R2 Solutions voices opposition to Vermont Draft Procedures

Last month, in the article Vermont Draft Standards Require R2 certification, R2 Update reported the Vermont Agency of Natural Resources (ANR) had issued a draft plan that stated any electronics recycler providing services for the state program must, "Meet US EPA Responsible Recycling (R2) standards and be certified by a third party that they meet those standards."  R2 Solutions, and many others in the industry, applauded the ANR for recognizing the R2 standard as industry best practices.  However, the ANR recently issued the Draft Procedure for the Environmentally Sound Management of Electronic Waste for Collection Facilities, Transporters, and Recycling Facilities, which proposes a dramatically modified version of the R2 standard be adopted as regulation in Vermont.  Contained in the draft proposal are more than a dozen changes to the R2 Practices Standard, many of which are substantive. 

R2 Solutions is resolutely against creating alternate versions of the Standard. 

          In response to the Draft Procedure, R2 Solutions has issued a press release summarizing the general concerns shared by many about adopting altered versions of the standard.  R2 Solutions will be submitting comments in opposition of the proposed changes, and encourages others to also submit comment to the ANR by January 28, 2010. 

R2 Update would also like to provide a clarification to the December article, Vermont Draft Standards require R2 Certification, which stated that Connecticut would be recognizing R2 certification as one means to satisfying demonstration to the EMPs outlined in the state regulations.  Connecticut is not accepting R2 as a substitute for demonstrating that a recycler meets all the standards for becoming a state approved electronics recycler.  However, regulations do allow recyclers to demonstrate that any certification, such as R2, meets the standards for the EMS and EH&S plans (or the EMPs).

R2 Solutions explores quality control strategy options for the R2 Standard  

Recyclers seeking R2 certification are thoroughly vetted in 55 areas of concern during the auditing process.  However, the question that every certification program is challenged with remains, "Once certification is achieved, is there assurance that conformity is maintained?"  To assure continued confidence in the R2 Standard, R2 Solutions is exploring the possibility of developing a quality control strategy that will help to answer this question.

        The quality control strategy will likely include a combination of internal and external control tools.  This two-prong approach will include creating tools that will aid recyclers to internally evaluate conformity, as well as creating an infrastructure through which conformity can be periodically monitored by an independent party.  R2 Solutions believes this strategy will be crucial to maintaining the integrity of the standard in the long term.  Provision 13 of the R2 Standard likely will play a central role in the overall strategy as it requires R2-certified facilities to keep all relevant documentation in a single location.

         If you would like to provide input during the Quality Control Strategy development process, please contact Kim Holmes at kholmes@r2solutions.org.

Continuing Consistency in Auditing

This month, R2 Solutions and the supporters of the R2 Practices standard celebrate an important milestone - one year of R2 in operation.  Last January, Tech Turn (Austin, Texas) became the first electronics recycler to obtain R2 certification.  Since that time last year, there has been rapid adoption of the standard with 29 electronics recycling facilities in North America attaining R2 certification.  And, according to the certification bodies that certify companies to the R2 practices, there are dozens of recyclers currently working toward certification. 

       "This past year we have seen broad support for the standard amongst recyclers, but of equal importance, we've seen the R2 Standard gain significant recognition in the marketplace," says John Lingelbach, Acting Executive Director of R2 Solutions.  "Since R2 was put into practice one year ago, we have heard first hand from recyclers about the impact R2 has had on their operations, namely in the selection of more transparent downstream vendors.  R2 is improving industry practices, and that's exciting."

       On this important anniversary, R2 Solutions thanks the many recyclers that have chosen to demonstrate industry leadership by being certified to R2, and everyone else that has supported the development and implementation of the standard.