Use this as a practical, printable playbook. It translates R2v3 into day‑to‑day actions, owners, and evidence to show an auditor. Always defer to the official R2 Standard, the R2 Equipment Categorization (REC), the Code of Practices (COP), and SERI guidance when in doubt.
Quick‑Start & Table of Contents
How to use this guide
- Confirm your Scope and which Appendices apply. 2) Assign Owners. 3) Print the checklists for only the clauses that apply. 4) Build your Evidence Binder using the clause‑to‑evidence map. 5) Run the Self‑Assessment Scorecard and close gaps. 6) Rehearse with the Auditor Interview Playbook. 7) Keep it current monthly.
Table of contents
- Quick Orientation
- Roles & RACI (with matrix template)
- Evidence Binder (with clause‑to‑evidence map)
- Core Requirements CR‑1…CR‑10 (plain‑English + checklists)
- Appendix Applicability Matrix + Decision Tree
- Process Requirements A–G (plain‑English + checklists)
- Practical Tools (90‑day plan, floor tour, records map, common NCs)
- Self‑Assessment & Readiness Scorecard
- Printables: Daily/Weekly/Monthly/Quarterly/Annual checks
- Templates & Posters
Quick Orientation: How R2v3 is Organized
- Core Requirements (CR 1–10) — apply to every certified facility.
- Process Requirements (Appendices A–G) — apply only if you perform those operations (e.g., Data Sanitization, Test & Repair, Brokering, PV Modules).
Manager’s first job: publish a clear Scope (CR‑1), determine which Appendices apply, then build procedures, training, records, and metrics around both.
Roles & RACI (suggested)
- Top Management (TM): policy, resources, objectives, management review.
- EHS Manager (EHS): risk assessment, legal register, training, emergency response, inspections.
- Operations Lead (OPS): sorting, categorization, processing controls, throughput, facility controls.
- Data Security Lead (DSL): data policy, Appendix B controls, incident response, access/security.
- Quality/Testing Lead (QTL): REC categories, diagnostics, Appendix C, outgoing conformity.
- Downstream Chain Lead (DSV): Appendix A due diligence, contracts, monitoring.
- Logistics Lead (LOG): transport compliance, chain of custody, packaging, carrier vetting.
- PV Modules Lead (PVL): if applicable, Appendix G hazards, testing, routing, downstreams.
Tip: Assign each clause/appendix an Owner, Backup, and a Monthly “evidence refresh” reminder.
RACI Matrix (fill‑in template)
| Clause/Process | TM | EHS | OPS | DSL | QTL | DSV | LOG | PVL |
|---|---|---|---|---|---|---|---|---|
| CR‑1 Scope | R | C | C | |||||
| CR‑2 Hierarchy | A | C | R | C | ||||
| CR‑3 EHSMS | C | R | C | |||||
| CR‑4 Legal | A | R | C | C | C | |||
| CR‑5 Throughput | C | R | R | C | ||||
| CR‑6 Sorting/REC | C | R | R | |||||
| CR‑7 Data Security | R | |||||||
| CR‑8 Focus Materials | R | R | C | |||||
| CR‑9 Facility | R | R | ||||||
| CR‑10 Transport | C | R | ||||||
| A Downstreams | R | C | ||||||
| B Data Sanitization | R | |||||||
| C Test & Repair | R | |||||||
| D Specialty Reuse | C | R | ||||||
| E Materials Recovery | R | R | C | |||||
| F Brokering | R | C | ||||||
| G PV Modules | R | C | C | R |
Legend: R Responsible, A Accountable, C Consulted, I Informed.
Evidence Binder (what auditors love to see)
Keep a digital index with links to: policies, procedures/SOPs, training, competency records, forms/checklists, logs, sample contracts/BLs/manifests, calibration and maintenance, internal audit & CAPA, management review, legal register, permits/consents, emergency drills, vendor qualifications, material balance, REC mappings, incident logs, corrective actions.
