PODCAST TRANSCRIPT:

The Most Common NonConformances for R2v3 

More than 600 R2v3 audits have been conducted in facilities around the world.  With that many completed audits, we now know the most common issues that resulted in nonconformances at those facilities.  In this episode, we’re going to examine some of these nonconformances with suggestions on how you and your facility can better prepare for them. We hope you’ll stay tuned for this episode of Ask The R2 Guru.  I’m RG from SERI, Champions of Electronics Sustainability.

First, a note that this podcast is being recorded in late-February of 2023 and hundreds of R2 facilities are still in the process of transitioning to the R2v3 standard.  But as I mentioned earlier, compiled trends are available from more than 600 audits that have been completed.  From these trends, we can identify the most common nonconformances.  There are eleven of them and I’m going to quickly list them off at the beginning here and then go into detail on three of them.  There’s no need to take notes or try to memorize this list of 11 because a complete transcript of this podcast is available in the podcast section of the Knowledge Base.  It’s on the SERI website.

So let’s quickly go through that list of 11, beginning with an issue from Core Requirement 4.  One of the Top 11 nonconformances was that R2 facilities lacked the proper evidence to demonstrate legality of their imports and exports.  This is from core requirement 4(c)(1) and (2).

Next, from Core Requirement 6, two issues emerged.  First, some facilities lacked any internal correlation between their sorting and evaluation categories and those categories listed in the R2 Equipment Categorization Document, or REC.  This is Core Requirement 6(a)(2).  Also, categories from the REC were not disclosed to buyers purchasing reusable devices —  specifically, the data sanitization status and cosmetic condition of those devices.  This is from Core Requirement 6(e)(2)(A).

From Core Requirement 7, some facilities neglected to perform an annual data security and data sanitization audit which is required in Core Requirement 7(c)(3).  And from Core Requirement 7(b)(3), facilities lacked signage controlling unauthorized access to those parts of their facility dedicated to storing, evaluating and processing data bearing devices.

From Core Requirement 8, facilities did not have a documented and complete downstream vendor flowchart all the way to final disposition of focus materials or to the first R2V3 facility.

There were two more common nonconformance as related to management of downstream vendors; both of these are from Appendix A.  It appears that some facilities were confused on the two options of requirement 4 in that appendix.  We’ll be going into detail on this in a few moments, but facilities did not register their downstream recycling chain that they manage with SERI, which enables their downstream tracking to stop at the first R2 facility.  Also from Appendix A, facilities did not conform to all the requirements of Appendix A(8), which is a complete and thorough qualification of downstream vendors that are not R2v3 certified.

The final three common non conformances found in among the first 600 R2v3 audits performed are all from Appendix B – Data Sanitization.  From Appendix B requirement 5(c), facilities were lacking 60 days of video recordings of all areas of their facility where data bearing equipment or materials are received, stored or passed through.  In a related nonconformance, facilities also did not have 60 days of video recordings of physical data destruction at their facilities.  This is Appendix B requirement 9.  And finally, facilities were found lacking in conforming to requirement 13 of Appendix B which calls for routine sampling of all logically sanitized data storage media, to verify data is not recoverable by commercial software.

Let’s spend the rest of this podcast taking a closer look at three of these common nonconformances from Core Requirement 6, Core Requirement 8 and Appendix A.

I’m going to begin by reading the wording from the standard of Core Requirement 6(a)(2).  In discussing the documentation required by facilities to evaluate, sort and categorize electronic equipment components and materials, facilities are required to do the following from requirement (a)(2):

Include the applicable categories from the R2 Equipment Categorization or maintain a documented correlation of existing categories in use to those defined in the REC to demonstrate the levels of functionality, data sanitization status and physical condition of the items.

This requirement is in the standard to allow facilities to use their own categorization and evaluation categories that they may have been using for years or that is in their existing software, as long as they match up their categories with the categories in the R2 equipment categorization document.   Facilities can use one or the other, but the nonconformances found that many facilities were not using either one — or that the categories they were using were not matched up with the categories in the REC document.  This requirement was designed to give facilities some flexibility while still ensuring that they have a rigorous process for evaluating and categorizing their electronic equipment, components or materials while maintaining some degree of consistency of categorization across all R2 facilities.

