When the R2 Technical Advisory Committee (TAC) had its face-to-face meeting, there had been hope that the draft Standard revision would be released by the end of this calendar year for public comment, but the TAC was informed that April 2018 was likely to be the earliest date given the remaining work.
by Lynn Rubinstein, NERC
Among the highlights of the TAC meeting is the possibility of revising the Standard to introduce more specificity for different business models. An example currently being considered is to re-organize Provision 6 – Reuse to clarify the requirements for all certified recyclers and additional requirements based on specific business models and recycler activities.
A topic being debated is whether and how to provide a strategy for recyclers to be in compliance with the Standard that have customers that retain title to the material sent to the recyclers, and which the recyclers are required to send back to the customer for final processing. The challenge arises when the customer refuses to provide information about downstream processors making it impossible for the recycler to comply with its downstream due diligence requirements and therefore for the auditor to verify compliance. Strong concerns were expressed within the TAC about any changes that might weaken the Standard or provide easy loopholes for non-compliance. On the other hand, this business practice is growing and seeking ways to successfully integrate it into the Standard was also stressed. The TAC is deliberating about potential strategies and this will remain an active topic for the next few months.