[Note: “Text in italics and quotes” below are quoted directly from the R2v3 second draft standard.]
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 into 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.
This Core Requirement is one that gives many recyclers pause (and heartburn) – as the General Principle states, “To evaluate, sort, and categorize all equipment, components, and materials in accordance with the R2 Equipment Categorization reference document to ensure the applicable R2 requirements are followed throughout processing and outbound through the downstream recycling chain. Equipment and components may change categorization through stages of processing.”
It goes on further to state in 6.a that
“An R2 Facility shall develop and maintain a documented process to evaluate, sort, and categorize
electronic equipment, components, and materials controlled and processed. This process shall:
(1) Conform with the hierarchy; Core Requirement 2; and
(2) Include the applicable categories from the R2 Equipment Categorization (REC) or maintain a documented correlation of existing categories in use to those defined in the REC, to demonstrate the levels of functionality, data sanitization status and physical condition of the items; and
(3) Identify all data storage devices; and
(4) Define the instructions and criteria to determine if the equipment and components are capable of reuse based on physical condition, functionality, and value in the destination market; and
(5) Include steps to re-evaluate R2 Controlled Streams when processing changes the category of the stream. “
Let’s break this down a bit more. We are now sent to the R2 Equipment Categorization (REC) document which provides the ‘applicable categories’. While a separate later post will be devoted to the REC in detail, for now, peeking inside the doc we see that it has evaluation stage categories, data sanitation categories, cosmetic categories, and functioning product categories. For purposes of CR 6, REC applies to all “not evaluated / unknown functionality” equipment. (We’ll come back to REC again later in this post and discuss it in more detail).
Now imagine you’re a recycler that has just received a gaylord. It’s ‘not evaluated/unknown’ at this point. 6.a.2 requires you to categorize everything; 6.a.3 requires you to identify all storage devices (we’re talking anything that can save data – so, it may be scanners, desk phones that store numbers – anything!), 6.a.4 says that you have to have defined instructions for sorting, and 6.a.5 brings back in our R2 Controlled Streams when we change the category of the stream.
Wait – if we go from not evaluated / unknown to categorized, didn’t we automatically change the category of the stream? So, 6.a.5 requires us to evaluate every blinkin’ part again vis a vis our Controlled Streams now. And remember, this is under documentation – we all know that that means for our record keeping, right?
While there were several comments in the First Draft against this CR for Sorting, a large proportion of the comments had to do with the REC itself – it was seen as too prescriptive. Accordingly, the second draft added in language “REC, or the equivalent correlated internal categories.” This was implemented to allow companies that have their own system (maybe loaded into an existing ERP system, etc.) to use it once it’s been mapped back to REC. (The REC itself was also updated to simplify categorization, according to the SERI). While these changes ARE an improvement on the First Draft, I’ll be interested to see if there are still a number of comments on this second draft language.
Categorization states that
“(2) All equipment, components, and materials shall be managed as an R2 Controlled Stream that requires further processing in accordance with the R2 requirements, unless it:
(A) Has been processed and categorized by another certified R2 Facility, in which case the provided REC categorization can be recognized, or
(B) Has been processed and categorized by a non-R2 facility and the R2 Facility has implemented a documented evaluation and sampling process to verify the categorization, or
(C) Can be demonstrated with appropriate test and/or verification records to be sanitized and functional, or
(D) No longer meets the definition of an R2 Controlled Stream.”
Accordingly, if you use another R2 facility (basically, you’re buying from an R2 certified company) that provides its own REC, you can accept it as-is; or if you’re buying from a non-R2 certified company that provides a list, you have to take a verification sample; or you can test it yourself; or you can classify it outside of an R2 Controlled Stream and don’t have to process it further as a Controlled Stream.
This brings images of sorting and categorization we’ve seen at our clients to mind – big sorting tables with gaylords arranged around it – materials being sorted based on their value, base materials, etc. Care will have to be taken to meet all the documentation requirements in 6.a as well as the categorizing requirements in 6.b.
Let’s move on to 6.c and 6.d – evaluate and process.
Evaluate requires that a defined process be in place to determine capability of reuse, and ensure that equipment, components, and materials are directed to the next process as appropriate. Pretty straightforward.
Process requires that all equipment and components are evaluated “for data, including connected user accounts and services, and identified with the corresponding data sanitization status from the REC. “ This references CR7 (Data Security) to further define how to meet this requirement; as well as Appendix E for Materials Recovery; Appendix C for Test and Repair; Appendix A for Downstream Recycling Chain; and Appendix D for Specialty Reuse Electronics.
Note that ‘data sanitization is called out twice in CR 6 – this is covered in CR 7, specifically 7.c.2 – if through a DSV, that’s in Appendix B, and for a non-R2 DSV, that’s in Appendix A.8.d
Basically, CR 6 ties in to most of the Appendices, keeping CR 6 manageable only by referencing boatloads of other requirements.
Think of this as a process flow:
🡪Data? Secured and Controlled (CR 7)
🡪 not allowed to be sold or donated for reuse? CR 7 and App E
🡪 Reuse? 🡪ID uniquely;
🡪 Test/refurbish/repair (App C) or
🡪 Transfer to DSV (App A) or
🡪 Process (App D)
🡪 Can’t Reuse? 🡪 Materials Recovery (App E) or
🡪 Transfer to DSV (App A)
Does that help?
Output that is determined to be an Unrestricted Stream (as defined in REC) has to be managed/identified separately from Controlled Streams, meet justifications for being unrestricted, and have adequate records maintained, including cosmetic condition where applicable.
Records need to be kept including unique identifiers, and international shipments still must meet import/export compliance requirements.
Output also refers to packaging per CR 10; App C Test and repair, and App D Specialty Electronics Reuse.
While this Core Requirement has a lot of moving parts, if you break it down as I have in the process flow, and follow the text exactly, you should have no problems complying with this “meaty” CR.
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But wait – we’re not done yet!
Next up: Core Requirement 7 – Data Security
Can’t wait for the entire series and want to engage with us now? Contact us to start the process!
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