R2 Solutions Board of Directors sends letter to the TAC about maintaining and promoting the integrity of the Standard

Earlier this month, R2 Solutions made the decision to remove Intercon Solutions from the directory of R2-certified recyclers on the R2 Solutions website.  This decision was based on evidence of major non-conformances as announced in a press release distributed on July 5.  Taking steps to further address this issue, the R2 Board of Directors has sent a letter to the Technical Advisory Committee (TAC) highlighting the gravity of the situation and requesting the TAC help develop the steps needed to address future situations of this sort.   

     In the letter, the Board points out the need for "the Board and the TAC do everything in our collective means to maintain and strengthen the integrity of the R2 Standard." The Board outlines the activities that it sees as critical for handling future situations.  Of utmost importance will be creating an explicit policy to deal with suspected non-conformances; a policy that:

• Fully protects the integrity of the Standard while providing due process to the facility,
• Articulates the role and responsibilities of the CBs,
• Describes the actions R2 Solutions will take in such situations. 

The Board also calls on the TAC to look closely at the language of the Standard as it undertakes the Standard revision process, stressing that the "language of the Standard should be crystal clear about what is required of a recycler and, by extension, from the Certification Bodies (CBs) auditing the recycler. . . [thereby furthering the cause of] a robust, trusted certification program."    

R2 Solutions will continue to keep the public informed of actions relating to Intercon Solutions and the development of policy to address similar situations in the future.   A full copy of the R2 Board of Directors' letter to the TAC can be viewed on the R2 Solutions website.

Federal taskforce and OEMs offer support for certification of electronics recyclers

On July 20^th the U.S Environmental Protection Agency, the General Services Administration and the White House Council on Environmental Quality unveiled the Administration's strategy to more sustainably procure and manage federally-owned IT equipment throughout its lifecycle.  Joining in this announcement were Dell, Sony and Sprint which also offered their commitments to promote environmentally sound management of their products. 

     The strategy for responsible management of federal electronic assets includes taking steps to include greener purchasing, using EPEAT-registered products and responsibly managing electronics at end of life.  This includes requiring the use of certified recyclers when selecting IT asset disposal services.   According to the press release, "This collaboration with industry aims to encourage businesses and consumers to recycle their electronics with certified recyclers, and for electronic recyclers to become certified."  The selection of the venue for the announcement, Round2 in Austin, Texas-an R2-certified recycler-was further endorsement of the importance of choosing a certified recycler when seeking responsible recycling services. 

     "R2 Solutions applauds the Federal government for playing a leadership role in promoting the responsible recycling of used electronics by certified recyclers," notes John Lingelbach, Executive Director of R2 Solutions.  "This is a significant step forward in the collective effort to improve our nation's electronics recycling practices."  Certified recycler options continue to grow, as there are currently 95 R2 certified facilities in North America and Europe listed in the R2 Solutions directory of R2-certified recyclers. 

Guidance Update

Issuing guidance around the interpretation and implementation of the R2 Standard has been a top priority of R2 Solutions this year.  When the TAC was formed this spring a Guidance Workgroup was formed and launched into the task of reviewing draft guidance, identifying key issues and developing guidance language.  The Guidance Workgroup is made up of participants representing the interests of OEMs, recyclers and refurbishers, trade experts, auditors and consultants.  Together this group brings a diverse range of knowledge and experience to the guidance discussion.  To date, the Guidance Workgroup has considered Guidance for the first five Provisions of the R2 Standard and is slated to present the full TAC with a complete revised version of Draft Guidance in mid-September.   

     Once the full TAC has an opportunity to review the Draft Guidance, a 30 day public comment period will be opened, at which time any interested stakeholder may weigh in on the proposed Guidance before final consideration by the TAC and a final decision by the Board.  We anticipate that official guidance will be published by the end of year.   

Survey of R2 recyclers coming in August

In September, R2 Solutions will have completed its first year of operations as the non-profit housing entity for the R2 Standard.  In an effort to conduct on-going program evaluation and gather important information about the performance of the R2 Standard, R2 Solutions will be surveying R2-certified recyclers in August.  The purpose of the survey is to gather data regarding the implementation of the R2 Standard, and potentially identify ways in which the Standard is shaping the industry.  The information gathered also will be considered by the Technical Advisory Committee as they revise the Standard and by the Board and staff of R2 Solutions to inform the future work of the organization. 

     All R2-certified recyclers are encouraged to participate in the survey to ensure the data encompass the experiences of as many R2 recyclers as possible.  The survey will be distributed by email in early August.

Conformity review:  Maintaining conformance on an ongoing basis 

Conformity review is a monthly column highlighting important operational information concerning the R2 Standard

Photo courtesy of HiTech Assets, Inc.

One limitation of any audit-based certification program is that the audit only provides a snapshot of the system in place at the time of the audit.  Over time, a recycler can fall out of conformance but continue operating under the certification label.  One mechanism that mitigates against this is the annual maintenance audit which is required to maintain certification.  While this annual, independent third-party verification is important, it still cannot offer insight into the practices of the facility on a day-to-day basis.  For this we must rely on certified recyclers to continue self-monitoring conformance on an ongoing basis.

     The stakeholders that developed the Standard wanted to ensure that the principles of the Standard could be, and would be, applied daily.  To do this, the Standard requires monitoring, benchmarking, and continually improving by means of these internal controls:

• The EHSMS, which is to be reviewed regularly, and be based on a "Plan-Do-Check-Act" model for continuous improvement.  [Provision 1(a)(2)]
• Periodic evaluation of compliance with all legal requirements to protect environmental and worker safety. [Provision 3(a)(1)]
• Continuous hazards identification and assessment of occupational and environmental risks. [Provision 4(c)].
• Monitoring and sampling protocols to manage any hazard risks that have been identified.  [Provision 4(e)].
• Confirmation through audit or similarly effective means that downstream vendors conform to the Focus Material requirements each time a new downstream vendor is selected. [Provision 5(f)].
• Regular review and validation of data destruction procedures by an independent party. [Provision 8(d)].

During the audit process, the recyclers have to produce their plan for regularly carrying out the described monitoring and conformance checks.  So while it is the auditor's job to determine the recycler is operating in accordance to the R2 Standard's requirements at the time of review, it is the expectation that the recycler continues to actively monitor all operational areas on an ongoing basis, and address any discovered non-conformances immediately.