By Corey Dehmey, R2 Director
SERI has observed Focus Material (FM) Management Plans of many R2 Certified Recyclers that specifically name the downstream vendors in a company’s recycling chain. While this is an acceptable method of developing the FM Management Plan as long as the additional requirements of Provision 5.a are being met, it really misses an opportunity to establish the policies of your organization and enforce those policies through the downstream recycling chain.
FM Management Plans should define the policies of your organization regarding the way you and your downstream vendors (DSVs) will process electronics. It also is an effective tool for sharing your policies with your customers. Provision 5.e.1 requires that all downstream vendors conform to your FM Management Plan. It is your responsibility to set the policy consistent with the R2 Standard, and to ensure that your recycling chain is consistent in conforming to your FM Management Plan.
The FM Management Plan can dictate many things as long as the policies do not conflict with R2 Standard requirements. For example, you could dictate where your downstream vendor sends specific materials for further recycling, such as Lead Acid batteries to an approved vendor for final processing. You could also dictate the method(s) of processing for specific types of products, such as lead smelting for CRT glass. Maybe you want to establish a time limit for processing your equipment by the downstream vendor. If DSVs are not willing or able to meet the specifications of your FM management plan, then you would need to select a different DSV who is willing and able to do so.
An FM management plan can also direct how devices and/or components are reused. For example, you may want to direct downstream vendors to only harvest parts for reuse, and not whole units. In the FM Management Plan, you could also choose to prohibit the export of whole non-working or untested electronics by any downstream vendors.
How far your policies go beyond the requirements of 5.a is up to you. The more prescriptive you are in your FM Management Plan, the clearer your expectations will be to your partners. The additional policies you incorporate will establish your FM Management Plan as a customer requirement that your downstream vendors must meet. It is important to note, however, this may limit your choice of DSVs as some may be unable and/or unwilling to go above and beyond R2 requirements. This is particularly so for smaller companies trying to impose more prescriptive policies on larger companies.
Finally, establish a contractual relationship with your downstream vendor by having the vendor sign and agree to abide by your FM management plan. Then follow-up with due diligence to ensure the vendor is complying with your FM Management Plan. Repeat this at least annually.
Bottom Line: Use the FM Management Plan to clearly articulate your policies, both internally and to your downstream network, to further establish a system of accountability in your recycling chain. Your customers are looking for this level of accountability.