R2 Guidance & Knowledge Base

Pollution liability insurance

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Q. Are all R2 Facilities required to have pollution liability insurance under R2v3?

No, pollution liability insurance is not a requirement for all R2 Facilities, and therefore it is not included in the R2v3 Core Requirements.

Pollution liability insurance is required for higher risk R2 Facilities, as defined in Appendix A – Downstream Recycling Chain, when the R2 Facility manages ‘negative value’ equipment, component or material streams.

In addition, R2 Facilities certified to Appendix E – Materials Recovery are also required to maintain assurance for environmental incidents which may include pollution liability insurance or other guarantees.

Q:   Why is pollution liability insurance required for R2 Facilities that handle negative value equipment, components or materials under Appendix A (2)(a)?

The requirement for pollution liability insurance is intended to address those R2 Facilities where the potential risk of pollution is greatest, while excluding certain low risk operations.

As a result, the requirement for pollution liability insurance has been placed in the Appendix A – Downstream Recycling Chain and Appendix E – Materials Recovery to apply to those facilities that are processing for material recovery, or otherwise handling negative value items, which incur a cost to manage.

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