Provision 5: Focus Materials

Question 1

Provision 5

Focus Materials

Answer 1

An R2:2013 electronics recycler shall manage – both on-site and in the selection of downstream vendors – the Focus Materials that pass through its facility or control in a manner protective of worker health and safety, public health, and the environment. An R2 electronics recycler also shall perform due diligence on downstream vendors to which it ships. these materials.

Question 2

Requirement:
Development and Adherence to an FM Management Plan
(Section a)

Answer 2

An R2:2013 electronics recycler shall analyze, plan, regularly review, and update as necessary
how the FMs that pass through its facility or control will be properly managed both on-site and down the Recycling Chain (and include this analysis and plan as the “FM Management Plan” section of its EHSMS). The FM Management Plan shall state how the recycler and its downstream vendors shall conform to the requirements set forth in the rest of this Provision 5.

Question 3

Requirement:
Removal of FMs
(Section b)

Answer 3

Prior to shredding or materials recovery of equipment or components, FMs (as well as print cartridges) shall be removed using safe and effective mechanical processing or manual dismantling.

Question 4

(Subsection 1)
Exception to this requirement:
Items containing mercury if:

Answer 4

(A) They are too small to remove safely at reasonable cost, and
(B) Workers are protected from the potential risks of handling mercury, and
(C) The materials recovery occurs in facilities that meet all applicable regulatory requirements to receive and process mercury, and that use technology designed to safely and effectively manage equipment or components containing mercury.

Question 5

(Subsection 2)
Exception to this requirement:
CRTs, Batteries, and Circuit boards contained in equipment or components destined for materials recover

Answer 5

CRTs, batteries, and circuit boards contained in equipment or components destined for
materials recovery need not be removed prior to shredding and/or materials recovery if the
shredding and/or materials recovery occurs in facilities that meet all applicable regulatory requirements to receive these FMs, and that use technology designed to safely and effectively manage equipment or components containing these FMs.

Question 6

Requirement:
Processing, Recovery, and Treatment of FMs
(Section c)

Answer 6

An R2:2013 electronics recycler shall send removed FMs to processing, recovery, or treatment facilities that meet all applicable regulatory requirements to receive the FMs, and that use technology designed and operated to safely and effectively manage the FMs This shall include:.

Question 7

(Subsection 1)

Answer 7

For items containing mercury – mercury retorting or other legal methods, excluding incineration

Question 8

(Subsection 2)

Answer 8

For circuit boards - removal of batteries and mercury, and processing for metals recovery

Question 9

(Subsection 3)

Answer 9

For items containing polychlorinated biphenyls (PCBs) - Technology specifically designed for PCB destruction, occurring in facilities that meet all applicable regulatory requirements, and that use technology designed to safely and effectively manage equipment or components.
containing these FMs.

Question 10

Requirement:
Prohibition on Energy Recovery, Incineration, and Land Disposal of FMs
(Section d)

Answer 10

An R2:2013 electronics recycler shall not use energy recovery, incineration, or land disposal as a
management strategy for FMs or equipment and components containing FMs unless applicable
law requires the use of a specific technology (e.g., thermal destruction of PCBs). However, if documented extreme and rare circumstances beyond the control of the R2:2013 electronics recycler disrupts its normal management of an FM, it may consider using these technologies to
the extent allowed under applicable law until normal management is again possible

Question 11

Requirement:
Selection and Ongoing Due Diligence of Downstream Vendors for FMs
(Section e)

Answer 11

For shipments of removed FMs, and shipments of equipment and components containing FMs, an
R2:2013 electronics recycler shall select both domestic and international downstream vendors that:

Question 12

(Subsection 1)

Answer 12

Conform to the R2:2013 electronics recycler’s FM Management Plan (developed in accordance with and including the requirements.

Question 13

(Subsection 2)

Answer 13

Adhere to a documented system to manage environmental, health, and safety risks and legal
requirements. The management system shall include at a minimum the components of Provision 3 (Legal Requirements and Provision 4 (On-Site Environmental, Health, and Safety),

Question 14

(Subsection 3)

Answer 14

Comply with all applicable environmental and health and safety legal requirements and maintain a current list of its environmental permits and copies of each

Question 15

(Subsection 4)

Answer 15

Conform to this Section (e) and Section (f) below, or allow the R2:2013 electronics recycler to confirm this information with each of its relevant downstream vendors, thereby establishing that each facility in the Recycling Chain conforms to these subsections

Question 16

(Subsection 5)

Answer 16

Conform to Provision 6 (Reuse), if applicable

Question 17

(Subsection 6)

Answer 17

Conform to Provision 7 (Tracking Throughput), documenting the flow of all FMs down the
Recycling Chain

Question 18

(subsection 7)

Answer 18

Conform to Provision 10 (Physical Security), ensuring security of the equipment down the
recycling chain.

Question 19

Requirement:

Section f

Answer 19

An R2:2013 electronics recycler shall confirm at least annually and document, through audits or other similarly effective means that each downstream facility to which Section (e) applies continues to conform to the requirements of Section (e) for as long as it receives FMs directly or indirectly from the R2:2013 electronics recycler.

Question 20

(Section g)

If the R2:2013 electronics recycler uses an R2:2013 certified downstream facility:

Answer 20

Then verification of conformance to 5(e)(1) and 5(e)(6) satisfies the due diligence requirements of 5(e)
and 5(f).

Question 21

Requirement:
Non-Focus Materials Requiring Specific Management
(Section h)

Answer 21

An R2:2013 electronics recycler shall manage print cartridges in accordance with Provision 2 through print cartridge remanufacturers, recyclers, or Original Equipment Manufacturers (OEM), in facilities that meet all applicable regulatory requirements to receive these print cartridges, and 8. The R2:2013 electronics recycler is only responsible for due diligence related to the Focus Materials shipped by the R2:2013 electronics recycler. That use technology designed to safely and effectively manage print cartridges, including both ink
and toner.