October 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-certified companies support "spot-checking" audit program
The TAC takes on downstream due diligence
How does the R2 Standard apply to Refurbishers?
Conformity review: Change Management

R2-certified companies support "spot-checking" audit program

In the survey of R2-certified companies conducted this past August, over 80% of respondents indicated they believe a "spot-checking" program would contribute substantially to maintaining the integrity of R2.  54% stated they believe such a program should be mandatory for all R2-certified organizations, while 20% indicated they believe it should be voluntary.

R2 Solutions is implementing a comprehensive quality assurance strategy that includes actions such as developing the R2 Guidance Document and assuring high-quality training is available for auditors and facility managers.  Key to the overall strategy could be this "spot-checking" program that garnered support in the survey. 

R2 Solutions is considering how it could structure such a program.  One possibility is for R2 Solutions to audit a handful of R2-certified facilities each year.  Such audits likely would focus primarily on some of the central tenets of the R2 Standard relating to the overall management of Focus Materials.  Other possibilities might include witnessing of yearly surveillance audits of R2-certified companies, or perhaps an in-depth review of shipment records.  The goal would be one of continuous improvement for the facilities (and the Standard).

A number of questions have yet to be answered regarding how such a "spot-checking" program would be implemented.  Given the support expressed by R2-certified recyclers in response to the recent survey, R2 Solutions will be working hard over the next couple of months to answer them and to produce a viable "spot-checking" program that is beneficial for all in the R2 community.

The TAC takes on downstream due diligence


The R2 Technical Advisory Committee (TAC) has been working hard since its inception this past June. Jody Erikson, of The Keystone Center, is the facilitator for the group and she been keeping things moving. One of the key areas the TAC has been considering is downstream due diligence.


Perhaps the most pressing issue in this area concerns the level of due diligence needed when the downstream vendor is R2 certified. The current version of the R2 Standard is silent on this important matter. The R2 Standard requires refurbishers and recyclers obtaining R2 certification to select downstream vendors for Focus Materials (FMs) that conform to the R2 requirements for downstream vendors listed in Provision 5, section (e). Furthermore, once certified, R2 refurbishers and recyclers are required to "confirm through audits or other similarly effective means" that their downstream vendors for FMs continue to meet the requirements of section (e).


The issue arises because the R2 Standard does not make clear whether the R2 certification of a downstream vendor is acceptable as evidence that the downstream vendor is conforming to each of the requirements of section (e). Since it is not clear, Certification Bodies and their auditors have been forced to make their own determinations. Some have determined that an R2 certification is sufficient evidence to reasonably conclude conformance on the part of the downstream vendor (and all its downstream vendors).


Others have not. They point to the fact that an R2 auditor would most likely have conducted a sampling of downstream documentation, rather than an exhaustive review of each vendor. Furthermore, Provision 5, section (e) (1) requires that downstream vendors for FMs conform to the FM Management Plan of the upstream company. Therefore, each downstream vendor's practices need to be evaluated for conformance to the company's FM Management Plan.


The TAC needs to address this issue, and soon. It likely can do so through the Guidance Document it is developing, in which case the issue could be resolved within just a few months. Alternatively, the TAC may determine that this issue must be resolved through a change to the language of the R2 Standard itself, in which case it will take some months longer. Either way, the TAC is aware of the pressing nature of the issue, and that this is a test of the TAC decision-making model - one that is inclusive, transparent, and provides due process - to make good decisions expeditiously.


How does the R2 Standard apply to Refurbishers?


Refurbishers play a critical role in the hierarchy of responsible management strategies within R2. They are important in ensuring maximum reuse of electronics. Refurbishers provide the expertise and the focused markets for repair, reconditioning, and reuse of standard and specialized electronics. Whether as a certified organization or a downstream vendor, refurbishers are key to attaining the responsible management objectives of R2.


Refurbishers come in many different flavors. Their business model may call for 100% refurbishment, with all recycling of unusable equipment performed by a downstream vendor. Or they may be predominantly refurbishers, but also recover materials from the unusable equipment in-house. Either way, the R2 Standard applies to them and at least some of their downstream vendors, particularly Provisions 5 and 6.


First, refurbishers must be able to track equipment and components through the refurbishment process. This includes not only receipt and shipments, but also the condition of the equipment and components, and test results for functionality. This is a key difference between recycling and refurbishing. For refurbished equipment, one must ensure that proper testing is performed to determine key functions are working properly pursuant to Provision 6(c). The R2 Standard is intentionally flexible to allow for changes in technology and markets in determining what constitutes a "key function" and what constitutes "working properly".


Second, refurbishers must satisfy R2 requirements for the proper handling of all the equipment that does not go to reuse, and the components which were replaced during refurbishment. Batteries are one common component replaced during refurbishment. Under Provision 6(c)(3)(C), the equipment and components containing Focus Materials that do not go to reuse must be managed in accordance with Provision 5, which addresses management practices and downstream vendors for Focus Materials. Refurbishers are subject to the same requirements as recyclers with respect to unusable equipment and components.


The business model and customer requirements of a refurbisher will determine whether all or only part of the R2 Standard will be applicable. In either case, however, there is no reason why a refurbisher cannot be R2 certified. It only improves the quality of services provided in the electronics reuse market and further enhances the overall management quality of the reverse supply chain.


Conformity review: Change Management    


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


Provision 4(c): An R2 electronics recycler shall conduct on an ongoing basis (e.g., as new types of materials are processed or new processes are utilized) a hazards identification and assessment of occupational and environmental risks that exist or could reasonably be expected to develop at the facility. Such risks could result from any sources, including but not limited to emissions of and/or exposure to substances, noise, ergonomic factors, thermal stress, substandard machine guarding, cuts and abrasions, etc.. The hazards identification and assessment shall be captured in writing and incorporated as a component of the recycler's EHSMS.


To summarize, this requirement in the R2 Standard calls for an R2-certified recycler to have in place a clearly-defined "change management process." Central to this change management process is the ongoing evaluation of environmental risks and health hazards. Often times this is done after a change in technologies or procedures. Such evaluation normally occurs during internal audits or a review of environmental, health, and safety (EHS) aspects. However, the intent of the R2 Standard is that such evaluations be conducted prior to making changes and be a part of a systematic process for implementing changes.


An example would be a recycler that is assessing whether to disassemble LCD monitors. The change management process within the organization should first document the proposed operational process. Then this process should be evaluated by a qualified EHS professional to identify any potential hazards or risks. In the case of LCD monitors, one risk would be the breakage of mercury-containing compact fluorescent lamps (CFL's). The EHS professional may decide that an air monitoring study is necessary to determine if there is a health risk from breakage of these lamps. Furthermore, the handling of mercury lamps will need to be analyzed to minimize any negative environmental impact. Since CFLs are Focus Materials due to their mercury content, an evaluation of the Focus Materials Management Plan will also need to be conducted to ensure conformance to the plan (as well as other organizational policies within the organization's EH&S Management System).


One key element here is to satisfy the requirement on an "ongoing basis". With a repeatable and proactive change management process, organizations will be able to systematically make operational changes, proactively taking into account the health, safety, and environmental hazards associated with such changes.   This is an integral part of the Plan-Do-Check-Act model of the management system required of R2-certified organizations.


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!