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The R2 Technical Advisory Committee (TAC) has diligently continued to work through the responses received during the public comment period which closed May 20. More than 500 public comments were received, and the TAC is considering each. Some comments may result in substantive changes; some are being considered for minor editorial adjustments; some will be addressed in guidance rather than the language of the standard; and some are being considered but will not result in any changes. As you can imagine, this process is laborious as each change requires the TAC to consider whether it is clear and improves the quality of the standard, whether it is applicable internationally, how it affects other sections of the standard, how practical it is to implement by R2 facilities, and the auditability by Certifying Bodies. Following completion of the TAC review in the coming months, SERI will provide responses to the public comments, and a new draft of the standard will be put out for a fresh round of public comment on the changed portions.
In addition, SERI has been working on the process and systems which may be required for registration of the downstream recycling chain (see Appendix A.7 of the draft) and closure plans/ financial instruments/ insurance (see 9.f of the draft). Last week, SERI showed the TAC a demo of ChainPoint, which is a cloud-based platform for mapping supply chains. Although the SERI customization was not yet complete, the software appears capable of meeting SERI’s objectives. TAC members continue to express concerns over security and control of the information, licensing of the software, liability for breaches, expansion of the software scope beyond A.7 & 9.f registrations, and duplication of effort. We expect to hear more about this platform in the future.