Overview and fast, easy to understand answers, focusing on the key rules of R2.
- What is R2?
- Where did R2 come from?
- Is R2 a standard the way ISO 9001, ISO 14001, etc. are standards?
- What are the differences between R2 and, for example, ISO 14001?
- So if I'm ISO 14001 registered, how R2 compliant am I?
- Does R2 view some types of e-scrap as more critical than others?
- If there are laws/regulations covering the e-scrap I handle, what does R2 require me to do?
- What does R2 require me to do with the e-scrap I handle?
- If I implement the top-level strategy and sell used electronic equipment for re-use, what does R2 require me to do?
- What does R2 require for "Focus Materials"?
- What does R2 have to say about the firms I sell e-scrap to?
- What if my customer for FM items is R2 certified?
- Besides Focus Materials, what other types of e-scrap require special attention?
- What other types of requirements does R2 contain?
- And by chance does R2 have some pretty serious record keeping requirements?
- Can we get certified to R2?
- Can Kantner & Company help us implement R2?
R2 (shorthand for "Responsible Recycling") is a collection of "practices" that, taken as a whole, comprise a program to govern management of used / end-of-life electronic equipment (e-scrap, for short) by electronics recyclers. Its rules are listed in a document called "Responsible Recycling (R2) Practices for Use in Accredited Certification Programs for Electronics Recyclers."
According to the web site of R2 Solutions, the sponsor of R2, the Standard was developed via "a multi-stakeholder" process convened by the U. S. Environmental Protection Agency. Participants, says R2, included state regulators, electronics recyclers and refurbishers, trade associations, OEMs/customers, and non-governmental organizations (NGOs).
Contrary to popular belief, however, the EPA does not "own" R2. "Although the EPA facilitated the development of these standards, Thea McManus, associate director of the Resource Conservation and Sustainability division of the EPA, says the agency does not own the standard. 'As a federal agency, the EPA cannot endorse any particular standard,' she adds, 'but we are encouraged by recyclers' desire to get certified to any particular standard.'" ("Certification Maze," Recycling Today, April 20, 2010)
No. R2, which calls itself a set of "practices," does not have the degree of international sponsorship and oversight as do ISO 9001, ISO 14001, or OHSAS 18001.
Too many to list here. Briefly: both stress the Plan-Do-Check-Act (PDCA) model; both are about environmental protection; both have strong legal/regulatory emphasis, and both are used in accredited certification programs.
In one respect ISO 14001 is broader in scope than R2, since it sets as its starting point all environmental aspects/impacts, where R2 limits itself to e-scrap (and, particularly, the subset known as "Focus Materials," about which more later). ISO 14001 is far less prescriptive, and significantly narrower than R2, since R2 addresses (besides environmental protection) health/safety and security.
With R2, moreover, you are seen as part of a "recycling chain" and there are requirements for how you deal with other members downstream from you ("Downstream Vendors," to use R2's term).
You've got a good start, but R2 is a steep stretch beyond ISO 14001.
R2 applies to all e-scrap. But it requires special measures for to what it calls "Focus Materials" (FM for short). FM are items that contain:
- CRTs/CRT glass
- Whole / shredded circuit boards (except those lacking lead, mercury, batteries)
- identify laws and regulations relevant to your dealing in e-scrap (national, local, international)
- Devise ways to comply with the laws (and build these into your controls)
- Comply with laws / regulations
- Regularly evaluate your compliance level and
- Take corrective action as needed.
If you (or a downstream vendor - see below) export e-scrap containing FM, you must confirm and document that it is legal for the importing country to receive the FM. And if you (or a Downstream Vendor in your recycling chain; more on that later) are exporting CRT glass, there is an EPA regulation to comply with.
You must have a written plan spelling out your system for managing e-scrap from start to finish (including, as relevant, downstream vendors; see below). In the plan, you must apply the following hierarchy of strategies when determining how you will deal with the items:
- Materials recovery (i.e. recycling)
- Energy recovery (i.e. incineration)
- Disposal (landfill)
You must show that you are able and qualified to process the items in a way that protects safety and environment. This means you must implement a written environmental / health-safety management program.
Your environmental / safety program must include:
- Identification of hazards and risks
- Implementation of effective controls consistent with the OSHA hierarchy (engineering controls,
- Administrative/work practice controls, personal protective equipment)
- Identification of potential emergency situations and effective preparation measures
If I implement the top-level strategy and sell used electronic equipment for re-use, what does R2 require me to do?
For all electronic equipment slated for re-use, you must have measures in place to preserve and protect it.
If the re-use electronic equipment contains FM, you must have procedures in place to confirm that its key functions work properly. This rule is waived if your customer is R2 certified, or is reselling for reuse and managing FM as required by R2. (Certain other exceptions apply.)