Clause‑to‑Evidence Map (print this)
| Clause | Must‑have Evidence (examples) |
|---|---|
| CR‑1 Scope | Public scope statement; certificate/annex; process map; list of controlled external locations; change log |
| CR‑2 Hierarchy | Hierarchy policy; routing SOP; blocked/recalled list; sampled routing decisions with evidence |
| CR‑3 EHSMS | ISO/RIOS certificate; risk register; training matrix; emergency drill logs; internal audit & CAPA; management review minutes |
| CR‑4 Legal | Legal register; permits/licences; import/export dossiers; compliance audits |
| CR‑5 Throughput | Inbound/outbound logs; REC categories; mass‑balance; WIP aging report |
| CR‑6 Sorting/REC | Evaluation forms; REC mapping posters; nonconforming material log; calibration records |
| CR‑7 Data Security | Data policy; access control list; incident plan & drills; chain‑of‑custody logs |
| CR‑8 Focus Materials | FM identification list; storage/inspection logs; downstream approvals; export screens |
| CR‑9 Facility | Housekeeping/inspection checklists; PM records; fire/battery controls; closure plan & financial coverage |
| CR‑10 Transport | Approved carriers; packaging/segregation SOPs; shipping docs; seal logs |
| A Downstreams | Downstream matrix; qualification pack; contracts; monitoring reports; exception/CAPA |
| B Data Sanitization | Method matrix; tool validation; wipe/destruction logs; per‑device reports; access logs |
| C Test & Repair | SOPs; grading guide; ESD program; outgoing QC; RMA/warranty analysis |
| D Specialty Reuse | Competency proofs; regulatory checks; calibration; outgoing documentation |
| E Materials Recovery | Depollution WI; shredder controls; monitoring data; downstream verifications |
| F Brokering | Broker SOP; contracts; chain‑of‑custody; downstream monitoring |
| G PV Modules | PV risk assessment; test plan; breakage controls; downstream files; inventory/traceability |
File‑Tree Starter (mirror this in your DMS)
/01_Policies
/02_SOPs & Work_Inst
/03_Training & Competency
/04_Legal & Permits
/05_Throughput & Mass_Balance
/06_Downstreams (Appendix_A)
/07_Data_Security (Appendix_B)
/08_Test_Repair (Appendix_C_D)
/09_Materials_Recovery (Appendix_E)
/10_Brokering (Appendix_F)
/11_PV_Modules (Appendix_G)
/12_Internal_Audit_CAPA
/13_Management_Review
/14_Facility_Inspections_PM
/15_Transport & CoC
Auditor Sampling Recipe (use every quarter)
- Pull 3 random lots from last 90 days and follow the paper trail end‑to‑end.
- For each applicable Appendix, pull 1 process run (e.g., a wipe batch, a repair traveler, a brokered shipment).
- Log gaps → open CAPA with owner and due date.
Core Requirements (CR 1–10)
CR‑1 Scope
Plain‑English: Say exactly what you do, where, and what R2 parts apply.
You need:
- A public Scope statement that matches reality (processes, materials, devices, brokered activities, any external controlled locations).
- Your certificate lists applicable Appendices and legal entities.
- Public list of other locations you control that handle used electronics but are not R2 certified.
Checklist (Owner: TM)
- Scope statement published (site, website, or certificate annex).
- Processes & external locations inventory up to date.
- Applicable Appendices identified (see matrix below) and shown on the certificate.
- Legal names/entities on certificate verified.
- Non‑certified related locations list published and current.
Show the auditor: current certificate, scope narrative, process map, site map, list of external locations, change log.
CR‑2 Hierarchy of Responsible Management Strategies
Plain‑English: Reuse first when lawful and safe. If not reusable, go to responsible materials recovery. Avoid disposal unless unavoidable and legal.
You need:
- A policy and SOPs that prioritize reuse, then materials recovery.
- Controls preventing reuse of illegal, counterfeit, recalled, or stolen items.
- Evidence that routing decisions follow the hierarchy.
Checklist (Owner: TM + OPS)
- Hierarchy policy approved and communicated.
- Intake triage SOP directs reuse-capable items to reuse processes; others to materials recovery.
- Blocklist SOP (lost/stolen, counterfeit, recalls) enforced.
