[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.
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.
Part 16 reviewed Appendix F – Brokering – our last appendix.
Now, we’re going to spend some time reviewing the R2 Equipment Categorization, or REC. The REC is “used to determine the R2 process applicability for all equipment, components and materials upon receipt and throughout processing, and to assign the cosmetic, functional, and data sanitization status to Collectible and Specialty Electronics, and Functional Products after processing. These categories are integrated with the R2 Standard to ensure the proper handling of the equipment by the R2 Facility. While these categories may be applied to individual pieces of equipment or components, they may alternatively be used to identify the status of batches of equipment or components, or specific storage areas.”
REC is meant to be ‘shorthand’ for denoting status of equipment – it can be used both by R2 Certified and by uncertified facilities when discussing categorization of electronic equipment for resale and recycling. It “is intended to be used for descriptive purposes in accordance with the R2 Standard to allow for a certified R2 Facility to assign and thereby define agreed upon cosmetic, functional, and data sanitization statuses to equipment and components upon receipt, in-process, and after processing.“ according to the disclaimer, which goes on to state that “The R2 Equipment Categorization (REC) is only offered for use on an “AS IS” basis for R2 Standard conformance only and is not intended to substitute for any other descriptions or categorizations that may otherwise be necessary, whether for contractual purposes, legal compliance, safety, or any other purpose.”
Initial reviewers of the draft standard didn’t want to get pigeonholed into exact wording issues (think back in the old standard re: the wording for labels in resale/repair). Accordingly, the released version of the standard states that “While it is preferred that an R2 Facility use the exact REC categories in identifying equipment in their operation and on their records, the R2 Facility may alternatively use an equivalent equipment grading and categorization system by cross-referencing their existing categories with this REC, using a written and audited cross-reference document to ensure consistency.”
Even better, the standard writers realize that every facility may not need every categorization, and states that only relevant categories are used.
REC has categories. Yep people, we got categories. And the categories are defined in a variety of ways. The first table, Table 1, discussed R2 Applicability, and calls out that “When equipment has been sanitized, tested and verified functioning, it can move from the R2 Applicability categories, to the Functioning Product categories (Table 4).” Table 1 goes on to define R2 Controlled Streams (where R2 evaluation and processing is required), and includes the applicable Core Requirements (6, 7, Appendices A, C, D, E, or F); while unrestricted streams (no further R2 processing or DSV verification) includes non-electronic equipment, non-focus materials (CR 2), or Planned return equipment/components which may include warranty return, recall, return to individual owner, failed equipment, errant shipment, damaged in shipment, and nonconforming equipment.
Table 2 discusses Data Sanitization Status, and has major topics of Pre-Sanitization (requires data evaluation and/or Sanitization) and Non-Data (Sanitized or free of data storage media).
Table 3 covers Cosmetic Categories, and includes 9 sub-category sorts – from damaged through to used (poor, fair, good, very good, excellent), to certified pre-owned, to unused, to new open box. These defects are coded as “C” and correspond with the various categories. While each sub-category has descriptors, there are no well-defined status for some of these terms (what’s the difference between minor scratches, light scratches, and scratches?). While there were several comments made during the consultation period on providing more concrete direction the TAC addressed it by stating that “Core Requirement 6.(e)(2)(A) has been revised as follows, to provide greater flexibility on cosmetic descriptions: “Identify and disclose the appropriate REC, or equivalent correlated internal categories, for Functioning Product, Data Sanitization Status, and either the Cosmetic Condition or provide other detailed description of the cosmetic condition of the equipment or components to the buyer.. .”
I’m not sure that I agree that this addresses the concern – especially coming from other industries, where you know the size of a defect – “no more than ¼ inch” for example, to be considered minor scratch, which in turn allows an inspector to have their handy dandy guide there, and pop it over the scratch – if the ¼” dot covers the scratch entirely, they know it can be marked as minor. No such helpful information is provided by SERI for determination of cosmetic defects.
Table 4 covers Functioning Product Categories (so our categories are F1-F6) starting with collectible or Specialty Equipment, then verified specialty equipment, key functions working (Appendix C – Test and Repair), hardware Functional (App C), Refurbished (App C), and Like New (App C). These categories provide guidance for hardware, software, and components sorting, and the last 3 categories include no hardware defects (Hardware Functional), no hardware or software defects (Refurbished), and zero defects (Like New).
In addition to the tables, there are Appendices.
Appendix A provides Enhanced Cosmetic Category Info, and covers visual appearance, label condition, dents and scratches, discoloration, missing parts, latches and hinges damaged, cleaned inside and out, and packaging; worked into a matrix against the C1-C9 categories.
Appendix B is Linkage with Functioning and Cosmetic Categories, and covers “equipment that have been processed and ready to be sold for reuse (finished goods). Products are assigned a combination of functional and cosmetic categories to ensure the product is finished processing.”
It provides a cross reference between the functionality description and the cosmetic category, which could prove to be helpful.
Organizations can set up a documented cross reference from their own categorization system to the REC, which will prevent them from having to set up a separate ERP just to conform to R2. However, for companies that are starting out, it will be helpful to use the REC methodology to determine cosmetic and functional codes.
Interested in getting some assistance on R2 implementation? Check out our other blog posts or contact us to get more info.