In Part 1 of this series, we discussed the second draft of the R2v3 standard – specifically, the introduction. This covered applicability and scope as well as Sanctioned Interpretations and highlighted some areas we want to pay attention to. Part 2 reviewed the Definitions section – some changes, additions, deletions, and the Focus Materials Table.
In Part 3, we started digging into the standard’s Core Requirements (CRs) – the auditable portion of the R2v3 standard. Specifically, the Scope and Hierarchy of Responsible Management Strategies.
In Part 4 of the series, we covered two short, but very important, Core Requirements – CR 3, EH&S Management System, and CR 4, Legal and Other Requirements.
In Part 5 which addressed Throughput Tracking, we discussed what inbound and out outbound summary reports should include, and how to address negative value.
In Part 6 we discussed sorting, categorization, and processing, including a helpful flowchart on how to process, including references to applicable Appendices.
In Part 7, we covered Data Security. Data Security ensures that the electronics we are handling are protected from data breaches, through the use of secured areas, data sanitation, and compliance with legal and regulatory requirements for this Core Requirement.
In Part 8, we reviewed Focus Materials (FMs), and the changed requirements from the R2:2013 standard (as well as some concerns we still have with it).
In Part 9, we reviewed Core Requirement 9 – Facility Requirements, which now encompasses Storage, Facility Security, Insurance, Closure Plan, and Financial Responsibility.
We’re up to the final Core Requirement – 10 – Transport (R2:2013 Provision 12)
Transport includes not only applicable legal requirements, but also ensuring the protection of physical and data security, as well as safety, health, and the environment.
While the overall intent of the standard has not changed materially from the 2013 version, as always, there are clarifications to the wording.
The first draft of the standard was well crafted, and the second draft expands on some of these concepts. Where the first draft talked about transport security requirements, the second draft has expanded that to include
“(b) When electronic equipment or components containing data are transported:
(1) Defined security measures are implemented as planned and transportation is tracked as appropriate for the sensitivity of the data on the devices and the requirements of the suppliers served, and
(2) Contracts are enforced with the transporter with a level of service that conforms to these requirements, and
(3) Additional security controls are used to conceal the package contents from public view and prevent unintended access during transportation.”
CR 10.b.3 is a new addition and requires the package contents to be protected from public view. I wonder where this requirement came from? Were folks seeing the contents of the pallets, and helping themselves to a few things in transport? No matter – how they have to be protected from public view and prevent unintended access during transport.
This Core Requirement is one of the few that did not change materially and is also the only one that did not have additional comment submissions after the first round, indicating that Transport is probably one of the more stable requirements through the transition from the 2013 Standard.
But wait – we’re not done yet!
Next up: Appendix A – Downstream Recycling Chain
Can’t wait for the entire series and want to engage with us now? Contact us to start the process!