Recognizing Equipment Categories from a Non-R2 Supplier

By default, all electronic equipment, components and materials managed by an R2 Facility must be treated as an R2 Controlled Stream and managed in accordance with the R2 requirements until demonstrated otherwise.  This means that to determine the appropriate R2 processing pathway, an R2 Facility must evaluate all inbound equipment, components or materials to determine its processing status and level of functionality in line with the categories of the R2 Equipment Categorization (REC).

As part of this process, under Core Requirement 6.(b)(2), an R2 Facility can recognize the R2 Processing Categories and Functioning Product Categories assigned by the supplier.  However, where the supplier is not R2v3 Certified, the R2 Facility must implement a “documented evaluation and sampling process to verify the categorization.”

In order to effectively evaluate the devices and verify the supplier’s categorizations, the R2 Facility must have the necessary technical expertise and competency, as well as the processes, tools, equipment and software required to verify that data has been sanitized and confirm the level of functionality.  As a result, these verification processes should be incorporated, as applicable, into the R2 Facility’s Appendix B – Data Sanitization and Appendix C – Test and Repair processes.

In addition, the documented evaluation and sampling processes should address at minimum the following elements:

1. Assess the supplier’s data sanitization and/or test and repair processes to confirm they are capable of producing sanitized and/or functional devices.
2. Assess how the processing status and functionality categories are assigned based on the results of the processes performed.
3. Determine how the supplier’s assigned product categories align with the categories define in the REC.
4. Determine an adequate number of devices to sample and the frequency for sampling considering the number of devices received.
5. Sample the required quantity of devices and:
   • In line with the R2 Facility’s Appendix B sampling process, test for the presence of any data; and
   • In line with the R2 Facility’s Appendix C test plans, verify the functionality of the devices.
6. Based on the results of the sampling processes, determine whether devices meet the assigned categories.

Where any issues are identified through the evaluation and sampling processes, the R2 Facility must identify and manage all nonconforming devices in accordance with its defined processes for:

1. Managing devices where sanitization is not successful under Appendix B (14); or
2. Managing devices that do not meet the REC functioning product category under Appendix C (4)(f).