[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 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.
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. 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.
Part 14 covered Appendix D – Specialty Electronics Reuse, with its long list of requirements for Verified Specialty Electronics.
Part 15 reviewed Appendix E – Materials Recovery, including handling and processing of FMs.
First, let’s go all the way back to our definitions, and make sure that we’re using the correct word:
“Brokering” (sometimes called “trading”) is the process where an R2 Facility sources electronic equipment, components, or materials and controls their delivery directly to a downstream vendor without physically receiving or processing the equipment in the R2 Certified facility. Brokering may be the only activity of an R2 Facility or brokering may be a process in addition to those performed at the R2 Facility.
Appendix F’s General Principle states, “To enable an R2 Facility to source and control the delivery of equipment, components, or materials directly to a downstream vendor, while ensuring that the same R2 requirements apply to all brokered R2 Controlled Streams.”
This appendix is quite short – it has 3 basic requirements (but you know we’re gonna have multiple sub-requirements under that, right?)
- Declare/document all brokering activities in accordance with CR 1
- Include DSVs receiving R2 Controlled Streams in facility’s audited activities per Appendix A
- Maintain certification to an approved QMS with scope that includes brokering activities
The second is that the R2 facility shall
- Identify/demonstrate conformance to legal requirements per CR 4
- Manage movement of R2 controlled streams through DSV chain using REC
- Be responsible for data and physical security of equipment/components/material throughout transport per CR 10
- Conform to tracking requirements per CR 5
- Provide packaging requirements to seller and/or transporter per CR 10.
Finally, if no R2 Controlled Streams ever pass through the broker facility, than conformance to CR 3 (EH&S Management System) and CR 9 (Facility Requirements) are not required.
Since there is no “R2 Facility”, there are no requirements for that facility, and in fact for ISO 14001 or ISO 45001.
You’d think we’d be done by now – but there’s more info to come!
Next up: REC – R2 Equipment Categorization
Can’t wait for the entire series and want to engage with us now? Contact us to start the process!