Spring 2018

VENDOR INFORMATION PACKET

5541 Central Ave., Suite 125

Boulder, CO. 80301
P: 303.543.7477
F: 303.543.7677
www.thewirelessalliance.com
Table of Contents

General Information 3
Environmental Policy 4
Health and Safety Policy 5
FM Management Plan Summary 6
FM Flow Chart 7
3rd Party Certifications 8
Data Security 9
Wholesale Tax License, EPA ID, Insurance 10
Building Security 11
Appendices
FM Management Plan A
Recent BOL to Scrap Processor B
Recent BOL to Battery Recycler C
Scrap Processor Certificates D
Battery Recycler Certificates E
2015 Audit Results F
Sample Shipment Report G
Sample Data Wipe Log H
Commercial Liability Cert. I
Worker’s Compensation Cert. J
R2:2013 K
ISO 14001 L
OHSAS 18001 M
General Information
Who We Are
The Wireless Alliance is a cell phone recycling company.
We work with wireless retail stores, e-waste recyclers,
schools, universities, state and local government, large
corporations, bulk processors, and non-profit organizations
to collect and recycle cellular equipment.
With over 300 million wireless users in the United States
alone, we continually strive to provide the best
environmental and charitable solutions for wireless
recycling.
TWA is an R2: 2013, ISO 14001:2015, and OHSAS 18001:2007
certified facility.
Since 2001, The Wireless Alliance has reclaimed thousands
of tons of wireless equipment from landfills, contributing to
a cleaner and safer environment.

5541 Central Ave. Suite 125 Boulder, CO 80301

The Wireless Alliance, LLC
Environmental Policy
We at The Wireless Alliance accept environmental responsibility for
our activities and processes. We are committed to sound
environmental practices and the prevention of pollution with the
aim of attaining our environmental targets and objectives.
The Wireless Alliance adheres to a policy for managing used and
end-of-life electronic equipment that is based on a “reuse,
recover, dispose” hierarchy of responsible management strategies.
The Wireless Alliance and its personnel are committed to
complying with the applicable environmental requirements of the
relevant legal authority, as well as the industry and any additional
requirements to which the company subscribes; including the
Responsible Recycling (“R2”) Standard.
Furthermore, The Wireless Alliance is committed to the review and
continual improvement of our EHSMS and activities to minimize
impact on the environment.
This policy is to be communicated and reinforced to all persons
working for, or on behalf of, The Wireless Alliance.

This EH&S-MS Policy is established by the Top Management of The Wireless Alliance, LLC
and approved by the President through the Management Review Process. (August 2011)
Health and Safety Policy
The Wireless Alliance is committed to the Occupational
Health & Safety (OH&S) of all persons within its facility.
The OH&S contributes to all aspects of business performance as part of The Wireless
Alliance’s commitment to continual improvement and the development of human
factors including the culture, attitude and beliefs within The Wireless Alliance.
The Wireless Alliance’s top management has set in place procedures to define,
document and endorse this OH&S policy and includes its commitment to protecting
the safety and health of persons at work and others who might be affected by their
work activities.
This policy will be achieved by:
Adherence to all relevant International, Federal, State and local OH&S treaties,
legislations and regulations;
Recognizing and implementing OH&S as an integral part of improving business
performance;
Achieving a high level of OH&S performance, and a commitment to continual
cost-effective improvement in performance;
Minimizing risk and the prevention of injury, ill health, diseases and incidents;
Acknowledging that people are the key resource and promoting the general
health and safety of employees;
Providing adequate and appropriate resources to implement the policy
including access to competent specialist advice where necessary;
Setting and publishing OH&S objectives at a minimum by internal notification;
Placing management of OH&S as a prime responsibility of line management
from most senior executive to first-line supervisory level;
Ensuring its understanding, implementation and maintenance at all levels in the
organization;
Ensuring employee involvement, participation and consultation to gain
commitment to the policy and its implementation;
Ensuring that employees at all levels receive appropriate training and are
competent to carry out their duties and responsibilities;
Periodically reviewing the policy, the management system and audit of
compliance to policy, as a driver of continual improvement;
Periodically reporting OH&S management performance internally and to
external parties where relevant.
FM Management Plan
Summary
The Wireless Alliance manages Prevention/Detection controls and meets Legal
Requirements to protect the environment, health and safety at the facility and
downstream.
TWA regularly reviews, updates, plans, and analyzes how the Focus Materials
(FMs) that pass through the facility will be managed properly on site and down
the Recycling Chain.
This FM Management Plan was developed by TWA to demonstrate how we and
our downstream vendors conform to continually meet the requirements set forth.

Definitions:
Focus Materials (FMs) are materials found in end-of-life electronic equipment
that require greater care during the recycling, refurbishing, and/or recovery
process. Due to the toxicity and other public heath and environmental concerns
found in these items, adverse effects can arise if not managed without
appropriate safeguards.
FMs Contain:
(1) Polychlorinated biphenyls (PCBs), or
(2) Mercury, or
(3) CRT glass, except for glass with lead content less than 5 parts per million,
and clean of phosphors, CRT fines, coatings, and frit, or
(4) Batteries, or
(5) Whole or shredded circuit boards, except for whole and shredded circuit
boards that do not contain lead solder, and have undergone safe and
effective mechanical processing, or manual dismantling, to remove mercury
and batteries.

Recycling Chain refers to all the downstream vendors who handle end-of-life
equipment or materials processed through our facility.
Downstream Vendors include any entity to which TWA will transfer used or end-
of-life materials including reuse, de-manufacturing, processing, materials
recovery, energy recovery, and incineration facilities.

