[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 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 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. hyperlink
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).
Now in Part 9, we’ll review Core Requirement 9 – Facility Requirements (R2:2013 Provisions 9 & 11)
The focus of CR 9 is on the facility itself – that it be legally compliant, protects the health/safety of workers, as well as the public, and protects the environment.
It is a combination of several clauses from the R2:2013 standard, and partially or fully addresses Clause 9 (Storage), Clause 10 (Facility Security), Clause 11 (Insurance, closure plan, and financial responsibility). By combining these together, and providing one CR that addresses the physical location from cradle to grave, it provides a more cohesive approach to addressing physical location and the requirements for safe and lawful operation.
It requires that work be performed indoors unless controls have been established to prevent uncontrolled releases to the environment. The facility has to store all R2 controlled stream to protect them from weather, meet legal compliance, protect against unauthorized access, and in clearly labeled containers / storage areas. This is a departure from previous requirements, and now allows “under cover” instead of “inside”, specifically:
Core Requirement 9.(a) – “An R2 Facility shall conduct all processing operations indoors unless the risks of the any outdoor operations have been assessed and controls established to prevent uncontrolled releases to the environment. ”
Core Requirement 9.(c) – “An R2 Facility shall store all equipment destined for reuse in an enclosed environment protected from the elements, unless intended for outdoor use. “
This change addresses some previous concerns for non-electronic equipment (vehicle, transformer, gas cylinders) that is okay to store outside, but had to be stored inside per R2:2013. It also includes shipping containers, trailers, and other temporary secured storage areas.
CR 9 also calls out the insurance requirements to cover potential risks and liabilities, and ensures that its insurance and/or reserves are adequate to cover these liabilities, including coverage of work-related injury and illnesses, as well as other requirements called out elsewhere in the R2 standard.
CR 9 addresses the need for a written closure plan that provides for closure of the facility in event of abandonment. This includes how the equipment, components, and materials will be managed; the risks (including equipment / materials that could be received under the facility’s certification scope); the reasonably foreseeable financial costs for processing remaining inventory, ensuring that environment was not affected (Sampling for environmental contamination/site remediation); ensure that funds for closure are established consistent with applicable law and closure plan; and include any process/closure requirements that may be referenced elsewhere in the R2 standard.
Abandonment financial instruments are not required if…
“(1) The total cost to properly close the facility in the event of abandonment is less than $10,000 United States Dollars, and
(2) The size of all buildings owned, leased, or used by the R2 Facility is less than 1,000 square meters, and,
(3) The facility prohibits and never accepts equipment or materials containing mercury, CRT glass, lithium primary batteries, or polychlorinated bi-phenyls.”
This is great news for companies that meet these requirements.
In the second draft comments, the question was raised about financial assurance, and the Technical Advisory Committee (TAC) had the following response:
“Typical examples of financial instruments for the closure plan include: trust funds, surety bonds, and letters of credit. However, the R2 Facility may also use other forms of funding such as asset based funding and corporate guarantees.
Assets intrinsic to the facility may be used to fund the closure, as long as the market value of the assets has been determined and updated annually, and the party responsible for liquidation of all assets has been identified.
A written corporate guarantee, that meets all defined criteria as indicated in Guidance, is also a permissible form of financial instrument.”
Another key issue that was deleted from the second draft was the requirements to provide closure plans, financial instruments, and insurance plans to SERI, since this information is often confidential and changes annually. Having to provide this to SERI and keep it updated did not serve a good purpose; auditors can review documents on-site to ensure they are in place and active.
But wait – we’re not done yet!
Next up: Core Requirement 10 – Transport
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.