Downstream Non-R2:2013 Certified Recycler Checklist
Vendor
Name:
Other
Business
Names:
Address:
Document #
Document the equipment sent to recyclers and the processing techniques by the downstream vendor.
Remove or change equipment types specific to each downstream vendor.
Equipment Processing Technique
Desktops Manual disassembly, shredding, mercury retort, etc.
Laptops
CRT TV’s/Monitors
Peripherals
Network Equipment
Video Equipment
Batteries
LCD TV’s/Monitors
Printers
Copiers
Polychlorinated Biphenyls
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Downstream Non-R2:2013 Certified Recycler Checklist
Equipment Processing Technique
Circuit Boards
Cellular Devices
Devices containing
Mercury
Document #
(Provision 7)
(Example – copy for each stream of materials. Make a flow diagram following the Focus Materials throughout the recycling chain.)
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Downstream Non-R2:2013 Certified Recycler Checklist Document #
Document the products containing Focus Materials that are imported or exported by the downstream vendors in this recycling chain. This shall not include any products Tested and Full Functions/R2 Ready for Reuse or
Tested for Key Functions, R2/Ready for Resale under Provision 6.
Product (with FM) Country Evidence of Legality
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Downstream Non-R2:2013 Certified Recycler Checklist Document #
These requirements are documented in R2:2013 Provision 5(e). The cross-referenced provisions are extracted here for all the requirements incorporated in 5(e).
Prov. Requirement Verification
5(e)(1)
How are downstream vendor(s) following the Focus Materials
Management Plan?
5(e)(1)
Are FMs removed from equipment prior to shredding?
5(e)(1)
Is mercury retorted or processed by other legal methods, not incinerated?
5(e)(1)
Are circuit boards processed for metals recovery?
5(e)(1)
Are polychlorinated biphenyls destroyed in legally compliant facilities?
5(e)(1)
Verify no FMs are managed for disposal through energy recovery, incineration, or landfill.
3(a)
Has the recycler developed a legal compliance plan and included it as a section of its EHSMS?
3(a)
Does the legal compliance plan include all applicable environmental legal requirements?
Examples: International regulations, national regulations, local laws, air pollution control, waste laws, etc.
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Downstream Non-R2:2013 Certified Recycler Checklist
Prov. Requirement Verification
3(a)
3(a)
3(a)
Does the legal compliance plan include all applicable health and safety requirements? Examples: worker safety regulations, fire codes, building codes, etc.
Does the legal compliance plan include data security regulations?
Examples include health information protection, financial information, personal identity information, etc. [section (a)]
Does the legal compliance plan include applicable import and export laws covering shipments of
FMs and shipments of untested or non-functioning equipment or components containing FMs? [
3(a)(2)
Does the legal compliance plan cover the legality of exports and imports through all countries?
3(a)(2)
Does the legal compliance plan include imports/exports by downstream vendors?
3(a)(2)
3(a)(2)
Does the recycler have evidence that transit or destination countries were determined prior to shipment by the recycler or downstream vendors?
Does the recycler have evidence of the legality of imports by each transferring or receiving country for which exports/imports move through? This includes imports/exports by the recycler or any downstream vendor for FM’s?
3(a)(3)
Does the recycler keep the legal compliance plan current?
3(a)(3)
Does the recycler identify and implement the steps necessary to comply with each requirement, and document the implementation of these steps?
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Downstream Non-R2:2013 Certified Recycler Checklist
Prov. Requirement Verification
3(a)(3)
Does the recycler periodically audit its compliance with applicable legal requirements?
3(a)(3)
Does the recycler have evidence of corrective actions that address issues of non-compliance?
4(a)
4(b)
Does the recycler demonstrate the expertise, knowledge, and technical capability to process each type of equipment, component, and material it accepts in a manner that is legal and protective of worker safety, public health, and the environment?
Does the recycler adhere to good housekeeping standards, including keeping all work and storage areas clean and orderly?
4(b)
Is housekeeping for all areas of the facility planned, regularly implemented, and monitored?
4(c)
4(c)
4(c)
Does the recycler conduct on an ongoing basis (e.g., as new types of materials are processed or new processes are used) a hazards identification and assessment of occupational health and safety and environmental risks that exist or could reasonably be expected to develop at the facility?