For FM Management Plan, see Appendix A

Materials Flow Chart
3rd Party Certificates

R2:2013
Certification Body: Orion Registrar, Inc.
Certificate ID: 1013452
Registration Date: January 24, 2018
Expiration Date: March 20, 2021
*See appendix K for certificate

ISO 14001:2015
Certification Body: Orion Registrar, Inc.
Certificate ID: 1013450
Registration Date: January 24, 2018
Expiration Date: March 20, 2021
*See appendix L for certificate

OHSAS 18001:2007
Certification Body: Orion Registrar, Inc.
Certificate ID: 1013451
Registration Date: January 24, 2018
Expiration Date: March 20, 2021
*See appendix M for certificate
Data Security

The devices received at TWA are

secured in a perpetually locked
data center and wiped 0-48 hours
after entering our facility.

100% of materials are processed

using commercial products;
combinations of Future Dial,
Greystone, Pervacio, and any
manufacturers internal
mechanism’s are verified effective
for data wiping. Per R2
requirements, 3rd Party
Verifications are conducted twice
annually by a mix of industry
partners and equipment
manufacturers.
TWA keeps a Wiping Log documenting each and every specific device
that has been wiped. *See appendix H

Devices that are not data wiped

must be smelted in accordance
with our certifications.
Integrated Recycling Solutions,
INC. (IRT) is committed to
providing the highest quality
recycling of non-ferrous and
precious metals in a manner
protective of the environment. IRT
processes electronic scrap,
catalytic converts, previous
metals, ferrous metals, and non-
ferrous metals.
Wholesale Tax License,
EPA ID, Insurance

Wholesale Tax License

Colorado Dept. of Revenue: 01530024-0000

EPA COR ID:

EPA ID No. COR 000210922

Insurance
Policy Limits:
Workers Compensation (Policy# 4056673): $500,000.00
General Liability (Policy# 05-XN3202-01): $4,000,000.00
Business Owners Liability (Policy #05-XN3202-01) $4,000,000.00

See Appendices I-J

Building Security

1. Security - General:
1.1. The overall security of the facility is maintained (including
alarm systems, secure access to facility, and any special
access areas.)
2.1. The Wireless Alliance identifies personnel who have
security access to the facility.
3.1. Personnel receive security training.
4.1. There are special secure areas of the facility where
access is restricted to only authorized personnel, including
the secure data destruction area and the area used to store
devices awaiting secure destruction.
Personnel: All personnel in the warehouse who are engaged
in secure data destruction will be required to have a
criminal background check prior to being allowed any
access to secure data destruction items or the area.
 QEHS-FMMP - Focus Material Management Plan - Ver:3.0

Company Name Personnel Developing This QEHS-FMMP

The Wireless Alliance, LLC Andy Bates
Facility Address
Vice President, EHSMR
where processing is taking place.
5541 Central Ave. Suite 125 303-543-7477
Boulder, CO 80301 [email protected]

Prevention / Detection Listing of downstream vendors

Focus Materials are Controls and Legal where Focus Materials are sent
The level of risk to the Check all appropriate certifications for each downstream
identified in the Requirements to protect by the facility.
environment, heath listed. If "Other" (such as a national license, permit o
R2: 2013 Standard the environment, health (Leave one empty row between
and safety certification) explain in "Comments".
in Section 5. and safety at the facility each vendor. Include company
and downstream. name, address and phone number)

Environmental, Health and ISO

Focus Material: Low Med High Downstream Vendors R2/2013 R2/RIOS e-Stewards ISO 14001
Safety Controls 18001

Batteries
Call2Recycle - RBRC x x x

LEAD ACID - lead dioxide.

metallic lead, sulfuric acid.
ALKALINE - potassium For Prevention Controls and
hydroxide & mercury unless Detection Controls, see the
designated 'mercury free'. appropriate AEHSPP and AIRA.
ZINC CARBON - mercury and
potassium hydroxide & lead
(as noted in MSDS). SILVER
OXIDE - potassium hydroxide
& silver oxide (some with
mercury). MERCURIC OXIDE -
mercury, mercuric oxide,
potassium hydroxide and/or
sodium hydroxide. LITHIUM -
lithium. NICKEL CADMIUM – For Legal Requirements, see the
cadmium, cadmium salts, Legal and Other Requirements
potassium hydroxide and/or Matrix.
sodium hydroxide, nickel,
cobalt & lithium salts.

Whole and shredded circuit boards

DOWA x
IRT x x x
Cadmium, Mercury, Thallium,
PBBs, PBDE, DecaBDE, Reldan Metals x x x x
For Prevention Controls and
OctaBDE, PentaBDE, Detection Controls, see the
Americium, Antimony,
appropriate AEHSPP and AIRA.
Arsenic, Barium, Bismuth,
Boron, Cobalt, Europium,
Gallium, Germanium, Gold,
Indium, Lithium, Manganese,
Nickel, Niobium, Palladium,
Platinum, Rhodium,
Ruthenium, Selenium, Silver, For Legal Requirements, see the
Tantalum, Terbium, Thorium, Legal and Other Requirements
Titanium, Vanadium, and
Matrix.
Yttrium.

Please contact us for full FM Mgmt. Plan: [email protected]

BOL to IRT
Call2Recycle BOL
DOWA BOL
Business insurance
Workers comp
SVP of Business VP of Business
Development: Development:
Tim Johnson Matt Koke

5541 Central Ave., Suite 125

Boulder, CO. 80301
P: 303.543.7477
F: 303.543.7677
www.thewirelessalliance.com
[email protected]