In practical terms, a facility that has an established system for categorizing materials could list their various categories, with a brief description of each, along with a listing of the equivalent REC Category.  Or they could list the various REC categories with a corresponding list of the facility’s categories.  For your facility, just make sure that you’re using one or the other, either the REC categories for data sanitization status, functionality and cosmetic condition or your own categories, matched up to those in the REC.  On the opening page of the REC, the fourth paragraph explains this and allows you to choose either method. Whichever method is used, it is important that R2 facilities use the introductory classifications from the REC such as R2 Controlled Stream, Uncontrolled Stream, Non-Data and Pre-Sanitization because these high-level classifications apply to every facility and determine the required processes that follow, such as data sanitization, testing, repair, materials recovery, and use of downstream vendors.

Core Requirement 8(a)(3) seems to be another point of confusion, resulting in nonconformances around this requirement.  Requirement 8(a) is about the development and adherence to an FM management plan in R2 facilities, and requirement 3 calls for the following:

When not the final point of processing, a flow chart of the downstream recycling chain selected according to Appendix A, Downstream Recycling Chain, including identification of international movements, to either final disposition or the first downstream R2 certified facility.

A flowchart of a facility’s downstream recycling chain has been in use by hundreds of facilities since the start of the R2 standard, but R2V3 makes this flowchart a requirement. So for facilities that are transitioning to the R2V3 standard, this might be the reason that this requirement has been overlooked. But it is a requirement nonetheless and needs to be included in every facility’s focus materials management plan.  As you are checking to make sure that you have this flow chart in your facility’s FM plan, remember that if you are sending materials to an R2v3 certified downstream vendor, the tracking of that material can stop with that R2v3 certified downstream vendor, provided that you have filed your downstream vendor flow chart with SERI.

When I was a compliance manager for an R2 certified refurbisher and recycler, before I joined the SERI staff, I found that a downstream flowchart was a really effective tool for a number of reasons.  Not only was it an easy way to keep track of the various downstream vendors that were being used but it was also a good communications tool for training the rest of the staff on how important it was to accurately track and manage the downstream flow of focus materials.  A sample downstream flowchart is available in the Register Your Downstream page in the Knowledge Base on the SERI website, and Episode 9 of this podcast series also has additional information on Downstream Vendor tracking and management.

This connects directly to the third and final common nonconformance that we will be looking at in detail in this podcast.  It ties in very closely to the last one and it’s from Appendix A, requirement (4).  It’s for facilities not registering their downstream recycling chain with SERI.  Even though this nonconformance is usually written against requirement (4)(b), this is really this is about requirement (4)(a) and (b) because the two are linked, giving R2 facilities an option on how to track their downstream recycling chain.  They can either track their downstream recycling chain all the way to final disposition or to the first R2v3 facility.  It’s up to them; here’s the requirement:

An R2 facility shall…

(a) Track and demonstrate the complete downstream recycling chain of all R2 controlled streams to final disposition, or
(b)  Register with SERI the portion of the downstream recycling chain that it manages, including all R2 controlled streams to final disposition or the first R2 Facility, to enable mapping of the entire chain, and register any changes prior to shipment.

 In writing this part of Appendix A, SERI’s Technical Advisory Committee gave facilities the option as to which path they choose to take.  Those facilities can either track their downstream recycling chain to final disposition of all materials, or they can register their downstream chain with SERI and then track those materials to the first R2v3 facility, where tracking stops.

If this seems a little confusing, we have two different training videos on Appendix A in the R2 Knowledge Base on the SERI website and in those videos, there are graphics that explain this process in a lot more detail. For your facility to avoid this nonconformance it’s important to choose one of those two options — either document everything for every downstream vendor to final disposition of each focus material or file your downstream flowchart with SERI. It’s an easy process.  The form you use to file your downstream is on the SERI website.

So whether you are preparing for your first R2V3 audit or your first annual surveillance audit, we hope this listing of common nonconformances will help you in the process of having a productive and successful audit.

One final note…some R2 facilities might emerge from their audit disappointed that their auditor found some nonconformances that needed correction, while others might be celebrating an audit in which no nonconformances were found.  But keep in mind, the process of becoming R2 certified means that whatever the outcome of a single audit, your facility has decided to prepare for those audits in order to hold your facility accountable to a high standard, verified through an external audit process that requires conformance to every applicable requirement.  And this process creates and reinforces that accountability through continuous improvement, so that customers can have increased confidence that R2 facilities like yours are properly managing used electronics.

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That’s it for this episode of Ask the R2 Guru.  Thanks for listening, and as always, thanks to the SERI team for their assistance in producing this podcast.  And once again, you can find a complete transcript of  this podcast with a listing of the most common nonconformances in the Podcast Library section of the R2 Knowledge Base on the SERI website. You’ll find that at sustainable electronics.org.