[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 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.
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
Part 14 covered Appendix D – Specialty Electronics Reuse, with its long list of requirements for Verified Specialty Electronics. hyperlink
We’re up to Appendix E now – Materials Recovery
Materials recovery covers both recycling and Focus Materials during the recovery process.
This appendix requires the organization to go back and cover hazards identification and assessment of occupational health and safety, and environmental risks identification that could reasonably develop when a change is made (the examples given in the standard is a new type of material to be processed, new process, or new equipment). The assessment should take into account exposure, noise, ergonomics, thermal stress, substandard machine guarding, cuts and abrasions, etc.
[I have no objection to this statement, but question why this is not covered by the applicable ISO requirements, which require a Management of Change form for process changes in ISO 45001. Perhaps to make the umbrella cover ISO 14001 also, where Mgt of Change is not a formal requirement?]
Appendix E.2 requires a trained individual to conduct the hazards identification and assessment; E.3 requires a written assessment; and E.4 covers what needs to be in the assessment, including:
- Decontamination facilities, clean areas for eating/drinking, transition areas;
- Prohibition of food/drink in materials recovery area unless IH shows no risk;
- Prohibition of work clothes/shoes being taken home unless IH shows no risk;
- Cleaning and care of PPE procedure in place;
- Equipment/work area cleaning procedure in place;
- Procedures for lockout/tagout, including training;
- Physical safety guards in use;
- Pre-use safety inspections performed;
- Implement an Industrial Hygiene (IH) monitoring program, covering air, noise, wipe sampling at a minimum;
- Evaluate mechanical separation processes at least annually;
- Periodically monitor air quality for mercury in material recovery areas (where fluorescent lamps are dismantled or lamps are removed)
- Implement medical monitoring program (baseline and worker evaluation for mercury, lead, other toxics)
There are a lot of moving parts here for this assessment. [I see a document template meeting all these requirements for my clients to use in my future… including calendar reminders for many of these items.]
This Appendix also addresses the removal of FM’s, covering
Disassembly controls are maintained to minimize EHS incident risk during dismantling operations (e.g. battery removal)
FM’s and print cartridge removal prior to shredding or materials recovery
- Exceptions –
- mercury if workers are protected from handling, and facility meets regulatory requirements to receive and process mercury, and process for mercury recovery is demonstrated.
- CRT’s, batteries, and circuit boards if workers are protected from hazards (technology designed to safely/effectively process equipment/components containing these FMs); facility meets all regulatory requirements to receive and process tehse FMs; and process recovery effectiveness is demonstrated.
Processing, Recovery, Treatment of FMs is also detailed, including removed FMs sent to processing, recovery, or treatment facilities that meet regulatory requirements, using technology to design and operate FMs safely., including
- Mercury retorting or other legal methods, including incineration
- Removal of batteries and mercury from circuit boards, and processing for metals recovery (unless demonstration of conformance to requirements listed above in 6(a) or (b))
- Polychlorinated biphenyls (PCBs – which is also confusing as many in the industry use PCB to indicate printed circuit boards!) – this nasty has to be handled in facilities that meet applicably regulatory requirements with technology designed for this purpose.
These requirements look as though they were plucked pretty much word-for-word from the R2:2013 standard. Oh wait – they pretty much were. OK, so we simply shifted the details of the R2:2013 requirements (Clause 5) from CR 8 in R2v3 to App E.
Appendix E goes on to address Assurances for Environmental Incidents (E.8) which requires pollution liability insurance, guaranteed reserves, or government guarantee per CR9; and
Continued Processing (E.9) requiring evaluation of materials recovery output streams, per REC for recategorization or continued processing per CR6.
So once again, an Appendix is providing a wealth of information on how to process materials (in this case, FMs).
While the first draft of the standard had MANY more requirements (some of them confusing, if not downright contradictory), the commenters were able to provide suggestions for deletions and wording alternative modifications that made the process flow better, and the TAC revised the wording to what was released in v.3.
This Appendix will still be one of the most heavily audited areas – ensure that you are keeping on top of the requirements, especially the hazards identification and assessment. Making some of these requirements as part of your monthly safety walkaround may not be a bad idea… I can see cleaning procedure inspections, lockout/tagout, physical safety guards, pre-use safety inspections as good candidates for regular checkups. What do you think?
You’d think we’d be almost done by now – but there’s more info to come!
Next up: Appendix F – Brokering
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.
