The original Responsible Recycler Version 1 was a public document. EPA in Washington DC paid a professional mediator, John Lingelbach, to host a series of meetings with environmental stakeholders and experts (myself included) to get a standard that ANAB and ANSI could ok various professional auditors, such as Orion Registrars or Perry Johnson Registrars to certify.
Here is a link to the original R2 V1 document, which is now very difficult to find online. I had to use the Internet Archive Wayback Machine (and I left them a donation, it's a really cool utility).
Conforming to a public standard is something a small recycling business can do without any legal third party, such as SERI or E-Stewards, taking a financial cut. You cannot claim to be certified BY that third party, and you don't get a certificate with a gold star. But you can pay for the exact same person, the exact same auditor, to come and audit your status as certifyable to your conformance to the 2008 standard.
The Versioin 2 of the R2 standard arguably made no changes at all to the Version 1 other than make it a non-public, copyrighted standard. And that was more than arguably due to the financial interests of the certification organization that John Lingelbach formed in order to make a living and hire people to "maintain" the standard. And they do "Maintain" it, and ANAB and ANSI may or may not add value that ISO (which you have to also adhere to in order to get R2 certification) doesn't give you anyway.
R2 Version Three is, shall we say, a subject of immense controversy. John Lingelbach has long left SERI, and the process he maintained of keeping 40+ stakeholders in a Technical Advisory Committee has long been ditched. The current leadership openly (brazenly) says they leave more than half of the seats on the TAC unfilled despite 90+ nominations because a large group of stakeholders makes "consensus" too difficult to maintain.
That's racketeering. I spoke to retired people familiar with ANAB and ANSI who say that it's the cancer of certification programs. Insiders get in. There are ZERO residential / municipal recycling companies on the TAC, and the standards are now written by members who charge $8 per hard drive, rather than 15 cents per pound. R2 V3 arguably includes standards that are impossible to achieve if the resident is dropping off their 15 year old dusty computer at a public drop off or charity, because the $8 per hard drive process certified to now has a chain-of-custody requirement. Any auditor (e.g. paid cash by your competitor) can disqualify any residential recycler today under V3, and you can't do anything but trust them not to disqualify you.
That's why the "spare tire" of conforming to R2 Version 1 might be important. If you want to find a less expensive certification that isn't changing the rules in smoke filled rooms by small groups of interested parties in a game of "last man standing", contact me.
In the meantime, we are conforming to R2 Version 1. And no one has the standing in court to challenge that unless they get EPA as a co-complainant.
Contact me at my email or DM me on Twitter if you want to be Children Of A Lesser God standard. Most clients don't care.
No comments:
Post a Comment