[Note: “Text in italics and quotes” below are quoted directly from the R2v3 second draft standard.]
In Part 1 of this series [hyperlink] 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.
In Part 6 we discuss sorting, categorization, and processing, including a helpful flowchart 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
Many folks think that the R2 standard is the “FM” standard. While FMs are a key part of the standard, there are a lot of controls around electronics in general as well as additional emphasis on FMs.
CR 8 still requires an FM Management Plan, which ensures that FMs are linked to the EHSMS. It also ensures that if you are not the final processor, that Appendix A for Downstream Recycling Chain is followed. This requirement for a flowchart of the downstream recycling chain, including international movements, to final disposition OR the first downstream R2 Certified facility, will be where implementers will be focusing their efforts. This is a HUGE improvement over the R2:2013 version, where it did not allow the chain to stop at the first R2-registered facility. My question, as an implementer, was then “Why do we bother using an R2 certified DSV if we still have to do all the due diligence of their DSVs?” This change has partially addressed that, and is a welcome recognition that if an R2 certified facility is doing their own due diligence, repeating it is not necessary.
There are several issues with Appendix A itself – that will be covered in a future blog post.
CR 8 also calls out non-FMs requiring specific management in 8.b, which details print cartridges. There is some ‘heartburn’ in the R2 community around this – what about the folks that sell printer cartridge filler kits? Do they now have to actively monitor the folks who are refilling the cartridges to save some money while reusing this resource? It appears from comments that some folks feel that this is too prescriptive and does not allow for various usage scenarios; however, the Technical Advisory Committee feels that, since this is not a change from R2:2013, it stands as is.
Some of the biggest controversy around this CR is that it is also covered in CR 2, Hierarchy of Responsible Management Strategies. If you go back to part 3 of this series, you’ll see that Disposal (3.3) covers both FM and non-FM parts. So then why do we need to call it out again here in CR 8?
Actually, there is a key DELETION from this section – the requirements on Prohibition on Energy Recovery, Incineration, and Land Disposals of FMs. This was moved to CR 2 for clarity, where it falls into the Hierarchy discussion, both for FMs and non-FMs. I think this makes CR 8 much cleaner from an implementation perspective.
But wait – we’re not done yet!
Next up: Core Requirement 9 – Facility Requirements
There’s a lot of information in these posts! 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.