Q. IF AN R2 FACILITY SENDS ELECTRONIC EQUIPMENT CAPABLE OF REUSE TO AN R2 DOWNSTREAM VENDOR FOR TESTING, REPAIR, AND LOGICAL SANITIZATION, DOES THE R2 DOWNSTREAM VENDOR ALSO NEED TO BE CERTIFIED TO APPENDIX B FOR PHYSICAL SANITIZATION JUST IN CASE SOME OF THE DEVICES FAIL LOGICAL SANITIZATION? 

A. ​ The short answer is no:

If an R2 downstream vendor is only being contracted to test, repair, and logically sanitize devices; they are not being contracted to conduct physical sanitization.  However, part of the R2 downstream vendor’s process will be to ensure that the physical sanitization does get carried out by a DSV that meets the requirements of Appendix B for physical sanitization.    

The R2 downstream vendor doing the test, repair and logical sanitization would not need to be certified to Appendix B (physical) in order to receive electronic equipment capable of reuse from a certified R2 Facility.  An R2 downstream vendor would need to be certified to Appendix A, Appendix B (logical), and Appendix C (test and repair) to receive electronic equipment for testing, repair, and logical sanitization.  If some of the electronic equipment destined for reuse fail logical data sanitization, then those failed devices would need to be sent to a downstream vendor with the capability to perform physical data destruction and also meet the downstream vendor qualifications in Appendix A(7) for an R2 downstream, or Appendix A (8)(a-d) for a non-R2 downstream. 

The intention of specifying “logical” and/or “physical” capabilities for R2 Facilities certifying to Appendix B was to adapt to the specialization within the industry and allow R2 Facilities to tailor their certification based on the specific processes performed.    It was not the intention that every facility certified to Appendix B (logical) must also certify to Appendix B (physical) just in case logical sanitization fails.  That would essentially eliminate the intended benefit of the logical-only and physical-only specializations within Appendix B. 

It is important to keep in mind, however, that different DSV qualifications are needed when a certified R2 Facility sends end-of-life electronics, equipment not capable of reuse, for the purpose of physical data sanitization and materials recovery.   In this case, the DSV must be qualified to perform physical data sanitization in accordance with the downstream vendor qualifications in Appendix A(7) or A(8), respectively depending on whether they are R2 Certified or not.