Provision 6 (Reusable Equipment and Components) requires an electronics recycler to implement a written Quality Assurance Plan (QAP). The QAP is a specific document that must be titled “Quality Assurance Plan” and included as part of the electronics recycler’s management system. A QAP defines methods to verify the accuracy of test methods, testing equipment, and records requirements. Its purpose is to ensure products are sold to the buyer in conformance with Provision 6 and any buyer specifications.
The QAP should include:
- Definition of Roles and Responsibilities. The recycler defines roles and responsibilities for all levels of workers involved in the testing processes. Roles and responsibilities could be defined for the following types of workers: sorters, testers, calibration technicians, final inspectors, testing managers, and nonconforming product reviewers. Keep in mind a technically qualified final inspector should be someone other than the actual tester.
- Worker Competency. When processes require workers to make decisions, a recycler must verify the workers are competent to make those decisions. Recyclers that internally test electronics for reuse should have experienced IT people in those roles. It is not acceptable to assign a general laborer for testing or data validation. Before assigning technicians to perform technical activities, the recycler must ensure the competency of the technician.
- Control of Supply. Buying or accepting electronics that can be tested and refurbished is a key element of quality control. This means communicating product specification to customers/suppliers prior to purchasing products. If a recycler sources mixed electronics it is important to train warehouse workers to identify and sort out reusable products based on established product specifications.
- Verification of Testing Equipment. Testing equipment used in the testing process needs to be verified or calibrated to ensure the test results are accurate. A recycler could use an outside service or specialized calibration device to verify the test equipment is working properly. Or more simply, a recycler can check the test equipment using a known “good” product and a known “bad” product to verify the results are consistent with the known good and bad products.
- Test Records. Test records should show the pass/fail results for each function that has been tested. Complete test records are essential for proving sales are conforming to the R2 Standard after the products are sold and shipped. The QAP should provide steps to verify the records are complete and accurate. For example, records that only list specifications such as CPU speed or hard drive size, “condition” grade (e.g. A, B, C, etc.), or labeling with R2/Ready of Resale, would not be acceptable test records in conformance with Provision 6. Quality control for test records should look for both pass and fail results. Not every tested function is expected to pass, therefore, failure records also demonstrate an effective test process by identifying failures.
- Final Inspection. The final inspection process is used to verify that test results are accurate and ensure the elctronics are working. The process for final inspections should be defined in the QAP. Final inspections may be necessary on every device that passed testing, or on just a subset of devices, depending on the continued effectiveness of the testing processes.
- Control of Nonconforming Products. Nonconforming products are those that have failed to meet the R2 Provision 6 requirements for reuse, and therefore, cannot be sold for reuse. Acceptable management of nonconforming products may include repair, harvesting components that have been tested and are working, or recycling for materials recovery. Auditors will be looking for evidence that the recycler is legitimately separating working from non-working equipment, and properly managing the nonconforming products
Quality standards such as ISO 9001 and RIOS can provide a good framework for ensuring that products sold meet the R2 requirements of Provision 6, as well as the requirements of the customer. For RIOS or 9001 certification to satisfy the R2 QAP requirements, the scopes of those certificates must include all electronics reuse activities occurring at the facility. If electronics reuse activities are not included in the scope, the quality certifications would not be relevant to the R2 quality requirements in Provision 6. For instance, an ISO 9001 certificate that lists only “plastics recycling” as its scope, wouldn’t be relevant or satisfy the R2 quality requirements for electronics reuse. Also, the address on the RIOS or ISO 9001 certificate must be the same as that of the facility being audited for the R2 Standard.
Bottom Line: The Quality Assurance Plan is a critical part of the R2 reuse requirements and must be rigorous to ensure electronics sold for reuse are indeed working.