2008 R2 Version 1 Is a Public Document. Certify That You Conform To It

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.

Bullboys 11: "My Generation Did WHAT??" to CRT Glass Markets

So I used to sell to Egypt, now I don't.

I used to sell to Indonesia, but it's illegal now, so I stopped.

And for years I exported to Malaysia for refurbishing, and that factory - which recycled 100% of accidental breakage at the CRT glass furnace in KL - no longer speaks English.  We gave them a price cut in return for their obtaining ISO14001 certification.  They began a takeback program, creating a domestic Malaysia CRT recycling infrastructure...

It's all dead.  Supply and demand.

The E-Waste Industry, at the EScrap Conference in Orlando, will be talking about there being no demand for CRT glass, cathode ray tube cullet.   But that's not exactly what there's no demand for.

There's no demand for self-righteous bigotry and b******t.

Back to the drawing board.  I can cross off lots of places that are expensive to visit, expensive to audit, and give R2 Auditors the heeby-jeebies.  Turns out, the heeby-jeeby feeling is mutual.  In Vermont, we have practically eliminated CRT export for reuse.  I could become an E-Steward right now, if I was willing to pay the dues.  I'm not doing anything they don't want me to do.

So gee... I should look back at the invitation to join E-Stewards, the gracious invitation extended to me last
winter.   Sure, I'm qualified now to be a "steward".  But, it's wasted on me.  See, I'm really not into calling innocent people guilty, and the whole making myself look like a better recycler by making other people look worse.   If an all white country club chased off my colored fiance, and said now I could be a member, I wouldn't be too keen with all that.  

I'm E-Steward qualified, E-Steward eligible, E-Steward compliant. I'm a good ole e-waste steward boy. Just got to show them my downstreams and write them a check.

Basel Action Network Accuses R2 Certified Companies of Illegal Acts

On June 17, Basel Action Network released another attack piece, accusing R2 Solutions of violating international law.  In doing so, BAN has indirectly attacked my company, which chose to pay for R2 Certification rather than accepting E-Stewards written offer to pay BAN to certify our operation to their own E-Stewards Standard.

Here's an "as concise" critique of BAN's "concise critique", based on the following international law.

Article 17 of the United Nations International Covenant on Civil and Political Rights states: 

1. No one shall be subjected to arbitrary or unlawful interference with his privacy, family, home or correspondence, nor to unlawful attacks on his honour and reputation. 2. Everyone has the right to the protection of the law against such interference or attacks.

Five Fundamental Flaws.   A Concise Critique of the R2:2013 Standard  / June 17, 2013

"The [R2] Standard suffers greatly from its seeming intentional avoidance of international law as it refuses to acknowledge or recognize the definitions and obligations, decisions and guidelines of the Basel Convention, which all developed countries, except the United States have ratified and implemented and is now globally adopted by 180 countries." - Jim Puckett

There are three problems with BAN's analysis of their competitors at R2 Solutions.  The third is the most important.

Corrective and Preventative Action (CAPA)

Our company just went into an environmental "Surveillance Audit" for R2.  Some advice for people who are getting certified, or thinking about getting certified...

The temptation is to think that on the second audit, you've done this before.  You got the initial certification, you think that's the hard part.  No.   Joining the Army is the easy part.  Staying in the Army is the hard part.

When you think about it, there aren't too many economic incentives to keep someone out of a certification, whether it's E-Stewards, or R2, or ISO, etc.  What the company is signing up for is a process.  It's like joining a church, it's not about your past sins, it's about your commitment to being better.

What happened prior to our Surveillance Audit was that I took two trips to the Southwest (things are heating up at Retroworks de Mexico, despite the snow down there) and left people I trust in charge.  They have earned my confidence, as in confidence to do what I've trained everyone is our culture to do.

Efficiency, Good Work, Value, Accountability.  Get 'Er Done, combined with Know-How.

In that vein, everybody at the plant was motivated, without me telling them so, to make the place ship-shape.  We were proud of our company, and open to the audit with open arms.  A special clean up crew was assigned room by room to make sure everything was swept up and ship shape.

Well, we do "batch work" a few times a year.   Like we let the projection tubes build up until there will be enough of them to actually fill barrels with ethyl glycol.  If you do them as they come in, a few per day, you tie up more floor space with 1/8 full barrels which are actually more susceptible to spills than the projection tubes they were stored in.  So it makes sense, operationally, to store up 30 gaylords of the projection tubes when things are busy in the summer, and to keep people employed in the winter by draining them in a batch.

LCDs are similar.  In the first batch, you test working.  In the second batch, of the ones not working, you examine for capacitors and other "easily" repairable problems (for those in the know).  In the third batch, you leave for last the de-manufacturing of the busted-up-beyond-hope LCDs that need demanufacturing.

You are proud of the quality of your reuse.  We are led to believe, and it's true, that a lot of companies will sell the LCDs "as is" in a mixed lot.  Economically, you can "externalize" the cost of the LCD demanufacturing if you use the reuse value of the working and repairable to make the other LCDs tag along, as "toxics along for the ride".   So we haven't been doing that, we are proud to be tackling the hardest part of the work during the R2 winter surveillance audit.

So you've got a couple of people doing something new, something they aren't as experienced in, in the "batch work".  And you have a crew of eager clean up guys, circling around, trying to make the place look neat and orderly before the auditor arrives.

Crack.

That was the thin ice.