- Periodic sample of routing decisions with evidence (e.g., evaluation forms, photos, test results).
Show the auditor: policy, routing SOPs, sampled job tickets, nonconforming material log.
CR‑3 EH&S Management System (EHSMS)
Plain‑English: Run a real EHS management system (ISO 14001 + ISO 45001 or RIOS). Know your hazards and control them.
You need:
- Certification to an approved EHSMS (or documented conformance if allowed by COP) and effective risk assessments for your processes (e.g., batteries, CRTs, PV, shredding, manual disassembly).
- Training matrix & competency, PPE, incident/near‑miss, emergency preparedness, maintenance & housekeeping.
- Internal audits at least annually and management reviews.
Checklist (Owner: EHS)
- Current ISO 14001/45001 or RIOS certificate (or approved pathway per COP).
- Process hazard analyses (incl. chemical, electrical, ergonomic, fire, explosive risks).
- Emergency plans (fire, spill, medical, utility loss) + drills recorded.
- Safety inspections and preventive maintenance on schedule.
- Training: orientation + task‑specific; competency verified.
- Annual EHSMS internal audit + CAPA; management review minutes.
Show the auditor: certificates, risk register, SOPs, drills, inspection logs, training/competency records, internal audit + CAPA, management review.
CR‑4 Legal & Other Requirements
Plain‑English: Know the laws that apply (environmental, health & safety, waste, import/export, data, privacy) and prove you follow them.
You need:
- A legal register covering all jurisdictions (site + shipping). Include permits/consents, waste codes, transporter and destination authorizations, and data/security rules.
- A compliance plan with monitoring, documented checks, and corrective actions. Include proof of lawful imports/exports when applicable.
- Consider customer and other contractual requirements.
Checklist (Owner: EHS + LOG + DSV)
- Legal register current (incl. cross‑border flows, Basel/equivalents, customs/classifications).
- Permits/licenses displayed and valid; conditions tracked.
- Import/export dossier template (evidence of legality) defined; shipping files include it.
- Periodic legal compliance audits completed, actions closed.
Show the auditor: legal register, sample shipping files, permits, audit reports, CAPA log.
CR‑5 Tracking Throughput
Plain‑English: Know what comes in, what happens, and what leaves — by quantity, category, and destination.
You need:
- Inbound/outbound logs with weights/counts, categories (per REC), dates, job IDs, and downstreams.
- Mass balance (e.g., monthly/quarterly) showing reasonableness vs. processes & yields.
- Work‑in‑process (WIP) controls and aging.
Checklist (Owner: OPS + QTL)
- System captures inbound/outbound by REC category, weight/count, date, and DSV.
- Reconciliation report (mass balance) prepared and reviewed at least quarterly.
- WIP aging report with triggers for action.
Show the auditor: sample lots from receipt → process → shipment, mass balance workbook, dashboards.
CR‑6 Sorting, Categorization & Processing
Plain‑English: Evaluate items, assign REC categories, and route them correctly. Do the work you say you do, in control.
You need:
- Evaluation SOPs by product family (PCs, servers, phones, displays, PV, etc.).
- REC mapping (internal grades ↔ REC). Clear acceptance/rejection criteria for reuse.
- Controls to prevent mixing of incompatible or hazardous streams; defect/hold process.
Checklist (Owner: OPS + QTL)
- Evaluation forms/templates live and used.
- REC mapping published at workstations.
- Nonconforming/hold procedure + quarantine area.
- Calibration/maintenance for test equipment.
Show the auditor: traveler packets, evaluation records, REC labels, calibration logs.
CR‑7 Data Security
Plain‑English: Prevent data breaches. Sanitize or physically destroy data storage devices under controlled conditions — and prove it.
You need:
- Data security policy (roles, access control, authorization levels, disciplinary consequences).
- Physical/logical security of data areas (restricted access, CCTV or equivalent controls, chain of custody, tamper‑evident packaging, device tracking).
- Sanitization SOPs aligned to device type and data sensitivity; incident response.
Checklist (Owner: DSL)
- Access control list + authorization records for data handlers.
- Secure areas defined; security controls tested.
