Q. What is BAN doing?
A. BAN is fully integrating and incorporating the R2 Practices into the e-Stewards Standard. This will be done in two stages. First, before the release of e-Stewards Version 2.0 the action will be taken by virtue of Sanctioned Interpretation #9 which requires all CBs to ensure that all requirements of the R2 Practices are now requirements of the e-Stewards Standard. Second, in Version 2.0 we will be ensuring greater harmonization in the actual e-Stewards Version 2.0 text and including the full text of the R2 Standard as an annex. It again will be up to the e-Stewards auditor to ensure conformity with all requirements of the R2 and e-Stewards Standard. Already, CBs have conducted integrated audits and are fully aware of the differences and how to accomplish the integrated audits. By now conducting automatic integrated audits, e-Stewards will get three certifications from one audit.
Q. Why is BAN doing this?
A. BAN has observed that despite R2 largely being a subset of the more comprehensive and rigorous e-Stewards Standard, diverse market forces have convinced some recyclers to incur significant cost to undergo both the e-Stewards and the R2 Certification. We see no problem with certification to both standards as long as the more rigorous and comprehensive performance requirements of the e-Stewards Standard are the primary basis of any “packaged deal.” Indeed, we believe providing a packaged deal in this way, utilizing one program administrator for both standards and one simultaneous audit, will reduce costs in terms of deliverables and become an incentive for more companies to subscribe to the e-Stewards Standard – the most environmentally and socially rigorous standard.
Q. Doesn’t this legitimize R2, a standard which BAN has criticized as being too weak?
A. This action makes it very clear that R2 is a subset of the e-Stewards Standard and should not stand alone. R2 by itself is inadequate to the task of identifying globally responsible recyclers. The e-Stewards Certification program is the best tool for doing that and will continue to provide the gold standard. The main provisions of R2 have always existed in the e-Stewards Standard in an equivalent or more rigorous manner but recyclers have had difficulty communicating that fact to customers. Our action removes this doubt while allowing companies that want both Certifications to do so at a very reasonable cost.
Q. Is BAN offering one standard or three different standards?
A. We are offering one e-Stewards Standard. But e-Stewards now will contain within it two other standards, ISO 14001 and R2. Because of that, recyclers can actually receive three certificates from one audit to emphasize the breadth of their certification.
Q. Is it optional for CBs or recyclers to include R2 in the audit?
A. No, it is not optional for CBs since the R2 requirements are now part of the e-Stewards Standard. However it is optional for a recycler to receive the R2 certificate in addition to the e-Stewards and ISO 14001 certificates.
Q. How can BAN claim ownership of the R2 Standard? I thought it was owned by R2 Solutions.
A. R2 was always designed to be an open source standard. The only stipulation placed upon it is found in its title, “for use in Accredited Certification Programs.” R2 Solutions has been created to manage and resolve issues related to R2 certification but they have no unique rights to its use in industry.
Q. R2 Solutions is planning to upgrade the R2 Practices later this year. Will BAN incorporate the changes made at that time?
A. We plan to do so. Now that BAN is a program administrator for R2 as it exists within the e-Stewards Standard, we hope to take a more active role working with R2 Solutions and others in assuring increased harmony between the two standards.
Q. Will the e-Stewards Certification cost more than before as a result of the R2 integration?
A. There will be no added costs for the license and marketing fees currently collected by BAN to administer and promote the program. With respect to audit costs, that will be up to the Certifying Bodies. To date, however, the three Certifying Bodies accredited to audit to both standards report little or no additional cost for adding R2 to an e-Stewards audit. However, independent of the decision to integrate R2 into e-Stewards certification, BAN increased the minimum time for a full e-Stewards audit by 15% to ensure a proper audit of Version 2.0 of the e-Stewards Standard, due for release this spring.
Q. There are two different ANAB Accreditation Rules (#33 and #34) that apply to e-Stewards and R2 certifications, respectively. Which one will now apply?
A. At present, both accreditation rules will apply and where conflicts exist, Certification Bodies must follow the more stringent of the two. BAN will work diligently with ANAB and R2 Solutions as necessary to make these rules more coherently applied to CBs in their integrated audits.