First you must have a written Focus Materials Management Plan addressing how these items are dealt with on site and downstream through the Recycling Chain. Whatever else happens with the FM, your plan must assure the safe and effective removal and management.
The most-favored preferred outcome is re-use (see above). But burning or landfilling, the third and fourth options of the hiearchy, are not permitted for FM. That means, for items you are not selling for re-use, your plan must assure that FM are controlled and managed until they complete the materials recovery / recycling process.
For FM items, R2 specifies specific materials recovery / recycling outcomes for these FM items:
- Mercury: retorting.
- Circuit boards: a) Removal of batteries and mercury, then b) smelting for metals recovery.
- PCBs: destruction by means of TSCA licensed methods.
As stated above, your FM Management Plan must ensure that the FM passing through your site are, ultimately,
- Sold for re-use (see rules on this above), or
- Processed for material recovery in a manner that is safe, environmentally responsible, and
- Compliant with all applicable laws and regulations.
If your firm performs the actual material recovery on the FM (making your firm the "Materials Recovery Point"), in effect transforming the FM to non-FM status, you have no downstream due diligence obligations under R2.
But odds are, you do not complete the materials recovery / recycling process for the FM at your site. If you're like most recyclers, you receive the FM items, aggregate, dismantle, sort, and/or repackage them, then sell them to others. In this case, your FM management plan must address and manage how your downstream vendors (and, as applicable, their downstream vendors – "the recycling chain") manage the FM in accordance with R2 rules, all the way to the Materials Recovery Point.
The more links in the Recycling Chain through which your FM items flow between your firm and the Materials Recovery Point, the more burdensome your downstream vendor due diligence task may be. It all depends on
- The number of sites entities in the Recycling Chain through which your FM flow before reaching the Materials Recovery Point; and
- Whether or not the FM leave the United States.
To meet R2 downstream due diligence requirements, you must ensure that the customer you sell FM to:
- Complies with your FM management plan
- Has a documented EHSMS
- Has all required environmental permits
- Is in a country where it is legal for them to receive the FM.
This is burdensome enough of your customer is the Recovery Point (where the Recycling Chain ends). If your customer is (like you) an intermediary, then your obligation for due diligence extends to successive links in the Recycling Chain all the way to the Recovery Point. This means you must require your customer to do the same due diligence on their customers also–for each link in the Recycling Chain through which the FM passes, all the way to the Recovery Point. You must verify, by some reasonable means, that this has been done.
Moreover, if you, or a member of your FM Recycling Chain, export FM items, you must obtain proof that the country/countries to whom the FM items are being exported legally accepts such items (see above).
If the customer is not in an Organisation for Economic Co-operation and Development (OECD) member country, they must furnish documentary evidence that it is legal, in the country they are domiciled in, for them to import the FM.
It gets messier when exporting CRT glass; the EPA has a regulation governing how to do that.
Selling FM items to an R2 certified recycler does not exempt you from meeting R2 downstream due diligence requirements. The advantage of selling to an R2 certified company is that they are fluent in the downstream due diligence requirements and, at least one hopes, have all the required evidence in hand.
Data storage devices (such as hard drives) must be affirmatively cleaned of all data to prevent data-mining. (Punching a hole is not sufficient. Shredding works though.) If you elect to degauss, the data destruction procedures must meet the requirement of a guideline from National Institute of Standards and Technology (NIST). If you're doing the data destruction yourself, you must implement effective training for the people doing the work. And from time to time your process must be independently validated for effectiveness.
Toner and toner cartridges must be recycled through a qualified recycler (or OEM) "unless it is not economically feasible."
- Adequately identify/label items and materials,
- Store them in a manner that mitigates environmental and health/safety hazards; and
- By means of an adequate security program, prevents unauthorized access.
Your transportation vendors must prove that they have appropriate legal authorization and credentials to handle the materials you ship. They must also prove they have been free of significant violations for the past 3 years.
R2 requires you to have insurance that adequately covers accidents, bodily injury, emergencies, pollutant releases, and property damage.
You must have a written plan assuring proper closure and prevention of abandonment of any recycling components, materials, or products, supported by a "sufficient financial instrument."
You must maintain complete transactional records including bills of lading, contracts, etc. for purchase, sales, and/or brokerage of all equipment/material you handle, for a minimum of three years.
Certainly. Five registration bodies are accredited by the American National Accreditation Board (ANAB) to audit and certify companies to R2. Part of our service is to walk you through the process of selecting the registration body best suited to you. (They are far from equal.)
Can Kantner & Company help us implement R2? So we don't have to figure all this out ourselves, and get it done fast?
As with all the other standards in these pages, we provide R2 advice, guidance, implementation, documentation, and training services. Call 989-289-6005 for details, or complete the Quote Request form.