational requirements that aim to:
- Protect sensitive customer data and maintain data privacy.
- Reduce pollution, diminish the environmental impact, and optimize the usage of resources.
- Ensure that processing facilities safeguard the health and safety of the surrounding communities.
- Ensure the implementation of fair labor practices, excluding practices such as child and forced labor and prisoners from managing hazardous material.
- Ensure proper disposal of hazardous e-waste.
- Operate according to global laws and regulations through the recycling chain and prevent the transportation of hazardous material from developed to less developed countries.
- Have the facilities and waste material inspected by random inspections and GPS tracking.
Section Wise Provisions of the e-Stewards Standard:
The e-Steward standard is a comprehensive 64-page document that covers the various aspects of the standard. The current version is 4.1, which was published on February 22, 2022. The e-Stewards standard requires e-waste processors to have the following:
- EMS (Environmental Management System), such as ISO 14001 or RIOS (Recycling Industry Operating Standard).
- NAID (National Association of Information Destruction) AAA data security standard Certification.
The following are the provisions of the e-Stewards standard. The standard can be downloaded from the e-Stewards website.
- Section 1 & 2: Scope & Normative References
Page 4
Section 1 defines the scope of the e-Stewards standard, briefly discusses Appendix A to D, clarifies the hierarchy of compliance with existing laws, and defines the approved usage of the standard.
Section 2 references the requirements of having an EMS and NAID AAA certification as essential components to apply the e-Stewards standard.
- Section 3: Terms & Definitions
Pages 4-12
This section defines the various terms that are used throughout the standard, such as ancillary sites, commodity, customer data, DSP (Downstream Provider), e-Stewards Processor, electronic waste, HEW (Hazardous e-waste), IDP (Immediate Downstream Provider), MOC’s (Materials of Concern), processing facility, waste management hierarchy and many more. These definitions provide recyclers with a clear understanding of each term being used within the standard, simplifying the process of adhering to its guidelines.
- Section 4: Context of the Organization
Pages 12-13
Section 4 discusses the creation, management, and implementation of an SMS (Stewardship Management System) that covers all aspects of an organization’s operation. The SMS shall apply to all locations the organization operates in, irrespective of the country. The scope of SMS shall cover all electronic equipment, assets, properties, and workers of the organization and shall apply the precautionary principle (taking proactive action), reduce the negative effects of electronic equipment, follow the waste management hierarchy as defined in terms & definitions and manage MOCs suitably.
- Section 5: Leadership
Page 13
This section defines the role of management in implementing the Stewardship, following the organization's Stewardship policy, and authorizing employees to implement and address any issues.
- Section 6: Planning
Pages 14-18
Planning encompasses various aspects of risk assessment related to environmental impact, workplace, physical, chemical hazards, etc. It also assesses the Stewardship aspects, its impact on the environment, society, & economy, and plan of action to counter the impacts after taking into consideration various provisions of Stewardship.
- Sec 6.1.3 (Compliance Obligations) requires organizations to document, review, and abide by mandatory legal and voluntary compliance obligations that are relevant to their operations.
- Sec 6.1.4 (Performance Verification) requires that the organization to ensure the verification program of e-Stewards consisting of unannounced inspections and GPS tracking by making a documented plan keeping in mind key aspects.
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Section 6.2 (Stewardship Objectives and Planning to Achieve them) requires the organization to establish measurable Stewardship objectives, have a plan for changing SMS, and implement them effectively.
- Section 6.3 (Planning for Changes) requires the organization to carry out necessary actions to manage and implement changes to the SMS with proper training, communication, and documentation.
- Section 6.4 (Contingency Planning) requires organizations to retain up-to-date documented information about contingency planning in case of disasters or temporary closure in order to manage business continuity. For this purpose, organizations must have liability insurance or its equivalent in countries that do not allow insurance to cover the potential risk. Likewise, organizations should establish funds or financial instruments to cover the cost of site clean-up or closure.
- Section 7: Support
Pages 18-19
The support section outlines the essential requirements for implementing the SMS, including the necessary resources, personnel competency, awareness of the SMS, e-Stewards certification, organizational policies, and reliable & accessible communication documentation.
