One of the most important requirements of the R2 Standard is Provision 5e which calls for due diligence of downstream recyclers. R2 Certification not only relies on an annual audit by the Certification Body, but also on the monitoring performed by recyclers on their own recycling chain. Working with bad actors can seriously undermine your credibility. A downstream vendor (DSV) may provide all the right answers on paper, and even put on a good show during an in-person visit, but their everyday operations may not always be consistent with the image they portray. One important aspect of due diligence and auditing is determining whether the evidence sampled represents the normal, everyday processing of the DSV.
During spots audits, SERI has observed instances of recyclers that have suffered the consequences of working with DSVs who employ such “smoke and mirror” tactics. A few red flags to watch for –
- The DSV has a written process, but little or no evidence of execution of that process. For instance, the recycler might provide a table of contents to their EH&S Manual, but when you ask for the record of their last facility inspection, they have none or it is five years old. Look for ways to verify the information that is being provided to you. For example, you could ask who was the last person hired, and then ask to see their training records to confirm they are up to date.
- A generic process with cookie-cutter documentation that merely restates R2 requirements. Such a document is meaningless without verification that the process has been fully implemented and followed in everyday operations. Generic documentation can be purchased cheaply on the internet allowing recyclers to simply fill in the blanks with their own name. While this might meet the basic requirements for written documents in an EH&S management system, generic systems are often indicative of a management system that is not fully implemented.
During a recent SERI spot audit, a cell phone refurbisher presented a data destruction procedure for how to wipe hard drives – not cell phones. It was obvious this process was purchased in an attempt to meet Provision 8.b, but unfortunately it had no application to the mobile phones that the refurbisher processed.
- Outputs don’t line-up with the inputs by quantity or type. The outputs of a process should be consistent in volume to the inputs. For instance, if the recycler is dismantling LCD monitors, then the amount of mercury lamps sent to a downstream vendor should be consistent with the number of LCD monitors received by the recycler. A high-level comparison can quickly evaluate whether there is consistency without calculating exact quantities. If thousands of LCDs are received each month, yet only one drum of lamps was recycled in that year, then it is obvious that most LCDs are not being dismantled but likely diverted. Where are the LCDs going?
While audits have been a useful tool for improved accountability, they are still just a snapshot in time. It is important for both recyclers conducting due diligence and certification body auditors to verify beyond the written process that the recycler is doing what they say they are doing, and doing it for 100% of their operations. Ongoing conformance relies on recyclers holding each other accountable through their due diligence. The R2 Standard does not dictate who recyclers must partner with. It is the recycler’s choice, as long as the partner meets the R2 requirements for downstream vendors. Unlike ISO 14001 or OHSAS 18001, R2 requires more than a paper system or once a year audits. It requires continuous performance and accountability by all vendors in the recycling chain.
Bottom Line: R2 Certified recyclers have made the investment in time, money, and resources to demonstrate their credibility and commitment to industry best practices. Poor performing partners not only put their own credibility and R2 Certification in jeopardy, but also that of the R2 Certified recyclers who do business with them, and by association, the entire R2 Certified community. Don’t put your investment and R2 Certification at risk by giving others a free pass.