SERI occasionally receives calls or emails from recyclers who are in the midst of an audit. They are reaching out to SERI because they’re concerned about a potential non-conformance and are seeking a clarification or decision regarding the issue. It’s important for recyclers to note that while SERI can provide clarification on R2 requirements, SERI cannot arbitrate issues between the recycler and the auditor. Recyclers should also keep in mind that not every concern expressed by the auditor during the audit rises to the level of a nonconformance.
No person or facility is perfect – minor nonconformances are a normal and expected part of the audit process. Resolving and learning from occasional non-conformances is part of continuous improvement. When an auditor finds numerous minor nonconformances, however, it becomes a matter of concern. Even more concerning are major nonconformances. Major nonconformances are issued when a facility has significant gaps in their fulfilment of R2 requirements. This may mean some R2 requirements are not addressed at all, or that the facility may be ineffective in meeting certain requirements, or that the facility is consistently or systemically not conforming to the R2 Standard.
If you disagree with a finding made by your auditor, the following steps should serve as your guide to resolve the disagreement.
- Discuss the concern with your auditor during the audit.
- If a finding of nonconformance is made by the auditor, consider the validity of the nonconformance, remembering that no facility is perfect. Do a thorough root cause analysis to get to the real reason for the nonconformance. Consider this an opportunity to fix a legitimate issue.
- If after root cause analysis and getting the input of others on your team, you still feel that your objective evidence demonstrates conformance, use the appeals process of your Certification Body (CB). Reach out directly to your CB’s R2 program manager to file your disagreement about the finding.
- The CB will consider all the information and decide whether to uphold the nonconformance, amend it, or dismiss it. Should the CB need more information, they may contact SERI for assistance in understanding the requirement.
- SERI will not decide whether your non-conformance is legitimate. It is the responsibility of the CB to evaluate your objective evidence and determine whether it demonstrates conformance to the R2 Standard requirements. SERI will, however, provide clarification on the requirements as requested.
It is the responsibility of a certified organization to provide evidence that they are consistently conforming to each part of the standard. This is more than just an explanation or a written process, or even a single record – it is evidence that demonstrates how an organization operates over time. If a facility does not have strong evidence to demonstrate consistent conformance to R2 requirements, an auditor has no choice but to issue a finding of nonconformance. Objective evidence is always required – it is a key differentiator between a non-certified company and an R2 Certified company.
Bottom Line: Auditors will be pressing harder for objective evidence of consistent conformance. This is one of the desired outcomes of SERI’s enhanced auditor training. That said, everyone is fallible – including recyclers, auditors, certifying bodies and SERI. Recyclers have the right to disagree with an audit finding, but they also have the responsibility to follow the Certification Body’s appeals process. SERI has the responsibility to provide clarification on requirements when needed, while maintaining the integrity of a true third-party audit system. Everyone doing their part will continue to strengthen the R2 program – which benefits us all.