R2 Guidance & Knowledge Base

Understanding R2v3 Remote Surveillance Audits

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ORIGINALLY BORN OUT OF NECESSITY

The travel restrictions and limited access to facilities during the COVID-19 pandemic created a challenge for auditors and R2 Facilities in terms of completing audits. To address that issue, SERI explored ways to help R2 Certified facilities maintain their certification while still ensuring quality and conformance during that challenging time. Among the ideas tested and evaluated was a remote audit process for R2 Certified facilities transitioning from R2:2013 to R2v3. After testing this process for over 2 years, it was evident that the initiative was not only successful but also effective. SERI therefore adopted the same remote audit process for surveillance audits under Code of Practices (COP) Version 2.2.

The COP Version 2.2, Section 8.5.1, now permits one surveillance audit in a certification cycle to be done remotely. It is important to note that remote audits are conducted at the discretion of the Certification Body (CB), but for those facilities that qualify for a remote surveillance audit, there are multiple benefits.

  • Efficiency – Documents and records are shared in advance of the audit using the R2 Facility’s controlled file sharing portal. This allows the auditor to review the documents before the opening meeting is conducted – and reduces the time demand for facility personnel throughout the course of the audit.
  • Flexibility – There can be flexibility in scheduling time blocks that suit the schedules and working hours of Facility personnel. Remote audits also make it easier to make last minute schedule changes to adapt to emergencies or other scheduling conflicts.
  • Cost Savings – The auditor is not required to travel to the R2 Facility, which eliminates travel expenses.
UNDERSTANDING THE REMOTE AUDIT PROCESS

The remote surveillance audit process as specified in COP Version 2.2 is divided into the following six phases:

Phase 1 – Pre-Qualification
Phase 2 – Information Gathering
Phase 3 – Opening Meeting, Facility Tour
Phase 4 – Documentation and Record Review
Phase 5 – Interviews, Follow-up
Phase 6 – Closing Meeting

Phase 1 – Pre-Qualification

During Phase 1, the R2 Facility will provide to the CB evidence of meeting the following pre-requisites:

  • Existing R2 Certification with same Scope and address
  • Current SERI License Agreement.
  • Certification to an Environmental, Health and Safety (EHS) management systems (refer to the Accepted Standards List on SERI’s website). EHS certification must be issued by a CB that is accredited by an Accreditation Body that is an IAF MLA signatory. Note: Once an accreditation body is a signatory of the IAF MLA, it is required to recognise certificates and validation and verification statements issued by conformity assessment bodies (aka CBs) accredited by all other signatories of the IAF MLA, with the appropriate scope.
  • Certification to a Quality Management System (QMS) acceptable to SERI, (refer Accepted Standards List on SERI’s website), as applicable. Issued by a CB that is accredited by an AB (Accreditation Body) that is an IAF MLA signatory.
  • Completion of an R2v3 Internal Audit of the entire scope of its operations, including all R2v3 Core Requirements and applicable R2v3 Process Requirements.
  • Implementation of corrective actions for any Nonconformities (NCs) that were identified during the R2v3 Internal Audit.
  • Completion of a Legal Compliance Audit by a competent internal auditor knowledgeable in the operations and all applicable requirements (this could be someone competent from within your facility or an outside resource or consultant)
  • 100% due diligence and qualification of all downstream vendors in accordance with Appendix A (7) and A (8).
  • Completion of a Data Sanitization Plan per Core 7.
  • Completion of an R2 Reuse Plan, as applicable, per Core C.
  • Required insurance(s) per Core 9, and Appendix A and E, as applicable.

