R2 Conformity review

Conformity review:  Maintaining conformance on an ongoing basis

Conformity review is a monthly column highlighting important operational information
concerning the R2 Standard

One limitation of any audit-based certification program is that the audit only
provides a snapshot of the system in place at the time of the audit.  Over
time, a recycler can fall out of conformance but continue operating under the
certification label.  One mechanism that mitigates against this is the annual
maintenance audit which is required to maintain certification.  While this
annual, independent third-party verification is important, it still cannot offer
insight into the practices of the facility on a day-to-day basis.  For this
we must rely on certified recyclers to continue self-monitoring conformance on
an ongoing basis.

     The stakeholders that developed the Standard wanted to
ensure that the principles of the Standard could be, and would be, applied daily. 
To do this, the Standard requires monitoring, benchmarking, and continually improving
by means of these internal controls:

• The EHSMS, which is to be reviewed regularly, and be based on a “Plan-Do-Check-Act”
model for continuous improvement.  [Provision 1(a)(2)]

• Periodic evaluation of compliance with all legal requirements to protect
environmental and worker safety. [Provision 3(a)(1)]

• Continuous hazards identification and assessment of occupational and environmental
risks. [Provision 4(c)].

• Monitoring and sampling protocols to manage any hazard risks that have
been identified.  [Provision 4(e)].

• Confirmation through audit or similarly effective means that downstream
vendors conform to the Focus Material requirements each time a new downstream
vendor is selected. [Provision 5(f)].

• Regular review and validation of data destruction procedures by an independent
party. [Provision 8(d)].

During the audit process, the recyclers have to produce their plan for regularly
carrying out the described monitoring and conformance checks.  So while it
is the auditor’s job to determine the recycler is operating in accordance to the
R2 Standard’s requirements at the time of review, it is the expectation that the
recycler continues to actively monitor all operational areas on an ongoing basis,
and address any discovered non-conformances immediately.