[Note: “Text in italics and quotes” below are quoted directly from the R2v3 second draft standard. If it is in “quotes, italics, and underlined”, it is from the R2 Technical Advisory Committee]
In Part 1 of this series [hyperlink] 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 in to 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 flow chart 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. hyperlink
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. hyperlink
In Part 10, we discussed Core Requirement – 10 – Transport (R2:2013 Provision 12) which only had minimal updates.
In Part 11 we covered Appendix A – Downstream Recycling Chain. The R2:2013 standard had due diligence requirements covered in a variety of locations – Provisions 3, 5,6, 8, & 11 – while the new version consolidates all of these requirements into one Appendix.
In Part 12, Appendix B, Data Sanitization, we covered the requirements to provide physical or logical data sanitization. hyperlink Logical data sanitization is typically data wiping; while physical data sanitization is physical destruction.
Part 13, Appendix C – Test and Repair, covered the requirements for companies that do test, repair, or refurbishment – including the requirement to get registered to a fourth standard – this one for Quality Management Systems, typically ISO 9001 or TL 9000. hyperlink
Now we’re up to Appendix D – Specialty Electronics Reuse.
Starting off in the Definition section, we see the following for Specialty Electronics:
“ “Specialty Electronics” is rare and specialized electronic equipment that is not generally available in retail. For example, medical, diagnostic, laboratory, or other devices, which are customized for a specific purpose.”
The General Principle for this appendix states “To allow for the legitimate reuse of untested specialty electronics which often require sophisticated test equipment and simulations to test functionality and often cannot be tested by specialty electronics refurbishers.”
The Appendix itself jumps right in to linking requirements:
D.1 talks about the requirements for certification to Appendix C (Test and Repair).
D.2 require competent technicians to test all specialty electronics; if the facility cannot test (doesn’t have the technical capability), the requirement is to
“(a) Test all specialty electronics for which the R2 Facility has the capability to test in accordance with Appendix C – Test and Repair, and
(b) For specialty electronics which the R2 Facility does not have the technical capability to test:
(1) Verify and document from the prior user that the specialty electronics was removed from operation with no known defects in functionality, and
(2) Verify all specialty electronics are free of physical damage, physical defects, corrosion, and missing parts, and
(3) Verify the part number(s) or other similar unique identifier for the equipment, and serial number(s) are accurate, and
(4) Verify data on the specialty electronics was sanitized by the source in accordance with Appendix B – Data Sanitization, or the specialty electronics cannot store data that needs to be destroyed, and
(5) If the specialty electronics fail any of these verifications:
(A) Harvest the reusable components and conform to this Appendix D for each component, and
(B) Identify the remaining equipment and components as an R2 Controlled Stream and process according to Core Requirement 6, and
(6) If the specialty electronics pass all verifications:
(A) Track individual specialty electronics with a unique identifier, and
(B) Handle, package, and store all specialty electronics to protect it from physical and electrical damage, and
(C) Label all specialty electronics with the R2 Facility’s name and contact information for warranty returns and recycling, and
(D) Identify the item as Verified Specialty Electronics according to the REC.”
That’s a lot of requirements! Breaking it down, if you can’t test, you have to verify and document from prior user that the specialty electronics was removed from operation with no known defects in functionality (D.2.b.1). This would be OK if every recycler knew the origin of every piece of equipment, but I don’t see that happening realistically. The recycler also has to verify that the specialty electronics was sanitized by the source per Appendix B – Data Sanitization (D.2.b.4) or that it cannot store personal data. If it meets these requirements, it has to be tracked, packaged and stored to protect it, labeled, and identified as Verified Specialty Electronics per REC. (D.2.b.6)
If it can’t meet these requirements, then D.2.b.5 goes into play (harvest reusable components per this appendix and consider the rest as an R2 Controlled Stream, to be handled per Core Requirement 6.)
Verified Specialty Electronics may be stored indefinitely, presumably due to their unique nature.
In order to sell Verified Specialty Electronics, an R2 facility must
- Limit sales to customer’s request for a specific part number / identifier;
- List each unique identifier/part number sold on sales receipt
- Demonstrate customers accept the terms on the PO:
- Equipment has been inspected and verified but not tested;
- Customer accepts without testing;
- Customer will return all non-working equipment for a refund;
- Customer will only sell equipment to an end-user
- Customer will provide R2 facility records that demonstrate sale if requested since they will also
- Accept returns of specialty electronics for any reason at no charge to the end user
- Offer no charge return of the specialty electronics for recycling.
This one puzzles me a little – why is SERI stating that the R2 facility will accept returns, for any reason, at no charge, with no limitations on this? Let’s fast forward to 2040 – If I can prove that I bought specialty electronics 20 years ago, in 2020, and kept my receipt, I can send it back at no charge? I wish I had a warranty like that on all my appliances!
Digging in to the Technical Advisory Committee’s comments on this Appendix provided the best clarity for me: “Appendix D – Specialty Electronics Reuse provides an alternate processing path for verifying highly specialized equipment and components where full functionality testing is not feasible. Since functionality testing is not possible, it is critical that key information for the equipment can be verified, such as the functionality, condition and data sanitization status.
However, an R2 Facility can alternately reuse Collectible and Specialty Electronics under Core Requirement 6(e)(3)(A), without requiring the Appendix D certification or verifications.”
Based on that statement, I think companies should be very careful when deciding whether Appendix D applies or not.
But wait – there’s more info to come!
Next up: Appendix E – Materials Recovery
Can’t wait for the entire series and want to engage with us now? Contact us to start the process!
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