PODCAST TRANSCRIPT:

As R2 facilities transition to the R2 V3 standard, there are a lot of questions about how to manage downstream vendors. That’s the topic of this episode of Ask The R2 Guru. I’m Roger Greive, from SERI – Champions of Electronics Sustainability.

One of the major elements of the R2 standard has always been answering the fundamental question of what happens to the equipment, components and materials received by each R2 facility. How are those items processed, and where do they end up? The management of these items is woven throughout the R2 standard from Core requirements right through the applicable Process Requirements, depending on the intended disposition for each piece of equipment or material stream.  Is it destined for reuse and therefore requires data sanitization and test and repair?  Or, has the item surpassed its useful life and requires processing for materials recovery?  The answers to these questions can be found in the Focus Materials Management Plan and downstream recycling chain.

This process for selecting and qualifying downstream vendors is so central and so important to the R2v3 standard that the first and possibly the most important appendix in the R2 process requirements is Appendix A, the Downstream Recycling Chain.

In this podcast we’re going to discuss a couple of things – how your facility can establish a thorough method of documenting the flow of materials through your downstream vendors and, equally important for now at least, the transition from the R2:2013 Standard to the R2v3 Standard among the various facilities in your network of downstream vendors. I will also direct you to some resources available to assist you in this process.  They can all be accessed through the R2 Guidance Knowledge Base, in case you want to follow along during this podcast.

As we begin our discussion of downstream vendor management it’s important to remember that qualified downstream vendors are required for the movement, sorting and processing of all focus materials. And focus materials themselves include any equipment or components that contain a focus material, such as untested or nonfunctioning devices. And by the way, there’s a helpful chart in the Definitions section of the R2 Standard on focus materials covered by R2 along with definitions for each and information on when the required tracking of each focus material ends.

Each R2 facility is required to have a Focus Materials Management Plan as part of Core Requirement eight. This plan will describe the processing methods used and final disposition for each focus material your facility receives. For most of these materials, your facility will not be the final processor and that’s where using downstream vendors comes in. Your focus materials management plan will also include a downstream flowchart showing each step in the downstream recycling chain, including the vendors used, the materials they receive from your facility, and how they are processed. We’ll discuss this flowchart in greater detail in a few minutes. Also, as you begin the process, please remember that your facility needs to complete your downstream vendor verification before your first shipment to any downstream vendor.

Almost every R2 facility that is certified to the R2v3 standard will also be certified to Appendix A – Downstream Recycling Chain, since most facilities require a network of specialized processors to manage different equipment or materials streams they generate. This appendix defines the requirements for qualifying downstream vendors to ensure that all facilities operate in conformance with the relevant requirements of the R2 standard as they process focus materials and devices containing focus materials, whether those facilities are R2 certified or not. There’s a couple of ways to check this.

The easiest way to qualify downstream vendors is to use an R2v3 certified facility with a scope of certification covering the processes required for the specific materials your facility generates. When you use an R2v3 downstream vendor, your facility needs to show proof of their receipt of those materials with a detailed description of the materials, quantities, dates, and conformance with any relevant export requirements. And, if you choose to register your downstream flow with SERI, for any downstream vendor that is R2v3 certified, no further tracking to any subsequent processor is required. You will find the exact wording for this process in Appendix A, Requirements four and seven.

Did you know that an R2v3 certified facility has a lot of flexibility  when it comes to choosing their downstream vendors? As one option, they can choose to send all their focus materials to other R2v3 certified companies. The advantage to this is that they save time because there is no required due diligence of checking numerous tiers of downstream vendors past the R2v3 company. They will also save money in their annual R2 audit, because having R2v3 certified facilities in a downstream does not add any additional audit time, thus audit expense.

But even with these advantages, an R2v3 certified facility can send their focus materials to any facility, certified or not, provided those downstream facilities meet the requirements as specified in Appendix A, Requirement eight. This requirement has several different sub sections that may or may not apply depending on the equipment or material being sent to them. For instance, if the materials being sent to a non-R2v3 downstream vendor do not contain any data bearing materials then the entire section of data sanitization requirements does not apply.

Generally, any downstream vendor that is not R2v3 certified needs to conform to your facility’s FM management plan, and they need to demonstrate that they adhere to a documented management system for Environmental Health and Safety.  It’s important to note that these companies do not need to have an audited and certified EHSMS, but they do need to have some required elements of a management system as specified in Appendix A, Requirement (8)(b).

Non-R2 downstream vendors also need to provide a current list of permits and licenses to demonstrate compliance with the various Environmental Health and Safety requirements applicable to their scope and their national and local laws. There are also some specific items in requirement A(8) for tracking throughput and not storing materials with a negative value for more than one year.

The remaining items in requirement A(8) are all for specific operations, including for facilities that perform data sanitization, facilities for test and repair, and facilities that specialize in materials recovery.

There are three other important considerations when working with downstream vendors. First, in requirement A(7), an R2-certified downstream vendor is described as one that includes applicable process requirements or appendices in its scope of certification. That means that only R2v3 certified facilities, with an appropriate scope of certification qualify as an R2 downstream in requirement seven. Because of the many differences between R2:2013 and R2v3, any company that is still certified to the R2:2013 standard will need to be evaluated according to the expanded requirements in appendix A(8). After those facilities have been audited and certified to the R2v3 standard, their downstream verification requirements become much simpler, and your due diligence process in qualifying these facilities becomes simpler as well.

Second, it’s important for your R2v3 facility to verify the relevant items in requirement A(8) for every tier of a multi-tier downstream and show the transfer of the materials from one tier to the next until one of two things occur. Either the focus materials move through the tiers until they reach an R2v3 certified facility, or the materials move through various tiers until they undergo final processing as defined in the definition of Focus Materials. There are examples of both scenarios in the sample Downstream Recycling Chain Flow Chart  found in the R2 Guidance and Knowledge Base on the SERI website.

And that leads to the third and final thing when working with downstream vendors in R2v3. Requirement Four of Appendix A is about transparency. And it’s another place where the R2v3 standard offers some flexibility to R2 facilities. There are two options –you can track and demonstrate your entire downstream recycling chain, including all facilities, certified or not all the way to final disposition, or you can register your downstream flowchart with SERI. Remember, you have a flowchart already because it’s required as part of your Focus Materials Management Plan. If you choose to register your flowchart, that chart would include the movement of all focus materials, and you can choose whether to stop tracking materials with the first R2v3 downstream vendor or list every step, every tier through the final disposition of each focus material.

You’ll find complete information on how to register your downstream flowchart with SERI in the Register Your Downstream  article in the R2 Guidance and Knowledge Base.  It contains instructions, the online submission form, and a sample downstream flowchart for reference.  It’s easy and secure to submit your downstream information and to update it as required in the Standard whenever that information changes.

So, to sum up… there are some significant changes in the management of downstream vendors in the R2v3 standard. There are opportunities for flexibility in how an R2 facility can manage their downstream vendors while maintaining transparency and the ability to uphold the best practices of professionalism, high ethical standards and environmental responsibility.

There are a lot of additional resources in the R2 Guidance Knowledge Base. Go to the sections on Core Requirement eight and Appendix A where you’ll find videos, articles and other implementation tools to help your facility become familiar with these updated requirements.

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 Seibert 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.