Provision 5(a) of the R2 Standard requires that all R2 certified companies have a Focus Materials Management Plan. "Focus Materials," also referred to as "FMs," are materials in end-of-life electronic equipment that warrant greater care because of their toxicity or potentially adverse effects to workers, public health or the environment if improperly managed. The format of the FM Management Plan can vary from company to company. It may be a stand-alone document, or it could be incorporated into another document such as a company's R2 Manual or Environmental Health & Safety (EHS) Manual. Regardless of the format, here are some important elements to consider when developing the FM Management Plan:
The FM Management Plan should lay out company policies and practices relating to the recycling requirements of Provision 5. Every type of equipment and Focus Material received should be identified and a description of the processing methods for each should be included. For example:
- Disassembled internally.
- Button cell batteries on the motherboard shall be removed in-house.
- All circuit boards shall be accumulated and sent to a downstream smelter for precious metals recovery.
Some recyclers choose to include the names of specific downstream vendors in their FM Management Plan. This is not required, but it is acceptable. Companies following this practice should note, however, that their FM plan will need to be updated whenever their list of approved downstream vendors changes. For some, this may be infrequent - others will need to update their FM management plan regularly to reflect changes in downstream vendors. Special requirements should be included in the FM Management Plan. For example, a business located in California may require all electronics to be labeled as Universal Waste in accordance with California regulations. Or if a customer requires physical destruction of hard drives rather than sanitization, this should also be included in an FM Management Plan. The FM Management Plan should be communicated to customers and to downstream vendors. The plan can be used as a tool to educate customers about how electronics will be managed throughout the recycling chain. It also details the requirements and expectations for downstream vendors in the recycling chain. R2 certified companies should have a plan in place for regularly evaluating the operations of downstream vendors to ensure their continued adherence to the FM Management Plan (Provision 5.e.1).