- Section 7.5 (Documented Information) covers the need for additional documentation that the organization can create to fulfill the documented information requirements. However, certain documents, like the Closure Plan, Emergency Preparedness and Response Plan, and Downstream Disposition Chart, must be individually maintained. These must be retained for a period of 5 years, and worker exposure records for the tenure of their employment plus 30 years.
- Section 8: Operation
Pages 19-35
This section covers various aspects regarding the operations requirements of the e-Stewards standard.
- Sec 8.1 to 8.3 require organizations to implement SMS, use pollution/hazard controls, have an emergency response plan, and maintain industrial hygiene programs that can be expanded to cover Potentially Hazardous Processing Technologies (PHPT). This includes specifying hazard testing frequencies and mandates a review of the program by a Designated Health Provider (DHP).
- Sec 8.4 covers the management of electronic equipment and facets like identification, categorization of equipment, establishment of operational controls, and ways to ensure proper storage and transportation of electronic equipment. It also places restrictions on prison operations. However, if prisoners are to be utilized, the e-Stewards administrator must agree to certain conditions, such as ensuring that data-bearing equipment is not handled by prisoners.
- Sec 8.5 covers the reuse and refurbishment of electronic equipment. It sets forth the conditions under which sale, transfer, or donation can only be made to NAID AAA-certified IDPs and requires e-Stewards-certified organizations to ensure that electronic equipment meant for reuse is fully functional, barring outsourcing to refurbishment facilities. The standard requires proper testing of batteries and other components of electronic equipment and proper documentation of the tests performed on the device.
For data-bearing devices, data sanitization must be performed and a record of the sanitization process must be maintained. The standard requires the organization to provide shipping documentation, which must include the quantity and make of each device. - Secs 8.6 to 8.8 outline the restrictions and disposition guidelines that organizations must follow when managing MOCs. Materials must be disposed of only at approved facilities, with strict controls, due diligence, and documentation throughout the recycling chain, including transboundary movement controls.
- Sec 8.9 (Data Security) requires the organization to sanitize all customer data before the data-bearing device leaves the organization’s control, except when it is being returned to the customer or tolling (as per the definition of Tolling Operation 3.48 Page 12). While before July 1st 2022, Appendix D (Data Security) provided the provisions for data security, now the standard requires the organization to be NAID AAA Certified.
- Section 9: Performance Evaluation
Pages 35-36
The performance evaluation section requires organizations to monitor, measure, and evaluate their Stewardship Management System annually. It further requires them to inspect the facility, track the flow of electronic equipment, and perform internal audits for compliance.
- Section 10: Improvement
Page 36
This section lays down the requirement for organizations to continually improve their SMS and take adequate steps to address non-conformity promptly. It also requires organizations to maintain a record of all recognized nonconformities and potential hazards.
The above provides a brief overview of each section of the
e-Stewards standard. The standard also contains 4 Appendices. Appendix A outlines additional requirements for e-steward organizations, while Appendix B details the administrative rules, policies, and procedures that organizations must follow. Appendix C contains the requirements for e-steward bodies, including copyrights and accreditation for Certified Bodies (CBs). Appendix D provides guidance on data security. However, now Appendix D is no longer valid, and organizations are now required to be NAID AAA certified.
NAID AAA certification in its Section 4.6 (Page 18) [HARD DRIVE AND/OR SOLID-STATE DEVICE OVERWRITING ENDORSEMENT (Level 2)] outlines the requirements for overwriting hard drives and solid-state drives. The overwriting process should be written, be verifiable, and should specify details like the serial number of the device, wiping software used, verification software used, quality control, and Certificate of Destruction.
BitRaser: Secure Data Erasure Helps ITAD Comply with e-Stewards & NAID AAA
BitRaser is tested & certified by global bodies like NIST (National Institute of Standards and Technology), DHS (Department of Homeland Security), CC (Common Criteria), and ADISA for its data-wiping efficacy. It can erase data from all types of drives like HDD, SSD, SSHD, SED, NVMe, SAS, etc., and devices like laptops, desktops, PCs, Macs, servers, and mobile devices. The software generates a tamper-proof certificate of erasure that acts as an audit trail and helps fulfill compliance requirements with NAID AAA and e-Stewards standards.
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