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RIOS: an assessment

We applaud ISRI for introducing RIOS. Within the scrap recycling industry, RIOS has generated much talk about documented, disciplined management systems to control and improve quality, environmental, and safety performance. This is good. The RIOS buzz has prompted several scrap recyclers to come to us for assistance. Speaking selfishly, of course, this is also good. With our decade-plus of experience in working with scrap recyclers nationwide, Kantner & Company is better equipped than anyone else to help scrap recyclers implement RIOS. But the emergence of RIOS has also created a dilemma. . . .(continued below)

Introduction (continued)

The dilemma RIOS presents is this: Scrap recyclers must now choose between implementing a RIOS system, or implementing a system compliant with the international ISO/OHSAS standards.

At first blush this seems like an easy one. Why should a scrap recycler go with ISO/OHSAS when there is RIOS, ostensibly designed just for scrap recycling firms?

When you face the brutal facts, this turns out to be no choice to be made lightly. Implementing a management system is for any scrap recycler a major step – similar to selecting a big ticket equipment item like a shear or shredder. Management system implementation, whether RIOS or ISO, requires a long term commitment of energy and resources. Before taking the plunge, the scrap recycler should be well informed and fully aware of all the realities.

And so, at the request of several potential clients, we performed a close and detailed analysis, comparing RIOS with the ISO/OHSAS standards that have been around for years. Our goal here is not to grind any particular ax – as stated, we are as prepared to help with RIOS as we are with ISO/OHSAS. Our goal is to identify the issues and the facts relative to the two different approaches, so that scrap recyclers in general, and our clients in particular, make their decisions based on facts and evidence.

What is RIOS?

"Recycling Industry Operating Standard" (RIOS) – formerly Scrap3 – is a quality, environmental, and health/safety (QEH&S) specification designed for scrap recyclers.

Where did RIOS come from?

RIOS is marketed by Institute of Scrap Recycling Industries (ISRI), a scrap recycling industry trade association.

What's the difference between RIOS and the ISO/OHSAS standards?

Four key differences.

Difference 1: Parentage.

The organizations that developed, and sponsor, RIOS and the ISO/OHSAS standards are significantly different.

• RIOS was developed by ISRI executive staff and representatives from the membership, assisted by contractors and industry specialists.
• ISO 9001 (quality management) and 14001 (environmental management) are sponsored by International Organization for Standardization, a worldwide standards writing authority made up of national standards groups representing 156 countries. (The U. S. ISO representative is ANSI: American National Standards Institute.)
• OHSAS 18001 (safety management) was developed under the leadership of a British standards institution in cooperation with 13 standards organizations from various countries.

Difference 2: Cost.

• Unlike ISO/OHSAS, RIOS is a fee-based membership program. First, members pay an initiation fee, for which they receive a toolkit of system implementation materials and other services. Then, to maintain RIOS membership members also pay an annual maintenance fee of $975 per year per yard, capped at $20,000 per year. These fees do not include any outside consulting costs (optional) or certification costs (mandatory). Nonmembers pay substantially more.
• ISO and OHSAS standards together cost less than $500. Implementation toolkits specific to scrap recycling operations are available for under $2,000. As with RIOS, registrants to ISO/OHSAS pay certification fees to maintain registration. But with ISO/OHSAS there are no ongoing annual maintenance fees as there are with RIOS.

Difference 3: Recognition / acceptance / credibility.

• RIOS is new. As of yet, it has no certifications or performance track record.
• ISO 9001, first published in 1987, is recognized and accepted in 156 countries. Some 800,000 companies worldwide are certified. Of these, 125 are North American scrap recycling certified firms.
• ISO 14001, first published in 1996, is recognized and accepted in 156 countries. Some 115,000 firms worldwide are certified. Of these, 25 are North American scrap recycling certified firms.
• OHSAS 18001, first published in 1999, is recognized and accepted in 75 countries. Some 8,000 firms worldwide are certified. Of these, 2 are North American scrap recycling certified firms.