- Incident response plan + drills.
- If you sanitize: Appendix B is applicable (see below).
Show the auditor: policy, access logs, chain‑of‑custody, incident drills, sample sanitization packets.
CR‑8 Focus Materials (FM)
Plain‑English: Identify Focus Materials (e.g., mercury devices, CRT glass, some batteries and lamps, certain PV components). Manage them to prevent uncontrolled releases and ensure legal downstream recovery.
You need:
- FM identification by device/component, safe handling & storage, containment, spill kits, emergency response.
- Qualified downstream vendors with appropriate permits/capabilities; additional controls for export.
- Evidence that non‑FM streams are still managed per the hierarchy and law.
Checklist (Owner: EHS + DSV + OPS)
- FM inventory & handling SOPs.
- FM storage specs (closed, labeled, compatible, inspected).
- FM downstream qualifications complete and current; contracts reference FM controls.
- Export screens and records (where applicable).
Show the auditor: FM list by SKU/bill of materials, inspections, training, downstream approvals, shipment files.
CR‑9 Facility Requirements
Plain‑English: Your building, equipment, and housekeeping protect workers, the public, the environment, and product integrity.
You need:
- Good housekeeping; weather/containment controls; ventilation and dust/noise controls where needed; fire prevention & protection; battery and lithium handling precautions; security.
- Maintenance program; equipment safeguarding; pedestrian/forklift separation; signage.
- Closure plan & financial coverage sized to your risks and inventory profile.
Checklist (Owner: EHS + OPS)
- Facility controls checklist (weekly/monthly) with photos.
- Preventive maintenance plan executed; critical spares identified.
- Storage density limits posted and respected; aisles clear.
- Battery/PV/CRT special controls implemented where applicable.
- Closure plan reviewed annually; financial instrument current.
Show the auditor: inspection logs, maintenance records, floor plans, closure plan & financial coverage, photos.
CR‑10 Transport
Plain‑English: Ship legally and safely, with accurate descriptions and protection of data and environment.
You need:
- Carrier vetting, packaging/segregation SOPs, accurate codes/descriptions, placarding where required.
- Chain of custody and security for data‑bearing devices; seals/tamper evidence where appropriate.
- Export/import evidence of legality.
Checklist (Owner: LOG)
- Approved carriers list; licenses/insurance validated.
- Pack/segregation SOPs by device/material (incl. batteries, displays, PV).
- Shipping descriptions/codes verified before dispatch.
- Seal logs and exception handling.
Show the auditor: sample BLs/manifests, carrier files, packaging SOPs, seal records, training.
Appendix Applicability Matrix (quick self‑screen)
- A – Downstream Recycling Chain: If you transfer control to any downstream (reuse, repair, recovery, disposal) — almost everyone.
- B – Data Sanitization: If you wipe or destroy data storage devices, or manage data‑bearing devices for reuse.
- C – Test & Repair: If you functionally test and/or repair devices/components for reuse.
- D – Specialty Electronics Reuse: If you refurbish, test, or resell specialized equipment (e.g., medical, lab, industrial) requiring special competencies/compliance.
- E – Materials Recovery: If you mechanically or chemically process to recover materials (e.g., shred, smelt partners, de‑manufacture to commodity streams).
- F – Brokering: If you control equipment to a downstream without physically receiving/processing it at your site.
- G – PV Modules: If you handle, process, store, transport, or broker photovoltaic (solar) modules/cells.
If an activity is outsourced, Appendix A controls still apply to managing that downstream.
Appendix Applicability Decision Tree (quick)
Start → Do you transfer control to any downstream? → Yes → Appendix A applies
↓ No → (rare; recheck)
Do you handle data‑bearing devices or sanitize/destroy storage? → Yes → Appendix B
Do you test/repair for reuse? → Yes → Appendix C (and D if specialized equipment)
Do you mechanically/chemically recover materials? → Yes → Appendix E
Do you arrange downstreams without physical possession? → Yes → Appendix F
Do you handle/broker PV modules? → Yes → Appendix G
If an activity is outsourced, Appendix A controls still apply to managing that downstream.
