Preparing Your Company for R2v3 Certification: Essential Policies and Procedures
The circular economy for used electronic recycling is ever expanding. Playing a huge role in building a sustainable used electronic recycling chain has been the development of the R2v3 Standard by Sustainable Electronic Recycling International (SERI).
As the used electronic recycling industry continues to develop, ensuring that organizations that manage e-waste are adhering to responsible practices is critical. This is primary due to the hazard and toxic materials contained in these used electronic devices and components. The R2v3 standard is centered around the management of these hazard component and has defined these materials as Focus Materials. Focus materials include: circuit boards, batteries, cathode ray tubes (CRT TVs), Mercury, and Polychlorinated Biphenyls. These items per the R2v3 standard must be controlled and responsibly managed according to the requirements of the R2 standards.
Controlling and managing these focus materials per the R2v3 standard requires that an organization that is R2v3 certified must track all inbound or received shipments. Additionally, used devices containing data are required to be managed responsibly through sound facility security practices as well as the data be effectively wiped or sanitized using automated software (logical sanitization) or physically destroyed. Inventory tracking is critical as well as the status of each device throughout the process. Materials received by the organization need to be managed with the Hierarchy of Responsible Management Practices: Reuse, Recycling, Material Recovery. Lastly, outbound shipments either electronics for reuse/resale or recycling must be tracked and records be retained.
What is needed to get certified to the R2v3 standard? Achieving R2v3 certification will require careful planning and commitment to developing required documentation and implementing R2v3 practices. The documentation requirements are significant and require some time to put in place. The process generally requires about 2-3 months for organization that have less than 20 employees, but time frames do vary.
In this blog post, we will explore the essential documentation requirements that candidate facility need to develop when preparing for their R2v3 audits.
1. Establish Management System
A management system is simply documentation that outline the company’s organization, structure and their processes (activities) and how they interaction. Development of this management system represent putting into place documentation such as policies, procedures that describe the organization's structure and processes for carry out their business model.
Examples of common Management System documentation that will need to be develop include:
· Management System Manual
· Master Document List
· Organizational Chart and Job Descriptions that demonstrate the Roles and Responsibilities of the organization personal
· Training Program that cover R2 data sanitation, data security and quality, environmental and health and safety requirements that are applicable to the organization.
· Standard Operating Procedures to ensure consistency in carrying out operational processes and activities
· Compliance Plan that list the pertinent Legal Requirements
· Methods and procedures to ensure adequate monitoring, measurement, and continue improvements such as internal audit, compliance evaluations, facility inspections, organization objectives or goals and continue improvement methods such as a corrective action process.
Establishing a solid and robust management system is fundament to R2v3 certification and this takes a thoughtful approach, some solid planning and understanding of the R2v3 requirements.
2. Legal Compliance
One of main elements of your management system, as mentioned above, includes the development of a legal compliance plan. This requires the organization to do some research on the legal requirements that pertain to the organization based on its business model, activities, and materials (Focus Materials) it handles.
The plan needs to include federal, state, and local governmental regulations. Additionally, the organization needs to consider data security requirements and regulations, as well as import/export requirements if shipping materials internationally. A summary of these potentially applicable requirements may include:
· Occupational Health and Safety (OHSA) requirements
o Emergency Action Plans
o Fire Prevention Plans
o Hazard Communication Programs
o Medical Services
o PPE Requirements
· Environmental Protection Agency requirements
o Permits - air and water
o Business Registration with state as a recycler
o RCRA or other applicable EPA requirements
· Data Security / Sanitization – NIST 800-88 8Requirements, Privacy Acts
· Transportation Requirements – for lithium batteries for example
· Universal Waste Requirements
· Any other customer or business legal requirements – business entity registration, commercial zoning, required insurance, closure plan
3. Data Security
One of the main focuses of the R2v3 standard is around the handling and management of used electronic devices that may contain or is known to contain data. Facility security is a critical element in protecting data breaches. Security CCTV camera systems and secured entry to the facility are key elements for ensuring data security. With regards to data management a data sanitization plan is required by R2v3 requirements. The plan will list the data containing devices and media types that requires sanitization either logically with automated software (PhoneCheck, Blannco for example) or through physical destruction methods (shredding). Policies and procedures must be developed to ensure secure handling, storage, status, and disposal of data-containing devices.
4. Documentation and Record-Keeping Management
A keep part of the management system is managing all of the required documentation and records so that their integrity is maintained. Documents: polices, procedures, forms, and work instructions must be maintained and controlled effectively. Records must be adequate maintained for review during your certification audits. Three months of operational records is typically standard prior to your certification for review by the third-party auditors. A sample of records that must be retained include: training records, audit records, records of corrective action and customer feedback (complaints), calibration and maintenance records, inspections, and accident and incident records.
Common R2v3 Management System Record Requirements (if applicable):
· Sales Orders and Customer Purchasing Orders
· Customer Complaints
· Customer Specification/Requirements
· Customer Satisfaction and Surveys
· Supplier Evaluation and Status Records
· Internal audit Records
· Corrective Action Records
· Training Records
· Obsolete Records
· Facility Inspections
· Calibration Records
· Maintenance records
· Accident and incident records.
· Management Review Meeting Records
· Inventory Records
· Data Sanitization Records
· Testing/Auditing Device Records
· Inbound (receiving) shipment Records
· Outbound Transactions – sales, shipping records (Bills of Lading)
· Downstream Vendor Records
While this list is not exhaustive it demonstrates the careful planning and implementation of these management system documents in preparing your organization for R2v3 certification.
By focusing on these critical elements, you can streamline your certification process and gain the benefits of being a used electronic recycler that ensure that quality, environmental, health and safety, and data security practices are the best practices for managing e-waste.
Wilkshire Blog Posts
R2v3 Requirement Basics – R2v3 Core Requirements: Basics you need to know (wilkshireconsulting.com)
R2v3 Scope Determination – How to Determine your R2v3 Scope of Certification (wilkshireconsulting.com)
R2v3 Focus Material – R2v3 Reuse and Recycling Focus Material: A Closer Look (wilkshireconsulting.com)
Electronic Recyclers - What is R2v3 Certification and what are the benefits? – Electronic Recyclers - What is R2v3 certification and what are the benefits? (wilkshireconsulting.com)
R2v3 - The Sustainable R2v3 Overview of the Certification Process – R2v3 - The Sustainable Electronics Reuse & Recycling (R2) Standard V3 Overview of the Cert. project (wilkshireconsulting.com)
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