A publication of SERI

570+ R2 certified f
acilities in 21 countries

February 2016
USEPA's Implementation Study and R2
The United States Environmental Protections Agency (USEPA), through its Office of Resource Conservation and Recovery, recently released its Implementation Study of the Electronics Recycling Standards: R2 and e-Stewards.  This comprehensive and well-received study was three years in the making.  The study can be found on the EPA website .

The study states that “the Standards have brought better order; better management; and increased awareness of the environmental, health, and safety (EHS) risks associated with electronics recycling; and an improved awareness of regulatory requirements and best practices to the electronics recycling industry.”

The study is based on 39 interviews of key stakeholders and 9 “audit observations”.  It sets forth recommendations on aspects of the implementation of the certification programs that USEPA found could be improved.   The top recommendations of the study (with SERI comments on each) are:

1.  Provide additional training and guidance materials to grow the knowledge base. 
SERI absolutely agrees that additional training and guidance materials are needed for recyclers and auditors.  To that end, SERI has developed a number of documents for both audiences, including the R2 Guidance document and Implementation Guide Modules that include detailed discussion, examples, and other tools for recyclers working to better understand the R2 Standard.  Additional implementation modules will be published on the SERI website as they are completed.   Additionally, SERI provides two webinars on a regular basis – an introductory and an advanced webinar on the requirements of the standard.  SERI also is working with the R2 auditors through webinars on some of the more difficult provisions of the standard to audit.  

More important, SERI is developing a far more rigorous and comprehensive training program for auditors.  This will require additional time and financial resources for SERI, auditors, and the certification bodies.  However, SERI has found through its review of auditor packages (the documentation an auditor submits to its certification body) that there is need for improvement with regard to many auditors’ knowledge and/or implementation of some of the more complex requirements of the standard.

2.  Provide regular updates to the Standards to ensure they continue to evolve alongside this rapidly changing industry.
SERI’s standard development process is accredited by the American National Standards Institute (ANSI).   Consequently, SERI adheres to ANSI’s requirements concerning the frequency of updates to the R2 Standard.  ANSI’s general requirement is that a standard be revised every five years.  However, it recognizes that in some instances a revision to a section of a standard may be warranted sooner and it makes provisions for this.

USEPA’s recommendation regarding regular updates goes on to suggest that “[s]cheduled and publicized plans to update the Standards will allow stakeholders to  fully contribute and participate in the continual improvement in a fair and transparent manner (emphasis added).  Once again, ANSI requirements control SERI’s process and procedures.   In accordance with ANSI’s requirements, SERI’s standard revisions process meets USEPA’s recommendations.

3.  Increase audit time to allow for more thorough auditing of the Standards.  
This is a challenging recommendation.  During the development of the R2 Standard between 2006 and 2008, in which USEPA played a central and active role, the agency was adamant that small businesses not be priced out of the program (increased auditing time can impose significant additional cost).  On the other hand, there certainly are larger facilities, with multiple demanufacturing and refurbishing processes, downstream material flows, and other variables that auditors need considerable time to effectively audit. 

SERI believes the answer is not to increase auditing times across the board but rather to better tailor auditing time requirements to the type of facility being audited.  SERI is revising the R2 Code of Practices, which sets forth the formula for determining auditing times.  Auditing times is one of the main areas targeted for revision.

4.  Explore and address perceived conflict of interest issues to enhance overall rigorousness of the audits.
The issue here is that the certification bodies are for-profit companies, and the entities they certify are their clients.  Customer retention is presumably a consideration for certification bodies and can pose a conflict of interest when it comes to objectively and rigorously auditing and certifying these clients.  At the same time, however, each certification body has a strong interest in maintaining the integrity of the certification program, so the incentives are not all pointing in the wrong direction.

SERI has, and continues to, consider bringing some or all of the R2 auditing activities “in house”.  This would not be a simple matter and wouldn’t necessarily address the issue effectively as SERI also has a financial interest in maintaining the number of certified entities.  SERI will be working with its certification bodies to create an incentive structure for all parties that furthers the goals of R2 and continually promotes the quality and integrity of the program.

The EPA’s report affirms the findings of our own 2015 quality review, as well as the steps that SERI’s taking to strengthen all aspects of the certification process” says John Lingelbach, SERI’s executive director.  “In the past few years, there has been significant improvement in the electronics recycling industry as a result of certification standards.”  
The Competency of Internal Auditors
Internal audits are an important aspect of certification and are required by several provisions of the R2 Standard.  Provision 1.c requires an internal audit of a facility’s conformance to each of R2’s requirements.  Provision 3.a.3 requires facilities to periodically audit their compliance to all applicable laws and regulations. 

In order for internal audits to be effective, they must be conducted by someone with the right competencies. The auditor must have the knowledge and experience necessary to understand the R2 Standard’s requirements, and to evaluate whether the company is meeting those requirements.  An administrative person without such knowledge and experience cannot do the audit.  

