What activities to include (and NOT include) in R2 Scope Statement

Q.  Requirement 1.(b)(1) states that the R2 Certificate shall have an “accurate statement of the scope of operations…” What guidance should be followed to establish this scope of operations?

Section 11.0 of the R2v3 Code of Practices (COP) provides specific requirements for how the scope must be presented on the R2v3 Certificate. For each applicable R2v3 Process Requirement appendix, the COP defines specific terms that must be included in the scope.  In addition to these terms, the R2 Facility must also define the types of equipment, components, and materials managed related to each of the certifiable processes and have that information recorded on the R2v3 Certificate.

Q.   Can an R2 Facility write its own Scope?

Under Core 1.(b)(1), an R2 Facility is required to document and have published on their R2 Certificate an accurate statement of their scope of operations. Properly identifying the scope of operations is an important part of the certification process, as it signals to the Certification Body (CB) the R2 processes and activities that will be covered under the R2 Certification.  As a result, the initial scope, as defined by the R2 Facility will help the CB to identify which of the R2v3 Process Requirements apply to the facility’s operations and must be included in the R2 audit plan.

The scope of operations can change based on what the auditor observes and is able to verify through the audit process.  Discontinued processes, planned future operations, and other activities that cannot be demonstrated for an auditor cannot be included in the scope.  As a result, the final scope statement, as documented on the R2 Certificate, will be defined by the CB based on the R2 processes and activities assessed through the audit.

For more information on what the scope statement may and may not include, consult Section 11 of the R2 Code of Practices (Version 2).

Q:    Are the operations of downstream vendors (DSV) included in the scope of certification?

No, the R2 Facility’s scope of certification covers only the processes and activities that are directly managed by the R2 Facility itself.   In some cases, this may include operations that are external to the facility, such as collection sites or warehouses, but only where those operations are controlled by the R2 Facility.
Any R2 processes that are performed by a DSV would be verified by the R2 Facility through their downstream vendor qualification process under Appendix A. The R2 Facility’s DSV qualification process and the records related to each DSV verification are subject to review and assessment through the R2 audit to confirm conformance to the applicable Appendix A requirements, but those downstream operations would not be defined in the R2 Facility’s scope.

Q:    How far does the scope of R2 Facility extend for a smaller R2 division working within a larger parent company? What if they share a facility?

The R2v3 Standard defines the scope as “the extent of the R2 Certification covering all processes” and it must include “all certifiable activities at the facility.”   When developing the initial certification scope, the R2 Facility must consider:

• • All electronic equipment, components, and materials managed; and
  • Any process or activities related to the collection, processing or other management of the electronic items.

Non-R2 activities that may be conducted at the R2 Facility but these non-R2 activities “are not eligible for R2 Certification” and therefore are not included in the scope of certification.

Q:  Can we include planned or future operations in our current R2 scope?

No.  An R2v3 audit assesses and certifies the active operations of an R2 Facility through observation of the R2 processes and activities, as well as review of the related documentation and records supporting those operations. Any future planned operations that are not auditable and cannot be verified may not be included in the facility’s scope.