Almost 500 comments were received and reviewed by the R2 Technical Advisory Committee (TAC), many of which, have been incorporated into the next draft that was posted on the SERI website. A “red-line” version of R2v3 has also been posted to show the changes from the first draft to the second draft of R2v3. The R2 Equipment Categorization (REC) document has also been updated in response to the public comments received and is posted for public review and comment.
SERI invites comments on the new changes in the second draft of R2v3 and the REC. Please use the public comment form on the SERI website to submit your suggestions for improvement. At the end of the 45-day public comment period the TAC will consider all comments and determine whether any additional changes should be made.
Summary of Public Comments
A summary of all public comments submitted during the first round of public consultation is published on the SERI website. The summary identifies the public comments that resulted in changes to the R2v3 draft. For comments that did not result in change, a brief summary of the TAC’s consideration of the issue has been provided, including, where applicable, any related guidance or clarification to address the issue raised.
Where clarifying or guidance information has been provided, this information will be used as the basis for the development of further supporting resources such as training and guidance, following the release of the standard.
Commenters have the right to appeal any decision made by the R2 Consensus Body in accordance with the Appeals process defined in Article 7 of the SERI Manual of Policies and Procedures for R2 Standard Development.
Most significant changes from Draft 1 to Draft 2 of R2v3
The second draft of R2v3 incorporates many comments and suggestions that were submitted during the public comment period. Highlighted below are some of the key changes in the second draft. For a more detailed look, visit the R2v3 page of the SERI website.
Scope – Revised the definition of “scope” to clarify included and excluded operations/activities.
EHSMS – Revised the structure for better clarity and removed redundant requirements.
Sorting & Categorization – Simplified both the process and the R2 Equipment Categorization (REC) document. Key changes include:
- Clarification on processing paths for R2 Controlled Streams
- Allowing facilities to use their own internal categories if they are mapped to corresponding categories in the REC.
Verifying Downstream Recycling Chain – R2 facilities must track the entire downstream chain,OR they have the option to register their portion of the chain with SERI and stop tracking at the first R2 Certified facility in their downstream.
- Allows for data sanitization by a non-R2 facility that has been property qualified.
- Rather than prescribing specific methodology for verifying sanitization, R2v3 requires documented “quality controls to assess and verify the effectiveness of the data sanitization processes on an ongoing basis…” This flexibility allows R2 Facilities to verify using the method that best suits their process, while still maintaining the same high bar.
Materials Recovery – Additional controls based on hazard assessment.
– Appendix no longer needed with the new tracking requirements in Appendix A-Downstream Recyling Chain.
To learn about R2v3, the proposed revision to the R2 Standard, visit the R2v3 page
of the SERI website to download the proposed R2v3 Standard and access other informational resources.