Facilities must keep the following pre-qualification requirements in mind:

  1. Significant Changes – Any significant changes will require the CB to conduct an on-site audit of the changes. Examples of significant changes could include, but are not limited to expanding the facility’s scope to include a new process or accepted material stream; or changes to the certification scheme such as expanding a single facility to a campus; or a facility move from location to another; etc. The CB has discretion to determine what constitutes a significant change that would require an on-site audit.
  2. Filing Sharing – All records and documents must be provided to the auditor in a secure file sharing system. Some examples are DropBox, Box, Google Drive and/or applications containing evidence like CycleLution, Makor, RazorERP, etc.
  3. Video Sharing – A portable video sharing application such as FaceTime, Google Duo, WhatsApp, MS Teams, etc., is required for conducting live, on the job, worker interviews, and visual tour(s) and assessment(s) of all areas indoors and outdoors at the R2 Facility’s location(s). Test all areas of the site for adequate connectivity (cellular or Wi-Fi) and ensure there are no dead spots where video or other information sharing is limited or not possible, including outdoor areas of the property (e.g., storage, parking lot and perimeter). The audit will be suspended if the video sharing is not functioning or does not provide sufficient audio clarity.
  4. Employee and Processing Availability – Ensure all necessary employees are available for participation in the remote audit to support the audit objectives and ensure all process requirements and activities within the scope of the certification are auditable at the time of the audit.
Phase 2 – Information Gathering

The R2 Facility is responsible for uploading the documents specified in Table 1 of the COP, Version 2.2 for the auditor to access in the file sharing application. If some documents and records are in paper copy format, the R2 Facility will need to scan and upload those documents to the File Sharing application.

Table 1 lists the expected documentation and records that are to be uploaded, by the R2 Facility, at least 10 days prior to Phase 3.   These documents and records shall remain available during all the phases. Sharing the documents and records required in Table 1, via video conferencing is not permitted. Not all documents in Table 1 will be applicable to every surveillance, however Core Requirements 1, 5, 7, and 8 are required for every surveillance. The audit cannot start if the R2 Facility is unable to make any of these documents and records available during Phase 2. The auditor may also request additional documents and records not listed in Table 1. Table 1 is meant to be a representative list, not a comprehensive list of documents that will be reviewed during the audit process. A screenshot of Table 1 under Section 9.2 in the COP is given below. Please refer to this section of the COP for more details on what documents for review under each requirement.

Table 1
Phase 3 – Opening Meeting, Facility Tour

The R2 Facility will be present at a virtual opening meeting which is followed by an in-depth/all-inclusive virtual facility tour. The tour is meant to be a thorough review of the activities and processes of the R2 Facility. The tour takes place indoors and outdoors and uses the viable video sharing application. This tour includes all campus locations and controlled processes/activities not at the R2 Facility, for example, off-site data destruction.

Phase 4 – Documentation and Record Review

Phase 4 is intended to provide the auditor time to independently review the records and documentation that have been uploaded and document conformance in the R2v3 Audit Report. Phases 4 and 5 are iterative and may be conducted non-sequentially to enable the auditor to move to Phase 5 interviews to test and verify information assessed through Phase 4 if the objectives of each phase and the audit can be achieved. It is the R2 Facilities’ responsibility to ensure all additional records and documents are uploaded as needed into the file sharing system.

Phase 5 – Interviews, Follow-up

During this phase, interviews are conducted by the auditor to confirm that the R2 Facility’s operations are actively running, as applicable to the scope of the certification and audit plan. It is the auditor’s responsibility to ensure adequate evidence is reviewed to demonstrate conformance to the R2v3 Standard and R2 Facility’s scope.

Phase 6 – Closing Meeting

Closing meeting is conducted in this phase. The auditor communicates NCs as recorded in the audit documentation and audit report.

Additional Expectations at a R2v3 Remote Surveillance Audit
  • Breaks, pauses or other adjustments in audit time or format may be necessary to fully complete the remote audit, especially when there are technical issues. The CB will add time, as needed, to accommodate adjustments and ensure full audit time is accomplished.
  • R2 Facility makes available, in a timely manner, any personnel that the auditor chooses to speak to during the remote audit.
  • The auditor or the CB may choose to verify additional records or documents, at any time during the audit phases, and therefore has the discretion to add additional time, and/or determine the need for an on-site audit, as necessary.
  • Timely R2 Facility responses for information are required throughout the audit process.
  • Corrective actions and technical review process will follow requirements in the COP and the CB’s procedures. An R2v3 Certificate will not be issued, or “continued registration” will not be communicated until all R2v3 Remote Audit NCs are verified closed with objective evidence by the CB.
  • Under the SERI Assurance Program, SERI may witness any remote audit to monitor effectiveness of the process.
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