PODCAST TRANSCRIPT  (modified 4/10/23):

Well, it’s April 2023, and that means we are less than 90 days from completing the transition to R2v3.  More than 700 R2 facilities around the world have completed that transition and are now R2v3 certified, and hundreds more have completed their R2v3 transition audits and await final approval of their new certification.  So what have we learned, and how can SERI, consultants, auditors and R2 facilities work together to make the end of this transition even better? That’s the topic of this episode of Ask The R2 Guru. I’m Roger Greive, from SERI – Champions of Electronics Sustainability.

We’ve talked about this before, but the process of becoming R2 certified has a lot of moving parts.  It’s a lot more than just passing some sort of test in front of an auditor.  Admittedly, most of the work for becoming R2 certified is done by the R2 facilities themselves, which is as it should be. But there are also the contributions of consultants, internal auditors, the upstream and downstream vendors that facilities work with, R2 auditors, and the certification bodies that guide the auditors and administer the entire certification process.

This podcast is different from the other podcasts in the Ask The R2 Guru series because this information relates to the experiences of facilities that have gone through the transition process already.  As more facilities become R2v3 Certified, with different applications and experiences, there will be more for all of us to learn including facilities, consultants and auditors. We will be sure to keep you apprised of any key lessons learned as we continue toward the transition deadline.

I’m going to quickly list off a few areas where there have been numerous questions or issues raised from facilities going through the transition process. In the interest of time I’m not going to answer or explain each one in detail because these are covered more thoroughly in the knowledge base in the various guidance documents we’ve created. You can use the SERI website to email us for clarification if you have specific questions. That said, here are some of the most common issues we’ve heard about so far:

Numerous facilities have had some confusion over which process requirements they would need to have included in their scope and fully certified to under R2V3. There have been a few incidents where audits have been delayed because auditors have found operations in the facility that were not included in the facility’s proposed scope of certification thus requiring an adjustment to the process requirements being audited. Sometimes, process requirements needed to be added to the audit, which results in additional audit time as well. Other times the reverse was true and Process Requirements were not audited or included in the scope where the processes could not be observed.  When planning your audit scope, be sure to work closely with the CB and clearly identify all activities and operations being managed by the facility, including any off-site activities, to ensure the scope clearly reflects the operations.

For some facilities, there has been confusion over whether appendix E is required or not.  This appendix is for materials recovery, and the basic misunderstanding is around the concept of dismantling versus de-manufacturing.  Think about the basic difference between the two. De-manufacturing is the removal of intact components, as would be done for part harvesting, for the purpose of reuse.  Dismantling is where devices are taken apart in the process to separate the components and materials for materials recovery.  And, keep in mind that in order to be a downstream vendor for materials recovery, a facility is required to be certified to Appendix E.

There have also been some questions about the need for pollution liability insurance. The new R2v3 standard is different from the older version of the standard because not every facility is required to maintain this insurance coverage.  This is why pollution liability requirements are not included in the Core Requirements, but rather covered under Appendix A and E.  So, any of the higher risk facilities that are managing negative value materials or performing materials recovery will require it.

We’ve also been answering questions about the documentation and process of physical data sanitization versus logical sanitization issues such as individual device tracking as opposed to processing and tracking data devices in large batches.  While the standard allows for tracking of data sanitization results both by each individual device as well as in batches, the method used will depend in part on the type of device, the sanitization process used and the intended use or disposition of the device.  Each facility must carefully consider these factors and ensure their Data Sanitization Plan reflects the proper method to accurately demonstrate their sanitization activities.

There have also been questions about what is an R2 Controlled Stream and what is an R2 Unrestricted Stream, which is defined in the R2 Equipment Categorization Document or REC.  And speaking of the REC, many facilities have not realized that there is an option to map their own product grades to the categories in the REC to satisfy that requirement. Also, not every sorting category from the REC is required for every facility and the categories need to be adjusted to match what is actually happening at each R2 location.

If any of those topics have sounded familiar to you well, don’t worry, you’re not alone… obviously. It’s important to remember that each one of these topics that I just mentioned has further details and solutions that are available in our R2 knowledge base. As I mentioned earlier, we are all in this together and it’s important to stay in touch with your certification body, your consultant if you have one, and the people at SERI who are here to help. We want to be a resource throughout your transition to R2v3, and sharing the insights learned from those who have gone through the process already is something we will continue to do.

As always, I hope you’ve enjoyed this episode of Ask The R2 Guru and found it helpful. Thanks to Sean DeVries, Sarah Kim and Jeff Siebert for their assistance in producing this podcast series. If you have any questions or comments or want to suggest a topic for a future podcast please use the contact us form on the SERI website. You’ll find us at SustainableElectronics.org.