By Dr. John Lowell, Compliance Manager, Wistron Greentech
Provision 1 of the R2 Standard requires certification to and approved envrionmental health and safety management system and permits two options:
- ISO 14001 (best environmental practices) and OHSAS 18001 (best worker health and safety practices); or
- RIOS (combines environmental, health & safety, and quality best practices)
One approach is to create individual "silos" or document systems for R2, RIOS, and/or 14001 and 18001. While this is an acceptable approach, it can lead to a large number of documents and a lot of duplication. When faced with the simultaneous management of multiple certification systems, the silo approach becomes unwieldy and, frankly, does not allow managers to take full advantage of leveraging each system to enhance the R2 requirements.
A better solution? Where there is either exact or related overlap, R2 managers should leverage across certifications to reduce documentation. Some examples of overlap:
|No Direct Overlap||Some Overlap|
Exact or Similar Overlap
|Reuse/Recover||Tracking Throughput||Responsible Management|
|Focus Materials|| ||Legal Requirements|
|Data Destruction|| |
| || |
Focusing on documents such as quality goals, management reviews, corrective/preventive action reports (CPARs), and non-conformances as examples, are all common to each of the certifications. A recycler needs only a single list of corrective actions that document actions across the Quality Management System -- not multiple CPAR logs. Auditors want to see that CPARs are being logged, and one log for all is usually adequate. The same holds true for quality goals, policies, and non-conformances.
Risk Assessment provides another opportunity for integrating R2 requirements with those from other systems. Likewise, the R2 Downstream Due Diligence can track directly with 9001 Vendor Approval, or the numerous types of EHS monitoring in R2 correspond to many items found in other certification standards. R2 requirements can even be enhanced by integrating them with related requirements from other certifications. And, importantly, a fully integrated system can save you up to 20% in audit costs on an annual basis.
As a growing number of upstream OEMs and mid-stream service providers mandate specific certifications of their supply chain, using a "silo" system will become very costly and cumbersome to sustain. Having an integrated system, with a core set of documents that are applicable across all certifications, and that also meet auditor requirements by tying system procedures to specific certification requirements, makes a lot of sense.