Complaints can be a valuable tool and source of information in the continuous effort to improve quality and conformance of R2 Certified facilities, auditors and Certification Bodies throughout the year. Certification Bodies (CBs) are prepared to handle complaints about their R2 Certified clients. Because R2 Certification is based on independent, third-party audits, CBs have the direct responsibility to investigate complaints about R2 facilities and the single authority to issue nonconformities, suspensions, and revocations based on the evidence found.
Sometimes complaints are made directly to SERI from whistleblowers within an R2 Certified organization, anonymous sources, other recyclers, concerned citizens, or they may sometimes stem from a media report. These complaints are reviewed by SERI to ascertain their credibility. SERI recognizes that some complaints may be unfounded, and typically seeks to verify complaints before initiating further investigations by the CB. Sometimes complaints are unverifiable, meaning no specific information is provided or can be obtained to start an audit trail to follow. In these cases, the information is usually forwarded to the Certification Body to be included for consideration by the auditor at the next scheduled audit.
In many cases, the most recent audit report is obtained from the Certification Body and reviewed by SERI’s team to verify that a good audit was completed and supported by evidence of conformance. Sometimes SERI may perform its own unannounced spot audit to gather additional information necessary to determine the credibility of a complaint. When SERI finds credible concerns, SERI will file a complaint with the Certification Body (CB) or the Accreditation Body (AB) that oversees the CB, regarding the specific concern. This process is outlined in Advisory 15.
It is important to recognize that complaints may necessitate another CB audit, sometimes unannounced. Audits are intended to gather records to demonstrate conformance. Records of conformance are a key difference between R2 Certified facilities and their non-certified competitors. The ability to prove a facility is meeting the high bar set by the R2 Standard is what establishes the credibility of the R2 Certificate. In cases where facilities are not able to produce the records or documentation necessary to show conformance to the Standard, the CB would issue a non-conformance and could also suspend or revoke the R2 Certificate.
R2 Certified facilities, CBs, auditors, and Accreditation Bodies all have a role to play in maintaining the strength and integrity of the R2 Certification program. SERI will continue to oversee the R2 Certification program and ensure each party is fulfilling their defined responsibilities.