Process Requirements (Appendices A–G)
Appendix A — Downstream Recycling Chain (DSV)
Plain‑English: Know your downstreams, qualify them, contract them, and keep verifying.
You need:
- A downstream map from your dock to final disposition for each stream.
- Qualification criteria (permits, capabilities, certifications, FM handling, legality), initial due diligence, and ongoing monitoring.
- Contract terms requiring conformance and allowing oversight.
- Records that shipments matched the plan (no leakage to uncontrolled destinations).
Checklist (Owner: DSV)
- Stream‑by‑stream downstream map maintained.
- Qualification pack per downstream (permit/licensing, capabilities, references, audit/assessment).
- Contract language covering R2 duties, FM, confidentiality, sub‑tier control.
- Annual monitoring (desktop or on‑site); re‑qual triggers defined.
- Shipment exception process (mismatches, rejections) with CAPA.
Show the auditor: current downstream matrix, sample qualifications, contracts, monitoring reports, exception/CAPA log.
Appendix B — Data Sanitization
Plain‑English: Sanitize (logical erase) and/or physically destroy per device type, verify the result, and trace each device.
You need:
- Device‑specific methods (aligned to NIST 800‑88 or stricter where required). When using physical destruction, follow method tables and controls.
- Per‑device tracking (unique ID/serial) from receipt → sanitization → verification → status.
- Secure area controls, tool validation, operator competency, periodic method effectiveness checks.
- Incident handling for failed sanitization or chain‑of‑custody breaches.
Checklist (Owner: DSL)
- Sanitization matrix (media type × method × verification) published.
- Wipe tools validated; logs capture start/stop, result, operator, hash where applicable.
- 100% verification for logical sanitization; defined sampling/inspection for physical destruction residues per method.
- Per‑device certificate/report available for customers on request.
- Access controls, cameras (or equivalent), and storage security working.
Show the auditor: wipe logs, destruction logs/photos, calibration/validation of tools, per‑device reports, access logs, incident records.
Appendix C — Test & Repair
Plain‑English: Prove you’re competent to test/repair, grade honestly, and disclose what the buyer is getting.
You need:
- Diagnostic procedures by product family; competence/training for techs; calibrated test equipment.
- Functional and cosmetic grading tied to REC (and your sales channels).
- Repair parts traceability and quality controls; ESD controls where needed.
- Outgoing documentation: test results, firmware/lock status, data sanitization status.
Checklist (Owner: QTL)
- SOPs for test, repair, final inspection; calibration records.
- REC category labeling; cosmetic grading guide posted.
- Parts provenance/traceability (no counterfeit); ESD program.
- Outgoing quality checks; RMA/warranty feedback loop into CAPA.
Show the auditor: traveler with test results, grading snapshots, calibration certificates, training, outgoing QC records.
Appendix D — Specialty Electronics Reuse
Plain‑English: Extra controls for specialized equipment (e.g., medical, lab, avionics, networking/carrier‑grade) where laws, safety, or calibration apply.
You need:
- Proof of competency, specialized tools, and access to service info.
- Compliance checks (licenses/authorizations, radiation, biohazards, patient data, etc.).
- Calibration and functional verification to appropriate standards before resale.
Checklist (Owner: QTL + EHS)
- Specialty device inventory and risk screen.
- Regulatory/standards map per device type; prohibitions documented when reuse is unsafe/illegal.
- Calibration records & labels; warnings/instructions included with sales.
Show the auditor: device‑type cheat sheets, competence records, calibration, outgoing documentation.
Appendix E — Materials Recovery
Plain‑English: Control your depollution and recovery processes so there are no uncontrolled releases and FMs get proper downstreams.
You need:
- Depollution steps before shredding; emission/effluent controls where applicable.
- Process parameters, maintenance, and monitoring records.
- Contracts/downstream verification for each commodity, especially FM fractions.
Checklist (Owner: OPS + EHS + DSV)
- Pre‑treatment/depollution work instructions (batteries, mercury, toner, PV laminate, etc.).
- Shredder or dismantling controls (guards, ventilation, fire suppression, feed limits).
- Sampling/analytics for output quality if claimed.