Does the hazards identification and assessment include all reasonably foreseeable sources? Examples include emissions, exposure to substances, noise, ergonomic factors, thermal stress, substandard machine guarding, cuts and abrasions, etc.?
Is the hazards identification and assessment captured in writing and incorporated as a component of the recycl er’s EHSMS?
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Downstream Non-R2:2013 Certified Recycler Checklist
Prov. Requirement Verification
4(d)
Does the recycler have records of managing the EH&S hazards through corrective action
4(d)
Does the recycler have evidence demonstrating it has minimized the risks identified?
4(d)
4(e)
Does the recycler implement and prioritize the use of appropriate strategies, including engineering controls, administrative controls, and personal protective equipment?
Does the recycler use monitoring and sampling protocols to continuously manage the risks it has identified?
4(e)
Does the recycler comply with all applicable permissible exposure limits for sampling and/or monitoring?
4(f)
4(g)
4(g)
Does the recycler treat anyone performing activities under its direction, using the same standard of care?
Has the recycler designated a qualified employee(s) or consultant(s) to coordinate its efforts to promote worker health and safety and environmental protection?
Is the designated individual(s) identified to all employees and twoway communication encouraged between employees and this individual regarding potential hazards and how best to address them?
4(h)
Has the recycler identified probable emergency situations and exceptional circumstances?
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Downstream Non-R2:2013 Certified Recycler Checklist
Prov. Requirement Verification
4(h)
Has the recycler documented and updated as necessary an emergency plan(s) for the probable emergencies?
4(h)
Does the emergency plan(s) consider workers, the public, and the environment?
4(h)
Does the recycler periodically test the emergency plans(s)?
4(h)
Are occurrences of emergency events, reported to the required authorities?
5(e)(3)
Does the recycler have a current list of environmental permits?
5(e)(3)
Does the recycler have copies of each environmental permit?
5(e)(3)
Are there any exposures requiring a Storm Water permit?
(For example, uncovered metal rolloff bin stored outside)
5(e)(3)
Are there any processes that treat waste water?
5(e)(3) Are there any air permits required?
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Downstream Non-R2:2013 Certified Recycler Checklist
Prov. Requirement Verification
5(e)(3)
Are there any permits required for recycling?
5(e)(3)
Has notification of waste activity been made to the appropriate authorities? (generator, handler, transporter, etc.)
5(e)(3)
Verify compliance with all EH&S regulatory requirements.
5(e)(4)
Does the recycler have a downstream due diligence program in line with Provisions 5(e) & (f)?
5(e)(4)
Does the recycler hold all downstream vendors accountable to 5(e) & (f)?
5(e)(5)
If the recycler refurbishes any equipment provided, use the
Downstream Refurbisher Checklist to verify conformance.
7(a)
Recycler tracks equipment received and shipped sufficient to demonstrate that material is not diverted to other vendors.
7(b)
Did the vendor provide all downstream business names and locations for FMs throughout the recycling chain?
10(a)
Does the recycler have a security program to control access to the facility?
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Downstream Non-R2:2013 Certified Recycler Checklist
Prov. Requirement Verification
10(a)
Is the security program appropriate to the type of equipment handled?
10(a)
Is the security program appropriate to the sensitivity of media containing data?
10(a)
Is the security program appropriate to the needs of customers served?
Document #
10(b)
Do security controls include transportation from your facility to the downstream recycler?
The above information applies to the minimum requirements of R2:2013 Provision 5(e) for downstream due diligence of a recycler managing Focus Materials. Additional evaluation is recommended. Onsite audits are encouraged.
Additional Notes:
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Downstream Non-R2:2013 Certified Recycler Checklist
Year 1
Evaluator:
Attached
Evidence:
Comments:
Status:
Date
Completed:
☐ Approved ☐ Suspended
Year 2
Evaluator:
Attached
Evidence:
Comments:
Status:
Date
Completed:
☐ Approved ☐ Suspended
Year 3
Evaluator:
Attached
Evidence:
Comments:
Status:
Date
Completed:
☐ Approved ☐ Suspended
Revision Date:
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Document #
Published Revision: