Most followers of the Good Point Ideas Blog already know that the R2 (Responsible Recyclers) Certification program was developed over a decade ago by US EPA. EPA's Clare Lindsey and Bob Tonetti hired a professional consensus mediator, John Lingelbach, to moderate the development of agreed upon standards that would achieve better results in reuse, repair and recycling of used electronics. Lingelbach later incorporated the
Sustainable Electronics Recycling International organization to "house" the new standard. SERI realized that the original standard developed by EPA would be a public document, not copyrightable... so SERI tweaked the R2 Standard in order to establish a way to earn revenue.
SERI's R2 Standard gives prescriptions for electronics recycling practices. The practices are developed by the Technical Advisory Committee (TAC, the ongoing advisor team from the industry). The TAC standards, if passed by the SERI Board of Directors, create new rules (red tape) for Certified Recyclers to follow.
Without even a formal change in the rules, SERI can issue guidance to reflect
a change in interpretation of the original rules. That's right, a TAC can act like a radical Supreme Court, with no tether to precedent. A clear example of this took place during this year's audit of
Good Point Recycling, which passed 99% of the Audit with flying colors. However, the auditor called foul on a trade which passed R2 audits the previous 9 years...
a trade that has taken place with the same downstream vendor for 17 years. A new "interpretation" of the old rules may cost my Vermont company $356,000 dollars per year, while achieving zero environmental benefit.
This is messed up. The rules have not yet been changed, but the "interpretation" of the old rules has.