Both ISO and OHSAS are readily recognized and accepted internationally. Certification to these puts the scrap recycler on a par with excellent manufacturers of all kinds all over the world, not just scrap recyclers in the United States.

Difference 4: RIOS is not the same as ISO/OHSAS.

While they have many aspects and requirements in common, there are also significant – and critical – differences. A fully compliant RIOS system would not pass an ISO/OHSAS audit.

Isn't RIOS "functionally equivalent" and "on a par" with the ISO standards?

Whatever these terms mean, there are in fact significant differences between RIOS and the ISO/OHSAS standards. In 115 individual instances, the RIOS specification departs from the requirements of ISO and/or OHSAS either by ignoring ISO/OHSAS requirements completely, or by watering them down significantly.

So RIOS doesn't cover everything that ISO/OHSAS requires. Does this matter?

It most certainly does if your scrap recycling firm (like so many) has one or more consumers that require ISO certification. If so, you should understand that RIOS certification is not the same as ISO/OHSAS certification. A RIOS certificate is not an ISO certificate and would make no mention of ISO and/or OHSAS compliance or equivalency. Consumers, and others who may require ISO certification, may not accept RIOS certification in its place.

Beyond that, the compliance gaps and resulting system shortfalls will most likely keep a RIOS management system from adding as much value as an ISO/OHSAS-compliant one.

But American National Accreditation Board (ANAB) accredits RIOS just like they do ISO - don't they?

ANAB says it will accredit RIOS as an 'industry standard.' By doing this ANAB would in no way endorse RIOS as ISO-equivalent.

Wouldn't RIOS be better for us because it is specifically relevant to scrap operations whereas the ISO and OHSAS standards are not?

ISO and OHSAS, being deliberately generic, are as relevant to scrap as RIOS is.

Doesn't ISO have requirements that are not relevant to scrap recycling?

Yes. These can legally be excluded.

But with RIOS you're implementing one system, whereas with ISO you implement three separate ones.

ISO/OHSAS does not require you to implement three separate systems. You are free to implement an integrated ISO/OHSAS management system that is 100% free of overlap. This has been done for years. Today, Miller Compressing Company (Milwaukee, Wisconsin) and Wilmington Iron & Metal (Wilmington, Ohio) have integrated ISO/OHSAS systems. Several others are working toward this goal during 2006/2007. These integrated systems can be certified by a wide variety of registrars at considerable savings.

Isn't it true that RIOS is written in plain English rather than bureaucratic jargon, so it's easier to understand?

See for yourself. Here, side by side, are the Corrective Action requirements from ISO 9001 and RIOS. Which is ISO, and which is RIOS?

Doesn't RIOS's implementation guide, toolkit, and templates make system implementation easier and less costly than going with the ISO/OHSAS standards?

Toolkits and templates are valuable and important. They certainly make a system easier to design and implement. The RIOS version is not the first scrap-recycling-specific toolkit for quality / environmental / safety management, nor is it the only one.

The toolkit is the easy part. What's tough about implementing a truly value-added quality / environmental / safety management system -- what takes so much hard work and effort and time – is, to start with, modifying the generic system toolkit/template documents to fit your particular organization. In this, RIOS is no easier than ISO/OHSAS. No two scrap recyclers are alike. No toolkit on the market is plug-and-play.

As for the cost differences, to reiterate: RIOS is very new. There are no certifications of record and no track record to speak of. So any claims as to cost savings are purely speculative. Our decade-plus experience of working in dozens of scrap recycling operations has been that implementation costs are driven almost exclusively by organizational issues unrelated to the Standards themselves – issues such as size of the recycling organization, the scope of its processes, the commitment of top management, the investment of resources, etc.

Which approach does Kantner & Company recommend? ISO/OHSAS or RIOS?

That's up to the client. Our job is to provide honest, balanced, accurate information -- and then diligently help each client achieve the objectives that they set by whatever approach they choose.