Meeting the Challenges of Recycling Doing it Right !

1. Workshop on E-waste Recycling and Refurbishing: Environmentally Sound Management Practices Overcoming Challenges faced by SMEs Meeting the Challenges of Recycling Doing it Right ! Mitchell Rothstein Vice President Environment, Conformance & Business Development  - FCM Recycling Guadalajara, MéxicoFebruary 15–16

2. Object of the Presentation • FCM History • Where Are We • Audits Process • Processor Challenges • Summary

3. FCM History • FCM founded in 1992 as RMP Recyclage • Started as a small scrap recycler • 1994 started recycling electronics • 18 years existence • 2006 – Became – FCM Recycling / Recyclage Inc • Current location & EPSC / ERS approved facilities * • *Lavaltrie(suburb of Montreal) – 30,000 Sq Ft – Electronic Recycling • Lavaltrie (suburb of Montreal) - 28,000 Sq Ft – Electronic Recycling • * Cornwall – 55,000 Sq Ft – Electronic Recycling • * Halifax – 30,000 Sq Ft – Electronic Recycling • Toronto (Negotiation)- Storage warehouse / Office Space • Western & Central Canada – Recyclers - Business affiliations

4. FCM History • FCM was first introduced to - Processes of Standards ? • First requested by Industry Canada • Industry Canada Project • Computer for Schools – CFS Year 2005 • One of 26 responses • One of 3 on short list • Associated with the MoE – Quebec / Recyc-Quebec Provincial Assessment Recycling Program • Based on EPSC (Electronic Product Stewardship Canada) • ERS – Electronic Recycling Standards • Approved as Primary & Secondary Processor - Provincial Programs • Ontario • Nova Scotia • Prince Edward Island • Alberta • Quebec (Primary Operations)

5. Audit Requirements • Air & Swipe Tests - Lead & Mercury Testing • Environmental Conformance • 55 Environmental Regulations • Ministry of Environmental - Application for Certificate of Approval • Ministry of Labour • Audit • Health & Safety • Process • Tracking & Traceability • Recycling Rate Audit • Downstream Verification • Mass Balancing • Recycling Rate Efficiency

6. Air and Swipe TestsLead, Mercury and 20 Other Metals • Conducted through a 3rd Party Environmental Engineer / Industrial hygienist • Collected 3 AIR samples each - lead & mercury for analysis • Collect 2 sets of 6 SWIPE samples from selected surfaces - lead & mercury for analysis • Observed work activity and number of units processed / broken during test period • Prepare report of test findings Other Metals Include: • Manganese (Mn) • Mercury • Molybdenum (Mo) • Nickel (Ni) • Selenium (Se) • Strontium (Sr) • Thallium (Tl) • Tin (Sn) • Uranium (U) • Vanadium (V) • Zinc (Zn • Aluminum (Al) • Antimony (Sb) • Arsenic (As) • Barium (Ba) • Beryllium (Be) • Cadmium (Cd) • Chromium (Cr) • Cobalt (Co) • Copper (Cu) • Iron (Fe) • Lead (Pb)

7. Audit Requirements Ministry of the Environment • Ministry of the Environment - Certificate of Approval • Applications • Environmental Bill of Rights Registry • Design and Operations Report • Based on Provincial Guidelines • Financial Assurance Report & Obligation • Site Owner Authorization • Qualifying Neighbour Notice & Acceptance • Municipal Zoning • Well Water Disbursement Analysis

8. Audit RequirementsMinistry of Labor • Ministry of Labour - Approval / Verification • Reports – Air / Swipe Testing • Annual Employee Physical Test • Employee Medical History • Training • Processes & Procedures • Substances of Concern • Good Hygiene • Written Procedures • Blood Testing • For every Permanent Employment Opening • For every 15 Calls requesting interviews • For every 10 Interviews • For every 8 Hired • For every 5 starts (after police checks) • We have 2 employees that work for more than 1 month

9. Additional Audit Requirements • Liability Insurance $5,000,000 per facility • Provincial Workman Safety Insurance Boards • WSIB – Ontario • CSST – Quebec • WSB – Nova Scotia • Environmental Policy Statement – Commitment • Environmental Aspect • Procedures Analysis • Impact Assessment • Job Analysis • Fire Emergency Procedure / Evacuation Plan (Incident Emergency Plan) • Emergency Plan Natural Gas

10. Requirements, Mass Balancing • Mass Balance calculation verification • Received Product - Gross / Tare / Net weights • Electronics Inventory Shipped • Wood shipped / Recycled • Cardboard boxes / Pallets / Shrink Wrap / Garbage • Current inventory - Gross / Net • 120 day turnaround • Downstream evaluation • ERS guidelines / Environmental Permits • Insurance / Certifications • On-Site Visits • 5 year record keeping • Recycling rate Record - FCM & Downstream processor

11. Audit Requirements, Employees • Employee Orientation, Training & Responsibilities • Safety equipment • Health & Safety • PPE usage (Personal Protection Equipment) • Work Accountability • Cleaning Procedures • Emergency Evacuation • Forklift Training & Certification • MSDS (Material Safety Data Sheets) • WHMIS (Workplace Hazardous Material Information System – Canada) • TDG (Transportation of Dangerous Good – Canada)

12. Requirements, Recycling • Recycling Rate Audit • Tracking • Receiving / Sorting • Dismantling / Shredding • Inventory – Unprocessed versus Processed / Program • Administration • Weight Confirmation = Bill of Lading / Invoicing / Certificate of Destruction • Downstream • Receipt Confirmation • Monthly Weights Received • Recycling Rate Efficiency • Process Verification • Controlled Testing - both manual and mechanical processes

13. Summary • This is a BALANCING ACT • From humble beginnings as a scrap company to one of Canada’s leading electronic recyclers • An Industry in Flux • What is the true cost of doing business / recycling ? • Are WE truly prepared to pay for a realistic program for End-to-End Life Cycle Electronic Recycling ?? • Our planet has no price

14. Thank you