R2 Solutions


February 2013

R2 Update
The latest information on the Responsible Recycling (R2) Standard 
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AQA International  

 

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Orion Registrar, Inc.

 

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Perry Johnson Registrars, Inc.

 

 

SGS 

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SAI

Additional Certification Bodies may be found at ANAB.
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
R2:2013 Standard Revision Update
R2 Code of Practices
Meet the Board Member: Clare Lindsay
R2:2013 Preview -Closure Planning and Insurance

R2:2013 Standard Revision Update

   

After several meetings over the past two months, the Technical Advisory Committee (TAC) is poised to move the R2:2013 Standard to the next stage.    The TAC thoroughly reviewed all public comments and made appropriate changes. Today, the final draft R2:2013 Standard was reviewed by the TAC and is expected to be approved by the TAC next week.

 

Responses to public comments will be provided in March. The R2:2013 Standard will be presented to the R2 Solutions Board of Directors for final approval. The Board has 60 days to review. It is anticipated that the new standard will be released by June 1, 2013.

 

In addition, new programs are being finalized. An R2:2013 Transition Plan will be published soon with the expected timelines for R2:2013 implementation. A new program document called the R2 Code of Practices, which will also apply to R2:2013, will be published with the new Standard. The R2 Code of Practices will provide all the rules for implementation and administration of the R2 Certification process.  

 

Additional program elements for R2 Solutions approved training are being developed in the process to release R2:2013. Look for more details to be communicated in the coming months.

R2 Code of Practices

   

The R2 Code of Practices, which will also apply to the R2:2013 Standard, is being developed as the rules for the R2 Certification process. It will address becoming an accreditation body and a certification body.  It will establish rules for auditor and certification body training, oversight, and qualification.  Another part of the R2 Code of Practices includes specific audit time requirements to be followed consistently across all certification bodies.  Time requirements may include additional time based on the number of downstream vendors and whether those vendors are R2 certified.  Additional audit time is also proposed to allow for further evaluation based on an organizations' performance on a prior audit.   Organizations with more non-conformances would be subjected to longer subsequent audits.          

 

More information will be contained within the R2 Code of Practices.

Meet the Board Member: Clare Lindsay

 

In this new series, we'll occasionally profile a R2 Solutions board member to capture insights into electronics recycling and standards.  This month, we caught up with Clare Lindsay.

 

Clare recently retired from EPA where she worked for 20 years on resource conservation issues.  She led EPA's efforts to initiate the first-ever national dialogue on electronics product stewardship in the U.S. and actively participated in development of many product stewardship initiatives addressing products as diverse as packaging, carpet, office furniture, and paint.  Today she serves on the boards of R2 Solutions and the National Center for Electronics Recycling.


What drew you to serving on the R2 Solutions board of directors?  

I was working at EPA when those active in electronics recycling policy determined that there was a need to distinguish electronics recyclers using best practices from others.  While I was not directly involved in the development of the R2 standard, I was very supportive of this effort.  I respect the folks who are leading the R2 organization -- John Lingelbach, Board Members and TAC participants -- and feel that this community is trying to reduce negative impacts of electronics recycling in the context of an unavoidable reality -- the global marketplace.

 

What do you see as some of the opportunities and challenges for both the R2 Standard and R2 Solutions?  

Among the challenges is the need to ensure that audits to the R2 Standard are detailed and incisive.  The standard itself is strong, but there is the separate need to ensure that audits of facilities to the standard are sufficiently time-intensive and demanding to ensure that the R2 Standard requirements are met on an ongoing basis. Key opportunities include expanding uptake of R2 and other electronics recycling best practices worldwide.  The market in used electronics is, and will continue to be, an international phenomenon. It is more important than ever to encourage uptake of strong standards like R2 worldwide so that electronics recycling, where ever it takes place, can be an environmentally assured practice.

 

Any thoughts on the future of electronic recycling?  

Electronics are an ever-evolving product stream.  So the process of recycling electronics is ever-evolving as well.  I believe that easy access to safe and legitimate electronics recycling will become a norm in the U.S. in the next few years.  The resources that go into these products are too valuable to waste.  Our used electronics will be one source of increasingly valuable and rare resources needed for not only electronics but also new generation products.  

 

What makes R2 special?  

R2 is a standard developed with input from a wide variety of players in the electronics manufacturing, use, reuse and recycling community.  It recognizes and addresses the realities of the marketplace and is readily adaptable to changing market realities.  R2 recognizes and enables reuse of electronics in less developed countries, thereby extending the useful life of valuable products with a deep environmental footprint.  This is resource conservation and environmental protection at its most basic! 

  

R2:2013 Preview: Closure Planning and Insurance

 

To prepare for the coming transition to R2:2013, we are covering new requirements under consideration.  The R2:2013 Standard is currently a DRAFT.  The R2 TAC is finalizing the R2:2013 Standard. 

  

In the R2:2013 Standard changes are expected to Provision 11 regarding insurance, closure plans, and financial responsibility.  These changes are designed to clarify the requirements, ensure consistency, and align requirements with the level of risk associated with each specific facility.

Insurance requirements have been re-written to be commensurate with the evaluated risks of a facility's activities.  Furthermore, the risks should consider the geographic region where the facility is located.  Based upon this risk evaluation, insurance for environmental pollution protection and work health and safety are required.    Recyclers should be prepared to demonstrate the validity of the risk assessment.  It should not be an assessment based on the organizations assumptions or opinion.  One method might be to have a risk assessment conducted by the organization's insurance carrier.

Proposed closure plan requirements have been expanded in detail to provide clearer expectations to all R2:2013 certified organizations.  The closure plan must assure proper closure, including closure in the case of abandonment when the R2 certified organization is no longer in control of the facility.  Additional specific requirements of the closure plan include the assignment of the financial instrument to an independent party responsible for closure in case of abandonment.  For example, an independent party may be a government body when required by law, or another company. 

Based on the risks identified in the assessment for insurance purposes, the closure plan must specify the details of the funding instrument, including the beneficiary.  It must assign responsibility for closure to a specific organization or individual.  Finally, the closure plan must detail the plans for processing remaining inventory.  Based on the activities of the operations, it may also need to consider site sampling and remediation.

The financial instrument must align with the closure plan and provide funding to adequately cover the costs of executing the closure plan.  In accordance with the R2 Guidance, the amount needed may not be reduced by assuming a value of remaining inventory.  For purposes of Provision 11, remaining inventory is considered to have no residual value. 

In summary, Provision 11 requires a valid assessment of an organizations risks for environmental pollution.  Based on the risk assessment, closure planning should adequately address these risks to return the premise to sellable condition.  The cost of executing the closure plan will determine the amount of the financial instrument for closure. 

 

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!