- Downstream verifications current; shipments match declared outlets.
Show the auditor: SOPs, maintenance logs, monitoring data, shipment files, downstream approvals.
Appendix F — Brokering
Plain‑English: Even if you never touch the goods, you still control them. Prove they went to qualified downstreams with correct categorizations and documents.
You need:
- Control and visibility from seller → downstream; accurate descriptions and REC categories.
- Contracts binding downstreams; qualification & monitoring like Appendix A.
- Records: chain of custody, shipping docs, exceptions & CAPA.
Checklist (Owner: DSV + LOG)
- Brokered transaction SOP (quotes, PO, descriptions, REC, DSV qualification).
- Documentary pack per shipment; exception workflow.
- Periodic monitoring of brokered downstreams.
Show the auditor: broker files, communications, contracts, downstream evidence.
Appendix G — Photovoltaic (PV) Modules
Plain‑English: Handle PV modules safely, evaluate for reuse, and manage unique FM and processing hazards; maintain tight traceability.
You need:
- PV hazards identification (electrical shock/energized circuits, glass breakage, laminates/chemicals); safe handling and storage.
- Testing/evaluation method (can include defined batch testing where allowed); routing to reuse or materials recovery with evidence.
- Downstream qualifications for PV reuse and recovery; traceability of all PV panels managed (including brokered).
Checklist (Owner: PVL + EHS + QTL + DSV)
- PV handling & electrical safety SOPs; trained/competent staff.
- Evaluation & test plan (functional/visual criteria); batch testing rules where applicable.
- Breakage/clean‑up & waste controls; FM identification for PV components.
- Downstream matrix for PV reuse, recycling, and residues; contracts & permits verified.
- Inventory & traceability logs for every PV module batch.
Show the auditor: PV risk assessment, training, test results, routing decisions, downstream files, inventory/traceability logs.
Auditor Interview Playbook (by clause)
Use these to prep supervisors/operators. Keep answers short and point to records.
- CR‑1: What is our R2 scope? Which appendices apply? → Show scope poster & certificate.
- CR‑2: How do you decide reuse vs recycling? → Describe triage and prohibited items list; show a recent routing example.
- CR‑3: Top 2 hazards at your station and the controls? → Name PPE/engineering controls; show training card.
- CR‑4: What permits affect your job? → Point to permit board/legal register.
- CR‑5: How do we know where this lot is and where it went? → WMS, traveler, mass‑balance.
- CR‑6: How do you assign REC categories? → Show workstation REC quick‑guide.
- CR‑7: How is access controlled here? What happens in an incident? → Access list, incident workflow.
- CR‑8: Where are Focus Materials and how are they stored? → Point to labeled, closed containers; inspection log.
- CR‑9: What do you check on the daily walkdown? → Aisles, density limits, battery checks.
- CR‑10: How do you select carriers and describe shipments? → Approved list, packaging SOP, codes.
- A–G: How do you qualify/monitor downstreams? Prove this panel/device was routed correctly. → Downstream matrix, qualification file, shipment docs.
Practical Tools
1) 90‑Day Implementation Plan (template)
Days 1–30
- Publish Scope; pick applicable Appendices; appoint clause owners.
- Build legal register; collect permits/licenses; freeze list of external controlled locations.
- Draft core policies (Hierarchy, Data Security, EHS policy) and top‑level SOP index.
Days 31–60
- Finalize evaluation/test SOPs with REC mapping; stand up throughput tracking and mass balance.
- Downstream mapping + initial qualifications; draft contract clauses.
- Facility controls walkdown; corrective actions list; battery & fire risk projects.
Days 61–90
- Train & qualify operators; run mock jobs end‑to‑end; generate sample records.
- Perform internal audit (R2/EHS/legal); open CAPAs; hold management review.
- Audit‑day rehearsal with evidence binder and floor tour script.
2) Audit‑Day Floor Tour Script (one‑pager)
- Intake → Quarantine/ID check → Evaluation (REC) → Data Area (B) → Test/Repair (C/D) → Depollution/Recovery (E) → Outbound Staging (A/F/10).
