[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 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 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.
Appendix C – Test and Repair
Appendix C addresses the competency and tools required to test, repair, or refurbish electronic equipment to product function equipment. It provides information for the level of functionality, cosmetic condition, and data sanitization status.
IF we go all the way back to Part 2 of this blog, where we reviewed Definitions, we can see that there are two definitions in that section that help us here – they define “Evaluate” (a variety of activities designed to assess various aspects of equipment or components to determine reuse potential) and “Test and repair” (processing of used electronic equipment and components to produce reusable products and define the category of functionality). This cleared up some confusion in the first draft between these two important terms.
The big news for R2v3, from a certification standpoint, is that if an organization certifies to Appendix C (or R2v3 in general), that it is also required to be certified to an approved quality management system (QMS) with a scope that includes all the equipment, components, and processes that apply.
For those unfamiliar with management system standards, it means that your organization will now also have to get certified to ISO 9001, TL 9000, or a similar QMS, in addition to being certified to an EMS and OHSAS system. So you’ll be working with a registrar to grant a total of 4 certifications – an additional 33% cost to your registration costs.
While there are many overlapping requirements in a QMS, there are several unique requirements that now have to be implemented. McDonald Consulting Group specializes in implementing integrated management systems for this very reason – with very little additional effort, your organization can implement multiple standards seamlessly. We’ve figured out the “Rosetta Stone” to make this happen. That said, there IS additional work that will need to be done by companies who are not yet QMS certified, in order to meet this requirement…
While several comments were submitted after the first draft, suggesting that this requirement be deleted, or at least qualified (if you repair or refurbish at least xyz number of components, then you would require ISO certification), the Technical Advisory Committee (TAC) has chosen to leave the requirement intact.
The TAC stated “The TAC reviewed and considered the comment, however it determined that high-quality test and repair operations are critical for ensuring the proper level of functionality of products for reuse, as well as compliance with legal requirements for export of the reusable product. As a result, the QMS certification requirement is intended to provide an additional level of quality control for this key processing function.” So, if you’re going to do test, repair, or refurbishment, you’re going to get registered to FOUR separate standards. Which means more cost for you. Also, although I happen to hold certifications for all four standards, there are many folks who do not – so you might have to pay for 2 registrar auditors to come for your certification. I’ll be interested to see how this plays out in the long run…
App C calls out the use of an R2 Reuse Plan, which includes
“(a) Written instructions for each of the requirements in this section applicable to the scope of operations of the R2 Facility, and
(b) Competency requirements for workers testing, repairing, and verifying equipment and components, and
(c) Product safety plans to demonstrate the actions the R2 Facility undertakes to investigate and verify that equipment and components are safe to reuse, including procedures to check for conditions affecting product safety, and responding to recalls, and
(d) Test plans to verify the functions of the equipment or components are working, including:
(1) Defining the functions by each equipment type tested, and (2) Testing methods and test equipment for each function, and (3) Pass and fail criteria for each function, and
(4) Methods of documenting and storing test results, and
(5) Categorization of equipment based on test results in accordance with the REC, and
(e) Quality assurance plans to ensure the effectiveness of tests, including:
(1) Methods to verify the accuracy of test methods and testing equipment, and
(2) Measurements to monitor the quality of reusable equipment and components, and
(3) Management of equipment or components that fail testing to prevent their unintended use, and
(4) Verification of assigned categories in accordance with the test results for each test performed on each unit, and
(5) Verification that data has been sanitized in accordance with Appendix B – Data Sanitization, and
(f) Product return policy and plan appropriate to the final destinations of the equipment and components being reused.
There’s a lot of requirements in this R2 Reuse Plan – it has to be documented; trained and competence verified; test plans defined by each equipment type; methods defined as well as pass/fail criteria; test results stored (for 3 years per CR3!), and equipment categorized; as well as a QA plan that includes methods, monitoring measurements, management of failed equipment and components, and verification of assigned categories, and a product return policy/plan. And that’s just one section of this Appendix!
The first draft of the standard has a requirement to check for recalls by the manufacturer (2.c.2); it has since been revised to “Product safety plans to demonstrate the actions the R2 Facility undertakes to investigate and verify that equipment and components are safe to reuse, including procedures to check for conditions affecting product safety, and responding to recalls... ”
While this is an improvement, I am still wary of how this will be interpreted by overzealous registrar auditors, who will expect a level of documentation and frequency that may be unrealistic and unprofitable to implement.
App C goes on to require that all tested, repaired, or refurbished R2 Controlled Streams are done within one year of receipt from supplies, or evaluated and inventoried for future use.
It goes on to lay out the requirements for the R2 facility that is doing the test, repair, or refurbishment, including
“(a) Ensure data is sanitized on the equipment or components being tested in accordance with Appendix B – Data Sanitization, and
(b) Ensure workers are competent in testing the functionality of the electronic equipment and effective test methods, and
(c) Test, repair, clean, refurbish and configure equipment and components according to the R2 Reuse Plan to determine the functional category in accordance with the REC, and
(d) Execute the product safety plans to assess the safety of all functional equipment and components, and
(e) Generate and maintain records of test results for each function tested for each unique identifier assigned, and
(f) For equipment or components that do not meet a REC functioning product category when tested:
(1) Identify the equipment or components as non-functioning products, and (2) Repair the equipment or component and repeat testing after repair, or (3) Harvest the reusable components, or
(4) Evaluate the equipment in accordance with Core Requirement 6 to continue processing, and
(g) For equipment or components that meet a functioning product category in the REC when tested:
(1) 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, and
(2) Execute the quality assurance plans to confirm the assigned categories, and
(3) Based on the new category assigned after test and/or repair, manage the equipment in accordance with Core Requirement 6 to continue processing.
Section F lays out what to do with non-functioning products per REC; while G provides direction when the part meets testing criteria. Companies that are doing repair and refurbishment will need to pay particular attention to the sub-bullets in this section to ensure that you meet the requirements.
But wait – there’s more info to come!
Next up: Appendix D – Specialty Electronics Reuse
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.
