Original Date: 06/05/2006
Revision Date: / /
Best Practice : Control and Recycling of Production-Related and Electronic Waste
Rockwell Collins has concentrated on the control and optimization of its scrap process. The entire process has been scrutinized and leaned-out at the enterprise level. Waste elimination with the scrap process has taken the form of flow management and constraint elimination, resulting in space reduction, scrap traceability, and the elimination of future remediation liabilities.
Rockwell Collins has a strong focus on controlling and recycling production-related and electronic waste (e-waste). The main objective of this initiative is to properly dispose of wastes related to production as well as e-waste through certified recycling methods for all Rockwell Collins facilities worldwide, eliminating any potential liabilities. Production-related and e-waste scrap are defined as “all electrical, mechanical, and/or electromechanical components of Rockwell Collins-built equipment that is determined to be scrapped.”
Prior practices at Rockwell Collins were defined by ad hoc approaches to the recycling of this type of scrap. For example, production-related and e-waste were collected at Rockwell Collins facilities and subsequently shipped by common carriers to multiple non-certified refineries. Not all of these refineries were audited by Rockwell Collins’ Quality Assurance, creating liability concerns. Additionally, some excess equipment was sold to employees and to the public by inventory disposal stores, again raising potential future remediation liability concerns.
In 1996 the Federal Aviation Administration originated Order 8120.11, “Disposition of Scrap or Salvageable Aircraft Parts and Materials.” Paragraph 7 within this order specifies that the performing organization should “make scrap parts unusable by means of methodical mutilation.” This paragraph, along with changing technology and increasing terrorist threats, presented a call for action by Rockwell Collins. After an exhaustive review of its process, Rockwell Collins initiated change that took many shapes. All points of scrap collection were identified, and a central scrap point was selected. Shipping options were identified and audited for secure shipping, resulting in the selection of a certified shipping carrier. After several audits of refineries, United Recycling Incorporated was selected for all recycling and refining.
Rockwell Collins now has exact traceability for all of its scrapped and recycled material down to the pound. A customs broker was also identified to help transition material through U.S. customs, which has reduced time in customs from materials imported from Singapore to 24 hours. The process was subsequently documented in RC- ESH-P-012, a company document that is now used as a reference during audits to ensure sustainment.
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