- At each stop: show SOP, training/competency, live records, controls, and last internal audit/CAPA relating to that area.
3) Records Map (sample)
| Process | Record | Where | Retention |
|---|---|---|---|
| Intake | Receiving log, weights, photos | WMS/SharePoint | 3+ years |
| Data Sanitization | Per‑device report, tool validation | DS portal | 3+ years |
| Test & Repair | Traveler, test results, grading | QMS DB | 3+ years |
| Downstreams | Qualification pack, contracts, monitors | DSV drive | 3+ years |
| Throughput | Monthly mass balance | Ops folder | 3+ years |
| EHS | Risk register, inspections, drills | EHS drive | per policy |
| Transport | BL/manifest, seal logs | Logistics | 3+ years |
4) Common Nonconformities & How to Avoid Them
- Scope drift: unlisted external storage/processing locations → keep the list public and current.
- REC mismatch: internal grades don’t map to REC → post the mapping and train.
- Downstream staleness: expired permits/certs in files → calendar reminders and annual reviews.
- Weak mass balance: missing WIP or adjustments → standardize variance thresholds and triggers.
- Data gaps: no per‑device trace for sanitization → enforce unique ID and completeness checks.
- Facility basics: blocked exits, unlabeled containers, poor battery storage → weekly 5S + photo logs.
5) Clause Owner Dashboard (monthly)
- Green: training ≥ 95% current; Amber: 80–94%; Red: < 80%.
- Mass‑balance variance: <2% Green; 2–5% Amber; >5% Red (investigate root causes).
- Downstream re‑quals due: list and due dates.
- Open CAPAs: count, oldest age, on‑time closure %.
Self‑Assessment & Readiness Scorecard
Score 0–2 for each item (0 = not in place, 1 = partial, 2 = robust). Aim ≥ 85% and no zeros before scheduling certification.
| Area | Items |
|---|---|
| Governance | Scope posted; clause owners named; objectives set; management review held |
| Legal | Legal register complete; permits valid; import/export dossier template used |
| EHSMS | Risk assessments current; training ≥95% on‑time; emergency drill last 90 days |
| Throughput | REC captured; mass‑balance run quarterly; WIP aging controls active |
| Data Security | Secure area controls; per‑device trace; incident drill completed |
| Downstreams | Matrix current; qualification packs complete; contracts with R2 clauses |
| Test/Repair | SOPs & calibration; grading/REC alignment; outgoing QC |
| Materials Recovery | Depollution WI; shredder/vent controls; downstream verifications |
| Transport | Carrier vetting; packaging/segregation SOPs; seal logs |
| PV (if applicable) | PV risk/test plan; traceability; downstreams |
Scoring rubric: 0 = missing; 1 = documented but inconsistent; 2 = documented + trained + records present.
Appendix: Quick Checklists You Can Print
Site‑Wide “Daily”
- Housekeeping walkdown; aisles/egress clear; battery storage checks.
- Data area access control functioning; visitor logs.
- Staging labeled by status; no mixing of incompatible materials.
Weekly
- Eye‑wash/shower checks; fire extinguishers; spill kits.
- Forklift & baler/shredder PM checks; guards in place.
- Random job back‑trace from inbound → outbound (throughput control).
Monthly
- Mass balance review; WIP aging purge plan.
- Downstream file spot‑check (permits/certs not expiring).
- Training matrix review; retrain/qualify as needed.
Quarterly
- Legal register review; update export/import dossiers.
- Emergency drill (rotate scenarios) + lessons learned.
- Management KPI review: incidents, CAPA, customer complaints/RTVs.
Annual
- Internal audit covering EHSMS + R2 + Legal; close CAPAs.
- Management review; objectives for next year.
- Closure plan refresh; financial coverage check.
Printable Templates
Copy these into your DMS as living forms.
- Downstream Qualification Pack Checklist — permits/licences; capabilities; certifications; FM handling; sub‑tier control; audit/monitoring plan; contract clauses.
- Import/Export Dossier Cover Sheet — classifications/codes; licensing/consents; receiving facility authorization; due‑diligence notes; copies of shipping docs.
