PODCAST TRANSCRIPT:

You’ve probably heard a lot about the scope of certification in the R2V3 standard, but what exactly is that and how is the scope determined for an R2 facility? That’s the topic of this episode of Ask The R2 Guru. I’m Roger Greive, from SERI – Champions of Electronics Sustainability.

The R2V3 standard has 10 core requirements. Of these 10, the first four establish the foundation for the operations and structure of any R2 facility. These are things such as the hierarchy of responsible management strategies, the EH&S management system, and legal requirements. The next six govern the activities and the physical conditions of the facility such as data security, focus materials, and transport.

And of these 10, the very first core requirement is Scope. And there is a reason for this. The technical advisory committee that wrote the standard realized that before an R2 facility could do anything else, each facility needed to determine exactly what their processes are and what materials and equipment they manage, in order to determine which R2 requirements apply and how.

It’s important to note that each R2 Facility’s scope of certification is unique to their operations.  The scope clearly identifies what is covered under the certification in terms of the specific types of R2 activities. It also specifies the equipment or materials managed by that facility.

But, the scope doesn’t just include the processes performed at the facility.  The scope also includes all of the R2-related activities controlled by the facility.  That means that the scope may include off-site activities and locations, such as warehouses and collection points.  The scope may even include services provided off-site, such as data sanitization activities performed at a customer’s facility.

A key aspect of the Scope is that each facility determines which of the R2v3 Process Requirements apply to them. For the sake of illustration and a quick review, let’s run through the process requirements again with this in mind.

• Appendix A – Downstream Recycling Chain – Is for facilities that are not the final point of disposition and require a network of downstream vendors to perform further R2 processing.
• Appendix B – Data Sanitization – Is for facilities with additional data security controls and for those facilities that perform an enhanced level of physical and/or logical data sanitization and tracking.
• Appendix C – Test and Repair – Is for facilities that test, repair and refurbish electronics to produce functional devices.
• Appendix D – Specialty Electronics Reuse – Is for the facilities that manage highly sophisticated specialty electronics for reuse,
• Appendix E – Materials Recovery – Is for facilities that perform materials recovery operations, often through a variety of manual or mechanical destructive dismantling and separation processes.
• Appendix F – Brokering – Is for those facilities that source used electronic equipment or materials and manage the delivery of those items directly to downstream vendors for further processing and/or recovery.

So a facility’s scope is determined largely by which of these six process requirements apply. For the second and final part of the Scope, the facility must also consider the types of electronic equipment, components, and materials they manage, as this is also highlighted in the scope.

There are some things that the scope does not cover.  This includes any activities that are outsourced to downstream vendors, because those activities would be covered under the downstream vendor’s scope.  The scope also does not include planned or future activities.  So, if a facility plans to add a new process, or start managing a new stream of devices, they would need to ensure that all processes and R2 controls to manage those devices are in place, so that the facility can demonstrate conformance with the R2 requirements before those activities can be added to the scope.  So when you’re planning any changes to your operations, it is important to notify your Certification Body prior to making the changes, and to work closely with your CB to determine the best steps and timing for auditing the processes.

Proper scoping of the R2 Certification allows facilities to specialize in the areas best suited for their operations, and when the need arises, each facility can assess whether there is any value in adding new processes or equipment to their scope.

Just remember, only those activities that can be audited and verified in conformance with the R2 requirements can be included in an R2 Facility’s scope.

In summary, the scope serves two primary purposes.  First, prior to certification, it helps each facility determine the R2v3 Process Requirements that apply to their operations and that must be included in their unique scope of certification.  And second, after certification, the scope clearly identifies the specific operations that each R2 Facility is certified for.  This enables R2 Facilities to demonstrate the specialized skills and processes they maintain which is an important aspect for communicating to customers the specific services provided by the facility.  This helps R2 facilities select downstream vendors to perform specific processes and it also allows customers to select R2-certified processors best suited to meet their needs.

The scope of certification is an accurate and up-to-date description of the activities and operations of each R2 certified facility and the materials and equipment they manage. The full printed scope of each R2V3 facility is easily available on the SERI website using the Find an R2 Certified Facility search tool and hitting the more info button beside the facility.

There are specific requirements for how the scope is defined, and those are identified in section 11.01 of the R2v3 Code of Practices.  There are also some resources available on the R2 Knowledge Base that can help your facility identify what should be included in your scope as well as what requirements would apply should you make any changes in operations.  We have an appendix applicability guidance document and a tool that could help you determine which appendices apply to you. Episode one of this podcast series is also about determining which appendices apply to your facility.

As always, I hope you’ve enjoyed this episode of Ask The R2 Guru and found it helpful. Thanks to the SERI team 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.