June 2012  

R2 Update
The latest information on the 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 Solutions Welcomes Two New Board Members
R2 Solutions Board of Directors met on June 19th: Guidance Document Adopted, R2:2013 Discussed, Intercon Solutions Relisted
Certified company spotlight: R2 Certification for Refurbishers
Conformity review: battery handling part 2 -- downstream processors

   

R2 Solutions Welcomes Two New Board Members

  

R2 Solutions has named two new members to the nonprofit's Board of Directors.

 

Robin Wiener is the President of the Institute of Scrap Recycling Industries (ISRI). Rick Goss is the Vice President for Environment and Sustainability at the Information Technology Industry Council (ITI). Both joined the R2 Solutions Board of Directors effective June 1.

 

These additions underscore R2 Solutions' commitment to include a range of stakeholder perspectives on the Board. The updated list of the R2 Solutions Board of Directors is available online.

 

"Robin and Rick bring great perspectives and knowledge to our Board," said John Lingelbach, Executive Director of R2 Solutions. "Their contributions will be extraordinarily valuable as we work hard over the next few years to take the R2 program to the next level."

 

 

R2 Solutions Board of Directors Met on June 19th: Guidance Document Adopted, R2:2013 Discussed, Intercon Solutions Relisted

 

 

The R2 Solutions Board of Directors began the formal process of improving and updating the R2 Standard at its recent board meeting held on June 19th in Washington, D.C. In addition to launching the process that will update the standard, a number of important issues were decided.

 

The Board discussed and unanimously adopted the R2 Guidance Document developed by the R2 Technical Advisory Committee (TAC). This document helps explain and clarify the requirements of the R2 Standard. Auditors and recyclers will find it very useful as they navigate the standard. The TAC did a tremendous job of getting into the details of the Standard and working to clarify them. And thank you to those who submitted comments on earlier drafts of the Guidance Document - the comments were extremely helpful.

 

With the Guidance Document finalized, the Board (and the TAC) is turning its attention to the development of the next generation of the R2 Program. At the core, the new program will entail a revision to the Standard. The Board was briefed on the initial ideas of the TAC for how to "raise the bar" in various areas of the Standard, including requirements around the type of environmental, health, and safety management system employed by R2 recyclers (potentially requiring a certified management system such as ISO 14001 or RIOS).

 

R2:2013, as the next-generation program is currently being called, also will place additional requirements on Certification Bodies and auditors in order to strengthen the overall program. With six accredited Certification Bodies, the R2 Solutions Board sees a need for a renewed emphasis on auditor training and other strategies for assuring all the numerous auditors and the Certification Bodies are on the same page with respect to each of the requirements of the R2 Standard. Also, with R2:2013, recyclers will have to pay an annual per-facility fee to R2 Solutions in order to get certified. These fees will support the maintenance of the Standard and of the website. They also will be used to develop programs aimed at promoting the R2 Standard in the marketplace.

 

The Board also adopted a revised Non-Conformity Policy that provides a mechanism for companies that have been delisted from the website to be relisted. The Board then considered the situation of Intercon Solutions, which had been delisted a year ago. Over the past number of months, Intercon has been audited successfully by two accredited Certification Bodies. Based on these successful audits, the Board decided to relist Intercon Solutions on the R2 Solutions website.
 

 

Certified company spotlight: R2 Certification for Refurbishers

 

From time to time, the R2 Update will be featuring an R2 Certified company. This article was provided by PC Rebuilders & Recyclers (PCRR). For more information about PCRR, please contact Sarah Commes at (773) 545-7575 or sc@pcrr.com.

 

 

Founded in 2000, PC Rebuilders & Recyclers (PCRR) has a two-fold purpose of bridging the digital divide and supporting environmental responsibility through the refreshment of prematurely retired computer systems. In doing so, PCRR provides an inexpensive way for corporations to dispose of their unwanted equipment as well as an inexpensive way for people to invest in technology.   PCRR was launched by Willie Cade in his basement on the north side of Chicago. Since 2000, it has grown into a 13,000 square foot refurbishing facility. PC Rebuilders & Recyclers refurbishes and upgrades equipment with genuine Microsoft® software, keeping current with technology standards. As a Microsoft® Authorized Refurbishers (MAR), PCRR offers a complete refurbished computer system as a cost-effective alternative to new equipment. PCRR's goal is to prove that limited funding does not preclude access to technology.

 

PC Rebuilders & Recyclers immediately realized the benefit of R2 certification to its customers as well as to the organization's management and structure. PCRR invested in becoming R2 certified in 2011 and worked hard to implement its rigorous procedures. As a result of the hard work, R2 gave PCRR's customers a simple means of verifying that it is forthright and responsible in managing used and end-of-life electronic equipment. R2 certification has also opened new markets which require a certified recycler, resulting in a growing inventory.

 

Another benefit that has come from certification is that it has provided a sound structure for the day-to-day running of the organization. With a detailed environmental, health & safety management system, R2 certification has resulted in an effective continuous improvement program. The safety guidelines allow PCRR to hold its facility to a higher standard in both the safety and work ethic of its employees as well as the responsible handling and managing of equipment. The regular audits ensure that PCRR remains accountable and best in class in the recycling industry. While the R2 certification process was a significant undertaking, the benefits that have come from being certified have rewarded the hard work.

 

 

 

Conformity review: battery handling part 2 -- downstream processors   

 

Conformity review is a monthly column highlighting important operational information concerning the R2 Standard.  For the last number of months it has been written by Corey Dehmey of Momentum, Inc.  Corey can be reached at CDehmey@m-inc.com.    

 

In the last issue of the R2 Update we focused on battery handling as it relates to the provisions of the R2 Standard. The article looked at the handling required at an R2-certified recycler's facility. We discussed the requirements for emergency planning, health & safety risks, and environmental impacts. Furthermore, we looked at the implications of transportation to the recycler's operations. In this issue of the R2 Update, we are going to explore the impacts of vendor selection.

 

As with all FMs, downstream due diligence is always required under Provision 5(e). This also pulls in requirements for tracking under Provision 7. What can be a fairly simple process is often complicated by multiple collectors or aggregators ('intermediate vendors") in the recycling chain. Smaller volumes often mean that recyclers have to work through these intermediate vendors, not directly with the final processor. Recyclers must be cautious in their selection of intermediate vendors as some cannot meet the requirements of an EHSMS under Provision 5(e)(2). All downstream vendors to which a recycler transfers FMs must have an EHSMS.

 

Due diligence of downstream battery handlers is especially important in the United States. Anyone who discards a battery for recycling or disposal is a "generator" in the eyes of the law. Generators can be held financially liable for the cleanup of polluted sites as classified under CERCLA (aka "Superfund"). This means that not only the battery processor downstream, but the intermediate vendor(s), electronics recycler, and upstream customers can be financially liable for environmental pollution as a result of recycling electronics. Fortunately, the Superfund Recycling Equity Act (SREA) was passed in 1999 to allow generators an exemption from financial liability if they can meet the SREA due diligence requirements. It is only effective if due diligence is completed prior to the transaction, even though it may not become needed until many years from now.

 

In the next issue of the R2 Update, we will examine how Pollution Liability Insurance impacts recyclers. Specifically, we will look at how it indemnifies customers and its limitations.

 

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!