April 2011  
R2 Update
The latest information on Responsible Recycling (R2) Standard 
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Welcome to the R2 Update!  This newsletter contains relevant industry information and news pertaining to R2 Solutions, and more importantly the R2 Standard, the leading certification program for the electronics recycling industry.
In This Issue
R2 Governing Council gets name change to R2 TAC
Initial R2 TAC members announced
Overview of the R2 revision process
Industry Caucus to be formed
Quality Assurance program feedback
Conformity review: Downstream Due Diligence

R2 Governing Council gets name change to R2 TAC

    

R2 Solutions' is changing the name of the multi-stakeholder group that will be reviewing and recommending changes to the R2 Standard.  To date it has been referred to as the "R2 Governing Council".   However, the R2 Board of Directors has decided it will be more appropriately named the "R2 Technical Advisory Committee" or "R2 TAC" for short.  This name is more descriptive of the group's role and more consistent with the lexicon of standards development organizations. 

     A description of the TAC's role can be found on the R2 Solutions website.

     

Initial R2 TAC members announced

 

R2 Solutions would like to thank everyone who expressed interest in serving on the R2 Technical Advisory Committee (TAC).  The R2 Solutions' Board of Directors has considered the many nominations submitted and has selected an initial round of members to serve on the R2 TAC.  Initial voting members of the R2 TAC include:

  • Mike Watson, Dell (OEM)  
  • Chris Cleet, ITIC (Representing OEMs)
  • Bill Long, Wistron (ODM)    
  • Chris Boik, Best Buy (Large Customer) 
  • Robert Gamer, UPS (Large customer)
  • Bob Holcombe, General Services Administration (Large customer)
  • Renee St. Denis, Sims (Recycler)
  • Joe Clayton, Synergy Recycling  (Recycler)
  • Eric Harris, ISRI (Representing recyclers)
  • Rike Sandlin, Intechra (ITAD/Refurbisher)
  • Neil Simmons, Tech  Turn (ITAD/Refurbisher)
  • Colin Davis, WR3A (Representing refurbishers)
  • Josh Lepawsky, Memorial University - Dept. of Geography (Environmental/Trade Expert) 

Initial non-voting members (i.e. auditors, CBs, consultants, and other involved in the implementation of the Standard) include:

  • Kelley Keogh, Greeneye Partners (Consultant and auditor)
  • Eric Capps, ERM (Consultant and auditor)
  • Veryl Horsley, SGS (Auditor for CB)
  • Betsy Delaney, First Environment (Consultant and auditor)
  • Lynn Rubinstein, R2 Solutions Board Member

R2 Solutions expects the remaining positions on the Committee will be filled over the next number of weeks and that R2 TAC activities will commence by the end of May.

Overview of the R2 revision process

 

The role of the R2 Technical Advisory Committee (TAC) is vitally important to the governance of the R2 Standard.   The TAC is responsible for the content of the R2 Standard and keeping it up to date as technologies, management practices, and the materials processed change within the electronics recycling industry.  The R2 TAC will accomplish this through a process that is balanced, transparent, and open to input from all interested parties, including the general public.  The TAC will begin the process of updating the standard this summer.

     The process will begin with an issues identification phase. The TAC will request input from the public and engage in initial deliberations regarding issues that should be addressed by changes to the Standard. 

     The R2 TAC then will work to address these issues, developing new draft language for the relevant sections of the Standard.  This will be followed by a public comment period, during which the public may provide feedback on the proposed draft language. 

     The TAC will then deliberate on the public comments received, draft amended language accordingly, and vote on whether to recommend the language changes to the R2 Board of Directors for final adoption.  The Board of Directors will then adopt the language or remand it to the TAC for further consideration. 

     This process, plus a description of the role of voting, and non-voting members, will be contained in the R2 TAC Charter, which is under development and should be available for public comment in May.

Industry Caucus to be formed

 

During the Technical Advisory Committee (TAC) nomination process, R2 Solutions received many more nominations for recycling industry participants than there are seats for this group on the TAC.  Because opportunities to participate on the TAC are limited, R2 Solutions sees value in creating additional participation opportunities for individuals who could bring important expertise and perspective to the R2 Standard revision process. 

     R2 Solutions is forming the TAC Industry Caucus, which will be a group of individuals from the electronics recycling industry that are committed to supporting the work of, and providing input to, the industry members on the TAC.  Caucus members will act as a resource, sounding board, and information conduit for the recycling industry members of the TAC as the TAC updates the Standard.   

     Those industry nominees that are R2-certified and who were not selected to serve on the TAC will be contacted to see if they are interested in serving on the Industry Caucus, though it will be open to all R2-certified companies.  As the TAC process progresses, there will be the possibility of establishing caucuses for other stakeholder groups depending on the level of interest the process generates.


Quality Assurance program feedback


R2 Solutions thanks all of those who provided comments on the Quality Assurance program whitepaper.  In general, the feedback received stresses the importance of the education and training components of the program.  The comments suggest if these components are robust, this could reduce the need for a spot-checking program.  In particular, the Guidance Document was identified as an essential tool for providing consistent interpretation of the provisions of the Standard.  Providing regular training opportunities for recyclers was also identified as a high priority.  Development of both of these tools is currently underway.

      R2 Solutions has decided to extend the comment period one week to give those who have not yet had the opportunity to submit comments the chance to do so.  The comment period will close on May 6th.  A copy of the whitepaper can be downloaded from the Quality Assurance web page.  Please provide feedback and comments using the web-based form on that same page.   


Conformity review:  Downstream Due Diligence

Conformity review is a monthly column highlighting important operational  

information concerning the R2 Standard

 

 

R2 certification is one way for electronics recyclers to demonstrate leadership in environmental performance.  The R2 Standard requires specific treatment of Focus Materials (FMs) by R2 certified facilities and all tiers of their downstream vendors receiving FMs.  Customers of R2 certified recyclers should feel confident that they have selected service providers who use downstream vendors that manage FMs in accordance with the Standard and who continually monitor the performance of these vendors.  

It has come to the attention of R2 Solutions that Provision 5 (e) and (f) of the R2 Standard are proving challenging in some instances to implement and audit.  Nonetheless, all R2-certified recyclers must conduct downstream due diligence on all tiers of downstream vendors for FMs.  And all auditors must interpret and evaluate this set of requirements with equal rigor. 

It is the responsibility of each R2 certified recycler to perform adequate due diligence when selecting downstream vendors for FMs.  R2 certified recyclers should also be able to demonstrate a plan for continued monitoring and evaluation of vendor performance.  Each R2 certified recycler must maintain, and be able to produce, the following information for their downstream vendors for FMs (all tiers):

  • A flow chart of each tier of vendors for each FM;
  • Bills of Lading showing the flow of all FMs to these vendors' facilities and acknowledgment of receipt from each of these facilities;
  • Documentation relating to each of the requirements of R2 Provision 5e (EMS, permits, legal exports, etc.) for each downstream vendor of FMs;
  • Demonstration of vendor audits, including the date of the audit (on-site and/or desk audits), criteria evaluated, and findings.  The criteria should include all the elements of Provision 5e, and the dates which audits were performed of 3rd tier (and 4th, etc.) downstream FM vendors.  Vendor audits can be conducted by either a third party or the R2 recycler, however in each instance the paperwork obtained must be equally clear in showing conformance by each downstream vendor to the requirements of Provision 5(e). 

Downstream due diligence is critical to ensuring worker safety and environmental protection through final disposition of Focus Materials.  Further clarification on what constitutes adequate demonstration of downstream due diligence will be included in the R2 Guidance Document.  

     R2 Solutions also will be producing an information package for downstream vendors.  Use of this information package will be voluntary, but R2 certified recyclers and those pursuing R2 certification may use it as a means of facilitating communication with downstream vendors.  The package will explain the need for downstream transparency, as required by the R2 Standard, and describe the information that R2 certified recyclers must request in order to meet due diligence requirements.

We want to hear from you!  Please send along any R2 related news or information that you think would be important to share with the electronics recycling community. 

Thank you!