Facilities may find it necessary to have multiple internal auditors – each with their own area of competency.   For example, an internal auditor with competency to audit to R2’s requirements may not have the competency to audit the health & safety requirements of RIOS or OHSAS 18001.  Likewise, an R2 or EH&S auditor may not have the knowledge to effectively audit data security requirements.

An effective internal audit can help avoid non-conformances with requirements of the R2 Standard that may result in suspension or revocation of your certification(s).  Utilizing a competent internal auditor also can minimize the risk of violations and monetary penalties from regulatory authorities.  

Competency of the auditor can be achieved through training, hands on experience, and ongoing education.  SERI recommends that R2 internal auditors take SERI’s Advanced R2 training webinar and exam. This is a detailed, 5-hour review of all R2 requirements.  SERI also recommends that an internal auditor complete a training course on the fundamentals of auditing.  

The knowledge base for an internal EH&S compliance auditor is different than that of an internal R2 auditor.  An EH&S auditor is expected to be knowledgeable in areas such as storm water management regulations, air quality, respiratory protection, noise, powered industrial trucks, etc.  In the United States, formal OSHA training can provide a good start for compliance auditors.   Internal EH&S compliance auditors will also benefit from a basic course on the fundamentals of auditing. 

The required competency for an internal auditor will vary from organization to organization, depending on the complexity of the organization’s scope and legal requirements.  When determining who will be conducting internal audits, it is helpful to create a matrix of the requirements, including various regulations applicable to the organization, and determine who has the qualifications to audit each area.  It may be that a single person within your organization is qualified to audit all areas, or it may be that multiple auditors (either internal or external) with different areas of expertise are needed.   

The bottom line:  you must be able to demonstrate to your Certifying Body auditor that your internal auditor(s) understands how the requirements of R2 and EH&S Standard(s) apply to your specific operation, and is able to identify any non-conformances that may exist.  
R2 TAC meets in Dallas
During 2011-2012, the R2 Technical Advisory Committee developed revisions to the R2 Standard, culminating with R2:2013.  After this tremendous effort and high quality outcome, the committee’s work was completed and it was disbanded.  Thanks once again to all those who participated.

In early summer, 2015, SERI’s Board of Directors convened a new R2 TAC.  This multi-stakeholder group was charged with assisting the R2 Consensus Body to identify and work on areas of the standard where improvements can be made.  (The R2 Consensus Body is a subset of the TAC, designed to provide an additional layer of assurance that the R2 Standard is revised through an open, balanced, consensus-based process.  It is a requirement of the American National Standards Institute (ANSI), which has accredited SERI’s current R2 Standard development/revision process.) 

Over this past summer and fall, the R2 TAC has been working on a handful of pressing issues with an eye to improving the next revision of the standard or potentially recommending to the SERI Board that some interim actions be taken.  These issues include matters relating to: CRT management; closure plans and associated financial assurance instruments; and the testing and management of mercury-containing devises.

Earlier this month, the R2 TAC, along with a few members of the public (all R2 TAC meetings are open to the public), met in Dallas to begin the arduous task of going through R2:2013 and identifying potential areas for change.  This is just the first step in the identification process.  There will also be an opportunity for the public to provide input, followed by further discussions about the importance of each potential area of proposed change.

R2 TAC members flew into Dallas from all parts of the country and from Europe (though a member from Asia was not able to make it).  Much work was accomplished during the day and a half meeting in Dallas.   SERI will keep readers of the R2 Update apprised of the R2 TAC’s work, and the opportunities for public comment, as the process for revising the R2 Standard progresses.
Introducing R2 to Japan

Earlier this month SERI’s executive director, John Lingelbach, visited with electronics recyclers in Japan.  Lingelbach spoke at a seminar held at the US Embassy and put on by Perry Johnson Registrars.  About seventy-five electronics refurbishers and recyclers attended, as well as representatives from the Ministry of the Environment and other government agencies.  The seminar provided an excellent forum for introducing R2 to Japan.  SERI hopes CBs will conduct similar events in other potential new markets around the world.

Lingelbach also met with representatives of the Refurbished & Recycled Information Technology Equipment Association (RITEA) http://www.ritea.or.jp/.  RITEA provides information to electronics recyclers and the public about how to responsibly refurbish and recycle electronics in accordance with Japan’s extensive set of applicable laws and regulations.  RITEA also administers certifications covering electronics refurbishers and their products.  These certifications focus on Japanese law and data erasure.  (For a slide deck describing RITEA and its work, contact patty@sustainableelectronics.org.

R2 Training Opportunities

An overview of the R2 Standard requirements and the steps and cost of certification.  No cost to attend.

Wed. March 9,  10am-11:30am CST 

Wed. March 23, 10am-11:30am CST

Wed. April 6,  10am-11:30am CST


This interactive 5-hour training covers the requirements of the R2 Standard in detail.
Cost to attend:  $300 

Tue. March 8,  10am-3:00pm CST 

Tue. April 12,  10am-3:00pm CST

The R2 Update  newsletter is a publication of SERI, a non-profit organization 
that works to create a world where electronic products are reused and recycled in a way that promotes resource preservation; the well-being of the natural environment; and the health and safety of workers and communities.  To learn more visit: