R2 Guidance & Knowledge Base
Q&As about Nonconformities
REFERENCE FOR THIS ARTICLE: CODE OF PRACTICES (COP) – SECTION ON CLASSIFICATION AND CLOSURE OF NCs
Q. What is a nonconformity (NC)?
A nonconformity (NC) is issued when an R2 Facility does not have sufficient evidence to demonstrate conformance with a requirement of the R2 Standard. It is the responsibility of the R2 Facility to provide evidence to the auditor that each R2 requirement is being met by the Facility. During the audit, if the auditor determines there is not enough evidence to verify that the R2 Facility is meeting a particular requirement, then an NC will be issued and corrections and/or corrective actions will be required to resolve the issue.
Q. Do all nonconformities need to be closed out before an R2 Certificate can be issued?
Yes, both major and minor NCs must be closed and verified with a follow-up remote or onsite audit by the CB Auditor before an R2 Certificate can be issued. This includes new, first-time certificates as well as certificates issued for a recertification.
Q. Do nonconformities identified during an internal audit need to be closed before the certification body audit?
Any R2 nonconformities that are identified through the Facility’s internal audit must be resolved and closed before the CB certification or recertification audit, or they will be recorded by the CB auditor as an NC. Facilities are encouraged to complete their internal audit well in advance of their certification body audits to allow sufficient time to address all NCs. Consider scheduling internal audits half-way between annual CB audits. The CB cannot issue the R2 Certificate until all NCs have been closed.
Q. What are the different stages in the corrective action process when addressing an NC?
There are four steps in the corrective action process:
- CORRECTION – the first step and action to eliminate the identified NC.
- CAUSE ANALYSIS – the determination of why an NC occurred. A cause analysis ensures actions are taken to address the reason(s) for the NC.
- CORRECTIVE ACTIONS – the changes put in place to address the cause of the NC and prevent its recurrence.
- VERIFICATION – the step that requires checking to determine whether the correction and the corrective action were effectively implemented to rectify the NC(s). Depending on the results of this verification, it may be necessary to make some modifications and repeat the process until it can be determined that the correction and corrective action have been effectively implemented.
Q. Do the timelines for addressing NCs change depending on the type of audit?
Regardless of the type of audit, the R2 Facility is required to provide evidence of correction to their Certification Body (CB) within 60 days of the issuance of an NC. This includes both minor and major NCs. If the Facility does not submit evidence of correction with the 60-day deadline, the CB is required to suspend the Facility’s certificate (if the Facility has an active certificate at that time).
| TYPE OF AUDIT | WHAT IS REQUIRED TO CLOSE NCs? | WHAT TIME IS ADDED FOR NCs? | TIMELINES PER COP |
|---|---|---|---|
| Stage 1 | Correction Only | Audit time is added when corrections need to be verified onsite or remotely, at the discretion of the CB. | The CB will ensure that the time gap between Stage 1 and 2 audits does not exceed six months. If the completion of correction exceeds this period, the CB must repeat the Stage 1 audit. |
| Stage 2 | Full Corrective Action Process | The CB will add audit time to verify that CA for minors/major NCs have been implemented and are effective to address the closure of NCs prior to audit package approval or certification decision. The audit can be done remotely or onsite and the type/duration of the audit is determined at the discretion of the CB. | Audit time must be scheduled within 3 months after the last day of the Stage 2 audit. Failure to close NCs within the stipulated period will result in the CB scheduling a repeat Stage 2 audit (no later than 6 months from the Stage 1 audit) for the Candidate Facility. |
| Surveillance | Full Corrective Action Process | The CB will add audit time to verify that CA for minors/major NCs have been implemented and are effective to address the closure of NCs prior to audit package approval or certification decision. The audit can be done remotely or onsite and the type/duration of the audit is determined at the discretion of the CB. | Within 6 months of completion of the Surveillance audit, the CB will add audit time to verify that CA for minors/major NCs (either onsite or remote) have been implemented and are effective to address the closure of NCs prior to audit package approval or certification decision. Failure to comply with this requirement will result in the suspension of the certificate. |
| Recertification | Full Corrective Action Process | The CB will add audit time to verify that CA for minors/major NCs have been implemented and are effective to address the closure of NCs prior to audit package approval or certification decision. The audit can be done remotely or onsite and the type/duration of the audit is determined at the discretion of the CB. | The remote or on-site audit time must be scheduled within 3 months after the last day of the recertification audit. If the R2 Facility fails to close the NCs within the stipulated period, the R2 Facility will need to re-initiate the R2 Certification process. The CB will need to complete Stage 1 and Stage 2 audits for the R2 Facility to be certified. |
Q. What is the difference between a minor and a major NC?
A minor NC is issued by a CB for incidents where an R2 Facility is unable to demonstrate conformity to part of a requirement in the R2 Standard. Usually, a minor NC is considered a one-off and is not going to cause a serious failure in meeting the R2 requirements. A major NC is issued by the CB when an R2 Facility is unable to demonstrate conformity to all or most of a requirement in the R2 Standard. A major NC is considered a significant gap in meeting the R2 requirements.
In addition, the R2 Code of Practices requires a major NC to be issued by the CB when an R2 Facility is unable to demonstrate conformity to a requirement in the R2 Standard under one or more of the following conditions:
- A group of related or repetitive NCs have been identified, indicating an inadequate or complete absence of implementation of a R2 Standard requirement.
- When the corrective action for an NC has not been effectively maintained from the previous audit.
- Failure to identify a Focus Material stream in the FM Management plan.
- Failure to provide evidence of implementation and maintenance of a material stream (equipment, components, or materials) in Core 1.
- Failure to provide evidence of implementation for a defined Process Requirement.
- Failure to identify a Focus Material Stream in the FM Management Plan.
- Failure to identify a Downstream Vendor in the flowchart of the downstream recycling chain.
- Due diligence has not been performed effectively for shipments of Controlled Streams in accordance with R2 Process Requirement Appendix A – Downstream Recycling Chain
- Failure to maintain a valid SERI Licensing Agreement.
- Misrepresentation of any aspect of the Certification scope, including the existence or status of any facility/seller name/location affiliated with the company.
It is important to understand that both minor and major NCs must go through the R2 Facility’s Corrective Action Process and meet the timelines for closure per the COP, with the exception of Stage 1 NCs that only require verification of correction and do not require a full corrective action plan.
Q. Why is my CB scheduling audit time to close out my NCs?
A CB is required to assign audit time for closure of NCs. Assigning audit time ensures an effective process for reviewing and closing NCs before the next audit. Timely closure of NCs also reduces the risk of having an R2 Facility remain certified when it is not operating in conformance with R2 requirements. It is at the CB’s discretion, depending on the number and nature of the NCs, whether on-site or remote verification is required. The CB also has discretion in determining the amount of additional audit time required to close and verify any major or minor NCs from any audit.
The Bottom Line: Early and detailed preparation will be the biggest factors for preventing NCs and ensuring a successful audit. The quality of your preparation and internal auditing directly affect the outcome of your Certification process. Be ready with sufficient objective evidence that will demonstrate to the auditor all R2v3 requirements are being met. And when nonconformities are identified, be quick to make necessary corrections and provide the required evidence of correction to your auditor to prevent a delay or lapse in your R2 Certification.
