Voluntary Guidelines on Preparing for Reuse. Are they safe enough in Electrical Reuse?
Did you know that the United Kingdom and The EU have set Voluntary Guidelines as to how we treat all materials used to make consumer products. For us the interest is in Large Domestic Appliances and components in White Goods and in the future, Brown Goods (small appliances). Both regions recommend we use these guidelines and for EEESafe, the important ones fall into the EN50625 Suite of Protocols.
In 2013 the EU Commission requested the Standardisation Organisations to develop European standards for the treatment of WEEE. In the UK currently we follow these standards and Government recommends them. It's doubtful we'll change after Brexit, whatever the outcome. However nothing is done until something is done, so lets remain open to the potential movement as we wait with bated breath.
Within the Suite of Protocols is the EN50614 as you’ll find from the above link. When this article was written, the new PAS141 was not published, but it is now published in Feb 2020 (now withdrawn), despite our analysis with safety issues and to be clear, it’s about the treatment processes required for the preparing for re-use of waste electrical and electronic equipment. These will be items that come back into Consumer homes, from being classed as waste and has no independent accountable person, with any proven depth of knowledge in the Repair/Refurbishment of Large Domestic Appliance repairs. We felt that we needed to communicate some basic but important information on safety, for all citizens in the EU and UK who may receive a White Goods item, that is processed using this protocol. Why do consumers need to have a White Goods Competent Person involved in Refurbishment or Repair of White Goods, just look at this document to see a few reasons
Is a Voluntary Standard Sufficient?
The existing published processed management specification, which has to be purchased is also a British Standard which falls under PAS141 name which was apparently developed by industry experts working with the Department for Business, Innovation and Skills (BIS) and WRAP. It is awarded to treatment facilities that comply with best practice in preparing used electrical items for reuse.
It is an unregulated voluntary certification awarded (subject to a purchased audit) to companies adhering to industry best practice and aims to improve standards. However, anyone operating PAS141 can be audited by only one organisation in the UK & EU. Really Green Credentials, who look to possess technical experience in this Auditing process but no actual evidenced experience or qualification to show they have any depth of knowledge in the workings of White Goods Appliances/
When the new 50614 is published, this will be EU wide at this juncture and we believe it will still be one organisation providing audits, but of course that could change and possibly be dependent on who Purchases it from BSi.
Whilst it advocates checking a product for Recall, the competency validation remains nothing more than self-regulating of the repair/refurbish person themselves. A Landlord couldn't rely on this as evidenced competence, which is what UK MHCLG guidance states. It puts the onus on the Landlord who hasn't been given guidance on who is competent. It's certainly not an Electrician, which UK Government agreed does not have evidenced skills from their qualification. Nobody is assessed then independently, for their depth of knowledge of each appliance, of which White Goods are of the most concern to the Fire Services.
The EEESafe Certification and Qualification independently provides an assurance to consumers so they can ensure they engage a competent person when paying for a repair or refurbishment of Large Domestic Appliance. Operating a higher standard that also helps to intercept Used Appliance Recalls for sale or donation, delivers more trust, helps minimise rogue trading, and ensures repairers have the correct insurance in place, is unique to EEESafe. Through it's own Appliance Safety Register it can also evidence recycling, waste prevention and environmental impact through local Community Metrics. It even creates money and community currency to help tackle poverty, democratically gifting sums in each community where an EEESafe DAT (Domestic Appliance Technician) resides.
EEESafe and BSi meet
We had the privilege of meeting with BSi and RGC who kindly let us have a look at the revised as yet unpublished new EU50614, which will be based on the PAS. We wrote a confidential analysis on this standard and we took into consideration the old version as well from a White Goods Perspective, and provided it to BSi for comment.
We had a favourable response and appreciation that we were contributing something of value with our own Standard. Other industries were compared as similar examples of good practice, with some arguably creating confusion however well intentioned.
It was stated that the EEESafe standard addresses many aspects of safety (in terms of the competency of those involved in re-use) that are not in the European Standard due to these being outside of its scope. It was further stated that the European Standard does address competency but only its Annex, but we felt that it left too many safety gaps.
It was clarified that BSi's role was to stick to what it was mandated to do by the EU and that the outcome of any European Standard is the result of expert input (from all participating national member bodies) generated via a process of managed consensus.
- A MISSED OPPORTUNITY. There was no Representation of Independent White Goods Reuse expertise on the Committee – which we offered at the time it was doing it’s work. Therefore we must question the expertise, potential conflicts of advice from other board members who sold new White Goods and what value was lost that EEESafe now brings to the table with it's qualification.
- EEESafe Prevents WEEE Waste prevention is a higher priority than creating WEEE. Industry and Government appear more determined to set targets for Waste thereby encouraging it, than it does for Waste Prevention. The Right To Repair also needs higher accountability in electrical safety, something we could offer.
- GOVERNMENT SAYS WE’RE SAFER. In a previous meeting we met the Dept of BIS in 2016. Read what they said to us. EU & BSi could have noted this when we offered input. We have almost 60 years combined experience in White Goods Repair and Recycling.
- UK Housing Minister allows anyone to self certify they are competent in Appliance Repairs In Houses of Multiple Occupation, Electrical Safety checks must be conducted every 5 years at a minimum, as part of the Governments’ safety drive. Yet this PAS allows anyone to self certify they know what they’re doing? A PAT Test does not prove an item is safe to use. Read their document HERE. Trusting this standard in rented homes is increased risk and their is ignorance with MPs in parliament who pass laws as highlighted in the evidence we can show from this article.
- CONFIDENCE AND SAFETY IN ELECTRICAL REUSE UNDER THREAT The tests and processes of the PAS141, some of which are “minimum” standards, could mean repaired items will not last long, nor be fully tested for safe reuse. There is insufficient evidence of competence and depth of knowledge in White Goods refurbishment from WEEE that is returned to home use.
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EEESafe Findings on why it's Safer & better for the Environment
These were reported with other notations to BSi after they kindly allowed us access to the latest PAS141
- An approved Independent Competent Person Standard, Certified or Qualified to support it's Competence levels.
- A Safer standard than the EN Standard evidenced from our Referenced Notes 2. a/b/c – 3. a/b – 4. – 5. – 6. – 8.- 11)
- A Standard that can lead to the potential of more local repair and refurbishment jobs in all local communities.
- A Standard that can lead to transparent outcomes that evidence tackling poverty in participating local communities.
- A Standard that leads to better Environmental outcomes than that of the EN Standard.
- A Standard that ensures a person is properly insured when repairing or refurbishing White Goods Appliances.
- A Standard with a process that ensures Used appliances are tested for the owners’ home environment.
- A Standard that covers Non Waste arisings.
- A standard that encourages Waste Prevention. The EN Standard doesn't promote local work and seeks to feed the Waste Industry for targets.
- A Standard that tracks Appliance accessories, Recycled components and Appliances end of life.
- A Standard that allows citizens to make money in their community from prevented Waste Appliances and Parts.
- A Standard that delivers a more efficient model for Waste Prevention and Recycling of Appliances and their spares
- A Standard developed to increase Electrical Reuse Confidence Referenced from our (Notes 4.- 6. – 9. – 10. – 11.)
- A Standard that has a Qualification to support its Competence levels. PAS141 is an unregulated Protocol, not a Standard.