DISCUSSION

Shortly after R2v3 was released, we published two guidance articles on Appendix applicability in the R2 Knowledge Base (R2v3 Appendix Applicability Guidance and R2v3 Appendix Determination Tool).  We have learned through implementation, however, there was a lack of clarity in those articles, and although they are technically correct, the applicability of appendix E to various scopes has been inconsistent.

Those guidance articles tried to explain the applicability of Appendix E using language about destructive dismantling vs. non-destructive de-manufacturing to differentiate between the actions of de-manufacturing, in which components are harvested and collected in a manner designed for the testing and reuse of components, as opposed to a less-careful dismantling process in which components and materials are separated before recycling. This document seeks to clarify the confusion among R2 Facilities, Certification Bodies, consultants, and auditors, and to provide additional clarity as to the applicability of Appendix E in different situations.

WHEN DEMANUFACTURING IS PERMITTED WITHOUT APPENDIX E

• Core 2(b)(1)

R2 encourages reuse through the hierarchy of responsible management strategies in Core 2.  To maximize reuse potential, Core 2(b)(1) specifies that reusable equipment and components are to be directed to appropriate reuse channels. Under this requirement, facilities can harvest components for reuse even when the whole equipment is not capable of reuse.  For example, a chip can be cut off a board if the chip is harvested for reuse.  Or heat can be applied to a mobile phone to open the phone and harvest components for reuse.

Core 6(a) requires an R2 Facility to develop and maintain a documented process to evaluate, sort, and categorize electronic equipment.  This includes 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.  The whole equipment may not be capable of reuse because it is damaged or does not meet a minimum tech cutoff line, however, the components from that equipment may be capable of reuse.

De-manufacturing is the process of gently removing components from equipment without damaging the components so that they can be reused.  When components are removed for the purpose of reuse, those components are either tested in house or tested by a downstream vendor qualified to Appendix A to test, repair, and refurbish.  When de-manufacturing is done to remove reusable components from equipment, Appendix E is not applicable.

When harvesting components, sometimes it may be necessary to remove a component that will not be reused in order to access the reusable component(s).  For example, removing a phone battery that will not be reused in order to get to the camera that can be reused.  In cases when the ultimate purpose of removing components is to harvest some (or all) of those components for reuse,  a facility can perform the parts harvesting process without being certified to Appendix E.

In contrast, when equipment and components are determined not be capable of reuse, then  dismantling of the equipment for the purpose of materials recovery requires Appendix E.     There is no qualifier in the language of the standard regarding non-destructive versus destructive processing techniques, so if an R2 Facility chooses to process equipment and components that is not capable of reuse in any fashion, Appendix E is applicable.  Alternatively, destructive techniques such as heating a phone to open it and harvest components for reuse or cutting a chip from a board are not prohibited by the standard nor do they require certification to Appendix E.

• Core 6(d)(2)
  R2 facilities are also permitted to remove and secure components that may contain data under Core 6(d)(2). For example, an SSD can be removed from a laptop to be sanitized with software or shred in a self-contained hard drive shredder.  After sanitization is performed, the SSD would be re-evaluated in accordance with the REC.  The sanitized SSD would likely be directed to reuse unless there is no value in the destination market due to size of the drive or other factors, whereas the shred SSD would be directed to materials recovery.  A logic board from a mobile phone may be removed and crushed in a self-contained chip crusher.  Since the capability of reuse is evaluated after the data sanitization occurs, and before it is directed to reuse or materials recovery, Appendix E is not required.

EXAMPLES AND EXPLANATIONS

A mobile phone with a damaged screen is received at an R2 Facility certified to Appendix A, B for logical sanitization, B for physical destruction, and C for test and repair.  The R2 Facility understands that the camera is a reusable component and that the board needs to be destroyed because it is a data bearing component. The R2 Facility uses heat to open the phone with tools to gently pry open the device. The battery is removed and set aside for materials recovery, the camera is removed and inventoried for future use in repairs, and finally the board is removed, and chips on the board are crushed in the self-container shredder/SSD chip crusher.  The remainder of the phone is also set aside and sent downstream for materials recovery.  Even though heat was used in the de-manufacturing process, Appendix E is not applicable because components were being harvested for reuse and data sanitization.

A set top box is received at an R2 Facility certified to Appendix A.  The R2 Facility understands these set top boxes do not have value in a destination market and are going to dismantle the equipment to send the components downstream for materials recovery.  The R2 Facility separates equipment to a component level in a careful manner by removing the screws, taking the cover off, removing the boards, cables, wires, the hard drive, and all other components.  The boards are placed in a Gaylord box, the hard drives are placed in a locked bin to go to physical destruction, and the rest of the components are separated into material types in Gaylord boxes.  Even though the dismantling was performed in a non-destructive manner, Appendix E is applicable because the equipment and components were not capable of reuse and the R2 Facility processed the equipment through dismantling to the component level.  See Appendix E Applicability Flowchart Guidance (Flowchart) for other examples, this example is representative of Scenario 3 on the Flowchart.

AUDITING

Here are some potentially helpful audit trails to follow to determine whether Appendix E is applicable, however, please remember that these are merely examples and not the sole audit trails that could be followed to determine if Appendix E is applicable.

• When auditing R2 Facilities, consider looking at the process in Core 6(c) to determine if Appendix E is applicable. Is de-manufacturing done for the purpose of harvesting components for reuse or data sanitization?  Or is the dismantling done for the purpose of separating components to send to various downstream vendors for materials recovery?
• Auditors may look for evidence that components are being resold to a downstream vendor that is qualified in accordance with Appendix A to test, repair, and refurbish as audit evidence that components were harvested for reuse.
• Auditors may look for evidence of reuse in the placement of components during the separation processes. Are components being placed in trays or bins which would preserve the components from being damaged?  Are the components placed in slots in boxes or something to prevent damage as compared to being tossed into a Gaylord box or bucket.  Are processors tossed in bucket likely being preserved for reuse?
• Auditors may look for evidence of reuse by the tools that are used like manual use of a screwdriver or other handheld tools which are less likely to break components inside the equipment versus power tools which are usually used to remove screws quickly to separate components without regard for reuse.
• An auditor may look for commercially accepted records that contain evidence that the components were sold by piece versus by weight.
• Auditors may also look for evidence that the R2 Facility has test records for various components that were removed from equipment.
• If the R2 Facility is not certified to Appendix C and only Appendix A, and there is no evidence that components are being sent to a downstream vendor that is qualified in accordance with Appendix A to test, repair, and refurbish, the auditor should likely follow audit trails to determine if Appendix E is applicable.
• Evidence may be observed in the R2 Facility’s documented process to evaluate, sort, and categorize electronic equipment…in accordance with Core 6(a)(4) and Core 6(c).
• Alternatively, evidence may be observed in the R2 Facility’s FM Management Plan when discussing the planned methods and demonstrated capacity needed to process each type of electronic equipment containing an FM in accordance with Core 8(a)(2).
• Evidence might be observed elsewhere depending on the structure of the R2 Facility’s documentation.

Please reach out to your Certification Body or the team at SERI if you have any questions or need additional clarification.