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 this post for Part 3, we start digging in to the standard’s Core Requirements – the auditable portion of the R2v3 standard. Specifically, we start with the Scope and Hierarchy of Responsible Management Strategies (R2:2013 Provision 2).
The R2v3 Standard opens with the Scope, which talks about processes including equipment, component and material streams management, activities related to collection, refurbishing, repair, resale de-manufacturing, asset recovery, brokering and recycling of used electronic equipment, components, and materials.
The Scope has added requirements to ensure that all R2-related activities performed by a facility are transparent, and audited /included on the R2 Certificate.
It lays out the requirements for R2 Core Requirements (Section1) and R2 Process Requirements (Section 2), as well as requirements for the Certificate wording. All locations covered under the R2 standard have to be listed; and a new statement:
“An R2 Facility shall not have been included by SERI, within the previous 24 months of any certification audit, in a list of organizations maintained by SERI on its website that have been found to have engaged in deceptive marketing, illegal acts or other fraudulent activities which could reasonably lead to a false impression that the R2 Facility was certified to the R2 Standard during that period.”
Review of public comment change requests and their disposition highlights that the Scope has been revised to provide clarity in several areas. The key ones include
- Ensuring that the scope applies only to the R2 activities (wording clarified to include “associated with certifiable activities” to address this)
- Clarification of waste streams to “equipment, component, and material streams managed”
- Revision includes clarification of included and excluded operations and activities.
While we may not know why this was added to the standard, I can tell you that there was significant auditor and consultant training provided in 2019 about facility and scope, including “paper trails” using Bills of Lading, packing lists, and other evidence/records for both incoming and outgoing shipments, and review of activities observed during walk-around and audits.
Core Requirement 2 is the Hierarchy of Responsible Management Strategies. This covers the hierarchy of reuse first, followed by materials recovery for recycling. Core Requirements (CR) include both on-site and off-site activities and selection of Downstream Vendors (DSVs) that is based on this principle of hierarchy of responsible management strategies.
CR 2 details evaluation and sorting per CR 6 (SORTING, CATEGORIZATION, AND PROCESSING), with details added for Reuse, followed by Materials Recovery, and finally Disposal.
Disposal Core Requirement 2.b.3a and 2.b.3b has some new information:
(A) Focus Materials (FMs) – Energy recovery, incineration, or land disposal shall not be used as a management strategy for FMs or equipment and components containing FMs unless applicable law requires the use of a specific technology (e.g. hazardous waste landfill or incineration of PCBs). However, if documented extreme and rare circumstances beyond the control of the R2 Facility disrupts its normal management of an FM, it may consider using these technologies to the extent allowed under applicable law until normal management is again possible.
(B) Non-Focus Materials – Only when all opportunities for reuse or materials recovery have been exhausted and there are no technically viable recycling processes available may an R2 Facility direct material to the most environmentally beneficial option of energy recovery, incineration or land disposal.”
This CR gives ‘teeth’ to the hierarchy requirement – you must follow the path for FM’s, then non-FMs; and it must be Reuse followed by Recycle. Additionally, when disposing of the materials, you need to consider the most environmentally beneficial options among energy recovery, incineration, or land disposal. This requires the implementer to have a knowledge of the environmental concerns with each of these methods, and to make a determination based on the waste profile. Will you be releasing harmful toxins into the air by incineration? Will restricted substances leach into the groundwater if land disposal is chosen? Knowledge of the consequences is key here to making the right choice.
While these two Core Requirements are pretty benign from an implementation standpoint, they do lay the groundwork for the rest of the CRs. Stay tuned for analysis of the rest of the Core Requirements!
But wait – we’re not done yet!
Next up: Core Requirement 3 – EH&S Management System, and Core Requirement 4 – Legal and Other Requirements
Can’t wait for the entire series and want to engage with us now? Contact us to start the process!
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