Spot Audits: Protecting the integrity of R2 Standard and R2 Certified Companies
Spot Audits are one of the components of SERI's comprehensive Quality Program. Spot audits will be conducted randomly to ensure conformance between audits, and in some instances in response to a complaint or concern. When complaints are received, SERI will work closely with the Certification Body (CB). The CB will be asked to conduct the initial investigation, and if warranted, suspend or even revoke the Certificate of the company in question. SERI may choose to participate in the initial investigation audit or conduct a follow up spot audit, depending on the circumstances of each case. The spot audits will be conducted on very short - or no - notice in order to gain a truer picture of the company's "business as usual" operations.
In addition to using spot audits as a means to investigate complaints, SERI will be expanding its spot audits to include random visits to R2 certified facilities. This will help identify areas where additional training may be needed, and also identify recyclers/refurbishers who may be taking shortcuts between regularly scheduled audits. The ultimate goal of spot audits is to remove bad actors from the R2 certification program, protect the integrity of the program, and protect the reputation of R2 certified companies who work hard to conform to the R2 Standard's requirements.
The Spot Audit Process: On-site vs. Off-site Reviews
In the March issue of the R2 Update, spot audits were introduced as part of SERI's continuing quality control program. Described in the article was the process for on-site spot audits - an audit conducted by SERI (or a SERI representative), with little or no advance notice given. Another spot-audit option is an off-site review of a company's management system and documentation.
In the case of an off-site spot audit, the company under review will be asked to submit some or all of their R2 management system documentation directly to the assessor assigned by SERI. Because R2:2013 requires this information to be readily accessible, companies should be able to submit the requested documentation to the assessor within a short window of time. Some of the documentation that SERI may request includes but is not limited to:
- R2 manual
- EH&S certificates
- List of legal requirements
- Last compliance audit
- List of any exports
- FM management plan
- Downstream vendor list to final processor
- Due diligence checklist/report for Tier 1 downstream vendors
- Testing procedures and work instructions
- List of all shipments in/out within a designated period
- Data destruction procedures/work instructions
- Closure plan
- Copy of financial instrument for closure
- Certificate of Insurance
If the assessor determines the offsite review indicates insufficiencies, an on-site visit may be scheduled. The findings of the spot audit will be shared with the certifying body, and as warranted, SERI will make recommendations for further actions regarding the certification status of the company in question.