Qualifying non-R2v3 Downstream Vendors for Materials Recovery

Common Questions about qualifying downstream vendors (DSVs) for MATERIALS RECOVERY  [as required in Appendix A (8) (f)] 

Q.   When qualifying a DSV for Materials Recovery, do I need to get the credentials of the individual conducting the Appendix E (2) hazard assessment if this was already done when verifying the Core 3.(d) requirements?

Appendix E requires an additional level of diligence in the hazard assessment process because of the higher risk associated with materials recovery operations.  As a result, more specific requirements for the competency of the individual(s) conducting this assessment have been defined.  It would be important to verify the competency of individuals responsible for those activities, however, should this information already be verified through other assessment of Core Requirements it would not need to be duplicated, only referenced in the due diligence records to verify conformance to the requirements.

Q.   Am I required to verify all of the Appendix E (4) requirements for my DSV even if they don’t apply to their operations?

Each of the requirements of Appendix E (4) must be specifically assessed through the DSV’s hazard identification to determine which are applicable to the operations.  The hazard assessment will also be able to demonstrate which requirements do not apply and the reasoning for such a determination.  For those items that are deemed applicable, the facility would then use the assessment to determine the necessary controls and level to incorporate the requirement into the EHSMS to ensure proper control.

Q.   When qualifying a DSV for Materials Recovery, under Appendix E (4)(i), am I required to get copies of all industrial hygiene (IH) testing performed?

The standard does not require copies of any specific testing or results, only that the need for testing is evaluated through the hazard assessment, and where deemed applicable, evidence that an industrial hygiene program is in place based on the test results.

Q.   When qualifying a DSV for Materials Recovery, under Appendix E (4)(l), do all DSVs require a medical monitoring program?

No.  The results of the hazard assessment should be used to determine if, based on the risks present, medical monitoring is needed — and if needed, what specific type(s) and level of monitoring is necessary.

Q.   When qualifying a DSV for Materials Recovery, is evidence of conformance with each item in Appendix E (4)(a-l) required?

No.  The R2 Standard does not require evidence that each item has specifically been implemented, but rather that all are assessed through the hazard assessment and implemented as applicable.  As a result, evidence of implementation of all items will not necessarily be available.  Instead, it would be expected that there is a verification that necessary EHSMS controls are in place to address any applicable requirements.

Q.   When qualifying a DSV Materials recovery, under Appendix E (8), are we required to get copies of their closure plans (including calculations) and financial instruments?

Appendix E (8) does not stipulate requirements for closure plans or calculations, only that financial assurance for environmental incidents be in place.  In some cases, this may be covered through pollution liability insurance, and other cases it may be addressed through guaranteed reserves which can often be verified through audited and publicly available financial statements.

Q.   Are all DSVs required to use the REC categories?

As equipment and material moves through R2 processes the REC classifications can change.  These changes need to be accounted for in your FM Management Plan and the resulting materials identified and handled accordingly throughout the entire downstream chain.  In this case, the DSV would not necessarily be implementing the REC itself, but rather conforming with the classifications and management processes, including the use of appropriate DSV, as defined by the R2 Facility in its FM Management Plan.

In addition, the DSVs may either use the specific categories defined in the REC “or maintain a documented correlation of existing categories in use to those defined in the REC…” (Core Requirement 6.(a)(2)).  The importance of using the REC, or categories mapped to the REC, is to demonstrate the R2 applicability to all equipment and materials throughout the entire recycling chain, and ensure items are managed accordingly.