The second draft of the R2v3 standard, which will replace the current R2:2013 standard once it is released, has been released recently. This is the first in a series of articles that will delve into the draft standard in more detail, in order to provide you with a ‘blow by blow’ analysis of what is going on.
Although many people skip all the writing prior to the clauses (now called Core Requirements), we’re going to start at the front of the document and highlight some key points – both current and proposed changes – that should be kept in mind when implementing this standard.
The second draft, which was edited as a result of the first draft comments, is quite lengthy. We’re only going to analyze this in bite-size pieces for now, to try and “quell the overwhelm” ® for you.
The introduction covers how the standard was initially developed and how the Technical Advisory Committee (TAC) was formed and operates. It also covers how interpretations are developed, called Advisories, and indicates that Advisories or Formal Interpretations are auditable. This is a key point – not only do you need to meet the requirements of the Standard, but it is up to you to be aware of the Formal Interpretations and Cod of Practice Advisories, to ensure that you are also meeting their requirements.
The introduction goes on to cover the scope of R2 (described as “broad in scope”) and cautions that “The R2 Standard should be viewed only as one of various methods and tools that can be utilized by an organization, and by those evaluating an organization. The R2 Standard is thus offered “AS-IS” and without warranty, both to R2 certified organizations, and to third parties who may look to R2 certification in the process of evaluating R2 certified organizations. Any reliance otherwise is expressly disclaimed by SERI.”
The next section is legal requirements, pointing out that “it does so by requiring the certified organization to document and provide evidence of a qualified assessment of legal compliance.” And pointing out that “if a requirement of this document conflicts with an applicable legal requirement, the recycler must adhere to the legal requirement. R2 Facility must adhere to the legal requirement.” In other words, SERI auditors are not making determinations of legal compliance, and SERI states that “Organizations should seek competent legal counsel regarding their own compliance with applicable laws.”.
This is advice I often give my clients – that someone has to be trained in legal and regulatory compliance. Someone who’s been through a generic 3 day internal auditor course may have difficulty in determining the applicability of all of the international, federal, state, and local laws and regs. Only someone who’s “done the work” should be determining legal applicability and compliance.
In the Conformance section, the standard lays out the requirements – both the Core Requirements and the R2 Process Requirements – that are applicable to the scope of activities. The standard states that it is the responsibility of the facility to provide records and evidence of conformance, and says that “An absence of records is not just a non-conformity, but is potential grounds for non-certification, suspension, or revocation if the R2 Facility cannot satisfactorily demonstrate that it operates in conformance with parts of the R2 Standard due to a lack of evidence. Where an organization cannot demonstrate conformance or meet the requirements, the organization cannot be R2 certified. Certain processes can be outsourced only as specified within the defined requirements of this standard. All other outsourcing not specifically defined in the Standard, is prohibited.”
Let’s look at that a bit more closely – a facility has to demonstrate that it meets all the requirements. That demonstration should be either through evidence, or records. If you can’t produce that evidence or records, your certification is in jeopardy. So particular attention to records and evidence should be at the forefront of every internal audit and management review.
Introduction covers applicability and this is key for facilities. While R2 is applicable to all organizations, regardless of their size or location, it also “includes all electronics reuse or recycling related activities that are owned and/or operated, or contractually managed by an R2 Facility, or in connection with the operations of the facility.”
The scope “shall apply to all electronics reuse and recycling related activities controlled by the R2 Facility through title, physical possession or other contractual control of electronic equipment, components or materials.” This could include external processes including brokering, collection, and additional storage or processing buildings. What this means is that you have to look at all your operations – whether there is remote storage in some building, or another group doing brokering for you, to determine your applicability and scope.
It goes on to state that “Certification may be extended to multiple physical addresses of the same legal entity (company) through a campus certificate, multi-site certificate, or additional individual certificates. It may also be extended as a multi-site sampling certificate when the management system is shared by multiple locations in accordance with the R2 Code of Practices.”
The Introduction concludes with a list of normative references (which means that these standards are part of the R2 standard):
- RIOS – Recycling Industry Operating Standard
- ISO 9001:2015 – Quality Management System
- ISO 14001:2015 – Environmental Management Systems
- ISO 45001:2018 – Occupational Health and Safety Management Systems
- OHSAS 18001:2007 – Occupational Health and Safety Management Systems (Until March 2021)
- AS/NZS 4801:2001 – Occupational Health and Safety Management Systems
- NIST Special Publication 800-88: Guidelines for Media Sanitization
- NSA/CSS Policy Manual 9-12 – NSA Storage Device Sanitization Manual
And provides info on the R2 Equipment Categorization (REC) reference document, which is intended to be used in conjunction with the R2 standard and “provides the framework for evaluating electronic equipment, components, and materials, and categorizing their R2 condition throughout each step of the R2 process. The categories identified in the REC must be incorporated into the R2 Facility’s categorization process and procedures, or a written cross-reference to existing internal categories maintained.”
Finally, the Introduction concludes with the “About SERI” statement, providing some background on the organization as well as listing their website www.SustainableElectronics.org.
What does the introduction highlight for us? The key takeaways are:
- The R2 standard include all sanctioned interpretations and code of Practice advisories (as well as license agreement) as part of the auditable document.
- The organization should have competent legal advice re: applicability for both EMS and OHS
- Absence of records or evidence could lead to non-certification or revocation (loss of your cert)
- Applicability and scope are key in determining the correct addresses of your operations.
- Organizations may have a single site, multi-site, or campus certificate.
- There are several other standards listed as normative references – this means that an R2 facility also has to conform with those standards in their entirety as part of conformance to R2
- REC categories must be incorporated into the facility’s categorization process and procedures.
Whew! That’s a lot of info covered in the section that most people skip – I’m glad that you and I didn’t make that mistake, and we’re now aware of what we have to do and how we have to do it.
But wait – we’re not done yet!
Next up: Definitions
Can’t wait for the entire series and want to engage with us now? Contact us to start the process!
Interested in getting some assistance on R2 implementation? Check out our other blog posts or contact us to get more info.