- Mass‑Balance Workbook Tabs — Intake, Processing, FM, Outbound, Variance, WIP Aging, Notes/Assumptions.
- Sanitization Batch Report (Appendix B) — device ID/serial; method; verification result; operator; timestamps; hash (if applicable).
- Repair Traveler (Appendix C/D) — diagnostics performed; parts used; locks/firmware status; cosmetic grade; final test results; traceability to sanitization record.
- Facility Inspection (CR‑9) — aisles/egress; density limits; battery stations; fire systems; PM checks; photo log.
- Carrier Vetting Form (CR‑10) — licensing/insurance; scope; prohibited items; incidents; review date.
One‑Page Posters (make & post)
Create these as single‑page PDFs, laminate, and post at the relevant workstations.
1) Hierarchy of Responsible Management Strategies
Order of preference (always legal & safe): 1) Reuse → 2) Materials Recovery → 3) Disposal (last resort).
Never reuse: stolen, counterfeit, recalled, illegally imported/exported, or unsafe items.
Operator cues: If reusable per SOP → route to Test/Repair; if not → depollute FMs → materials recovery; document your decision on the traveler.
2) REC Quick‑Guide (per product family) — fill in your site’s mappings
| Product Family | Example Acceptance for Reuse | Required Tests/Proof | Data Status | Cosmetic Grade | Your REC Category |
|---|---|---|---|---|---|
| Laptops | Boots to OS; battery health ≥ threshold | Keyboard, display, ports, battery, Wi‑Fi | Wiped/verified | B/C | [select] |
| Desktops | POST OK; no missing major parts | CPU/RAM/storage checks; ports | Wiped/verified | B/C | [select] |
| Smartphones | Unlockable; no activation lock | Screen, camera, battery, radios | Wiped/verified | B/C | [select] |
| Servers/Networking | Powers; passes vendor diag | Fans, ports, firmware, PSU | Wiped/verified | N/A | [select] |
| Displays | No cracks; acceptable pixel defects | Burn‑in, color, controls | N/A | B/C | [select] |
| PV Modules | Safe connectors; passes test plan | Visual + electrical checks | N/A | N/A | [select] |
Replace [select] with your approved REC code per the official R2 Equipment Categorization. Keep a printed copy of the full REC table nearby.
3) Battery & PV Handling — Do’s / Don’ts
Batteries (esp. lithium):
- Do: tape/cap terminals; segregate by chemistry and state (intact vs. damaged); use approved containers; maintain spacing; inspect daily; keep spill/thermal event kit ready; train staff.
- Don’t: crush, puncture, over‑stack, mix damaged with intact, charge in staging, or store near heat sources.
PV modules:
- Do: assume energized; cover connectors; use glass‑safe lifting; store flat/secured; clean‑up broken glass per SOP; identify FM components before processing.
- Don’t: cut live wires; lean stacks unsecured; ignore micro‑cracks or delamination.
4) “Call Before You Ship” — Export/Transfer Checklist
- Receiving site authorized (permits/licences) and qualified in your downstream matrix.
- Correct classifications/codes and documentation prepared (include evidence of legality where required).
- Contract includes R2 obligations, FM handling, and sub‑tier controls.
- Packaging/segregation per SOP; no data‑bearing devices shipped without required status/proofs.
- Records pack assembled (shipping docs, permits/consents, contacts). If anything uncertain → call the DSV/LOG lead before dispatch.
5) Data Area — Golden Rules
- Access‑controlled: authorized, trained staff only; visitors escorted and logged.
- Chain of custody: every device has a unique ID; status visible (e.g., To‑Wipe/In‑Process/Verified/Failed).
- Approved methods/tools only; verification recorded for every device per SOP.
- No personal devices, photography, or unsecured notes in the data area.
- Incident? Stop, secure, report to DSL; complete incident log and follow response plan.
Final Reminders
- Keep it simple, visible, and provable. If you can’t show it, it didn’t happen.
- When you add a new process or product family, revisit Scope, REC mapping, hazards, downstreams, and training.
- Use internal audits as practice — the best time to find a gap is before the auditor does.
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