SERI releases R2 Standard Provision 11 guidance

Provision 11 covers insurance, closure plan and financial responsibility.


Boulder, Colorado-based SERI, the housing body and ANSI-accredited standards development organization for the R2 (Responsible Recycling Practices) Standard, has published updated guidance to support the implementation and auditing of Provision 11 (Insurance, Closure Plan and Financial Responsibility) in the R2 Guidance Document, which can be found in R2 Document Library section of the SERI website. 

This new guidance replaces the prior Provision 11 guidance contained in the Sept. 1, 2014, version of the R2 Guidance Document.

The new content was developed by the R2 Technical Advisory Committee (TAC). Some notable changes and clarifications to the guidance, according to SERI, are:

  • guidance on pollution liability insurance and how to determine if it is needed;
  • parameters for using pollution liability insurance as a sufficient financial instrument for closure;
  • parameters for using a corporate guarantee as a sufficient financial instrument for closure;
  • parameters for using noninventory assets as a sufficient financial instrument for closure;
  • the role of the Independent Administrator; and
  • how to calculate estimated closure costs.

The R2 Guidance Document is intended to offer further explanation of complex requirements in the R2 Standard and may also include examples and audit recommendations. However, guidance itself is not auditable and cannot be cited in relation to any nonconformances, SERI says. The explanations in the Guidance Document are intended to prevent misinterpretation of the R2 Standard; they are not intended to add to, subtract from or modify the R2 Standard. The examples cited are not necessarily the only way to fulfill a requirement of the R2 Standard, the nonprofit says.