SERI has begun conducting surprise audits of R2-certified facilities, with auditors concentrating on downstream due diligence and other topics of concern.

Sustainable Electronics Recycling International (SERI), the Boulder, Colo.-based nonprofit organization managing the R2 e-scrap environmental standard, began conducting spot – or unannounced – audits of facilities in mid-August. So far, it has conducted about a dozen.

“We see them in large part as an effort in continuous improvement, but, of course, we’re very much wanting to take action where we find that the standard is not being complied with,” John Lingelbach, executive director of SERI, told E-Scrap News.

The spot audits are different from the witness audits the group started conducting earlier this year, where a SERI representative and a certifying auditor would visit facilities together.

So far, one SERI staff member and one contractor have been conducting the spot audits of facilities. They’re focusing on major issues of concern, such as whether facilities are doing their due diligence in ensuring downstream vendors are responsibly managing “focus materials,” including CRT glass, mercury, PCBs, lead from circuit boards and batteries, Lingelbach said. Another aim is ensuring companies have plans and financial instruments in place to deal with material if the facility is abandoned, he said.

“The majority of the facilities that we’ve done spot audits on are doing well in those regards,” he said. “But what I want to emphasize is that those are the areas where we have the most concern.”

When serious shortcomings are found, which has only happened in a “distinct minority of the cases,” the issues are reported to the certifying body for follow-up, he said.

SERI started doing the spot audits using a framework that gave companies 24 hours notice, and the group has since moved to conducting them entirely unannounced.

SERI hopes to aggregate data to get a clearer picture of the most challenging compliance areas of the R2 Standard. Lingelbach said downstream due diligence seems to be the most time-consuming component of compliance for certified companies right now.

“That’s new to the industry. Four, five or six years ago, not a lot of companies spent a lot of time checking out their downstream vendors in any concerted manner and one of the things the standard requires is they do that.”

SERI staff are still working on putting together next year’s budget, but it appears they might be able to conduct up to 50 spot audits next year, he said.