Ballot Details: Approval of Ballot - 426i1r1 - New Standard (CLOSED)

Ballot Instructions

Please view the PDF file only when viewing the ballot document.

Ballot Question Should Ballot - 426i1r1 - New Standard be approved?
Ballot Description Enclosed for your review is the draft of NSF 426 Environmental Leadership Standard for Servers, issue 1, revision 1. Please review the ballot for this standard and submit your vote by the ballot due date of May 19, 2015 via the online workspace (http://standards.nsf.org).

Each Joint Committee member will vote affirmative, abstain, or negative with comment. Each negative vote must be justified in the comment section. Please include exactly why you oppose and what changes must be made in order for you to support the proposed draft.

Comments submitted during the balloting period, as well as the public comment period, will be responded to in writing. New substantive issues will be brought forward to the Joint Committee during a revision ballot (if applicable).

A copy of the NSF International Standard Development and Maintenance Policies are available here for further information on the process.

Webinar:
There will be a webinar open to all interested stakeholders on May 5th, 2015 at 11am EDT, to review the draft standard and answer questions. The meeting registration is available here.

Please note that NSF and IEEE discussions continue on a joint environmental leadership standard for servers. NSF remains fully committed to a positive outcome from these deliberations. In the interim, both Standards Development Organizations continue to work on their respective processes per their mutual agreement when the negotiations began.

Purpose
The purpose of this ballot is to create a new standard for servers that addresses product environmental performance criteria and corporate performance metrics that exemplify environmental leadership in the market.
Ballot Options
VOTING CLOSED: Friday, 22 May 2015 @ 11:59 pm EDT
Affirmative 22 91.667
Negative w/comment 2 8.333
Abstain 1
Document for Approval JC Memo and Ballot - 426i1r1 - New Standard.pdf (Document Details)
Open Date Friday, 17 April 2015 @ 12:45 pm EDT
Close Date Friday, 22 May 2015 @ 11:59 pm EDT
Ballot Type Official, as defined by organization policies and procedures

Voting Statistics

Number of votes cast (excluding abstentions) 24
Eligible members who have voted 25 of 32 78.125%
Eligible members who have not voted 7 of 32 21.875%

Voting Summary by Option

Options with highest number of votes are bold
Option # Votes % of Total
Affirmative 22 91.667%
Negative w/comment 2 8.333%
Abstain 1

Voting Summary by Interest Category

Interest Category Affirmative Negative w/comment Abstain Not Returned Total
Academia / NGO 0 0 0 0 0 (0%)
Distributor 0 0 0 0 0 (0%)
Emeritus 0 0 0 0 0 (0%)
Fabricator/Formulator 0 0 0 0 0 (0%)
General Interest 0 0 0 0 0 (0%)
Government 0 0 0 0 0 (0%)
Industry 5 1 1 5 12 (37.5%)
Ingredient Supplier 0 0 0 0 0 (0%)
Manufacturer Processes 0 0 0 0 0 (0%)
Medicine/Health 0 0 0 0 0 (0%)
Non-voting Liaison 0 0 0 0 0 (0%)
Other 0 0 0 0 0 (0%)
Practitioner/Service Provider 0 0 0 0 0 (0%)
Product Certifier / Testing Lab 0 0 0 0 0 (0%)
Public Health / Regulatory 10 0 0 2 12 (37.5%)
Trade Association 0 0 0 0 0 (0%)
User 7 1 0 0 8 (25%)
Water Utility 0 0 0 0 0 (0%)
Not Specified 0 0 0 0 0 (0%)
Total 22 2 1 7 32 (100%)

Voting Details

Voter Name Company Category Vote * Time (UTC) Comments
* Baxter, William Consultant - User User Affirmative 2015-05-18 18:54:00
* Berard, Cate US Department of Energy Public Health / Regulatory Affirmative 2015-05-21 18:52:00
* Bock, Geoffrey TUV Rheinland of North America User Affirmative 2015-04-17 17:32:00
* Booth, John CARBON3IT Ltd User Affirmative 2015-05-14 09:43:00
* Delforge, Pierre NRDC Public Health / Regulatory Affirmative 2015-05-05 15:33:00
* Elwood, Holly U.S. Environmental Protection Agency Public Health / Regulatory Affirmative 2015-05-18 14:57:00
* Ewell, James Green Blue Institute (GreenBlue) Public Health / Regulatory Affirmative 2015-05-13 17:45:00
* Ferhut, Fareed California EPA - Department of Resources R... Public Health / Regulatory Affirmative 2015-04-17 18:33:00
* Kyle, Barbara Electronics TakeBack Coalition Public Health / Regulatory Affirmative 2015-05-14 16:01:00
* Liu, Jinshui Huawei Industry Affirmative 2015-05-22 17:31:00
* Magalini, Federico Cyrcle Consulting/UN University Public Health / Regulatory Affirmative 2015-04-22 06:48:00
* Martin, Brian Seagate Technology Industry Affirmative 2015-05-22 15:55:00
* Nikolayev, Dmitriy Commonwealth of MA User Affirmative 2015-05-01 19:38:00
* Parkinson, Paul In Win Developments Industry Affirmative 2015-05-22 14:00:00
* Peters-Michaud, Neil Cascade Asset Management Industry Affirmative 2015-05-22 20:56:00
* Rifer, Wayne Green Electronics Council User Affirmative 2015-05-21 20:00:00
* Rubinstein, Lynn Northeast Recycling Council, Inc. (NERC) Public Health / Regulatory Affirmative 2015-04-28 09:38:00
* Samborski, John Ace Computers Industry Affirmative 2015-05-22 20:42:00
* Thompson, Cortney Green House Data - Data Center Operations User Affirmative 2015-05-18 04:45:00
* Westervelt, Sarah Basel Action Network Public Health / Regulatory Affirmative 2015-05-14 18:22:00
* Wood, Jonathan Department of the Environment Food and Rur... Public Health / Regulatory Affirmative 2015-05-19 13:59:00
* Zavatson, Dave University of California User Affirmative 2015-05-15 15:31:00
* Buoniconti, Ralph SABIC Industry Negative w/comment 2015-05-22 13:40:00
* Hoffman, William Underwriters Laboratories, Inc. User Negative w/comment 2015-05-22 20:23:00
* Ho, Catherine Koi Computers, Inc. Industry Abstain 2015-05-22 16:57:00
* Hopton, Peter Iceotope Industry --
* Lin, Jennie ASUSTek Computer Inc. Industry --
* Ma, Hsien-Chen (Jason) ITRI Industry --
* Morimoto, Michael US General Services Administration Public Health / Regulatory --
* Paolucci, Steve Polyone Corporation Industry --
* SN Lin, Patrick Wistron Corporation Green Recycling Busine... Industry --
* Zhao, Fu Purdue University Public Health / Regulatory --

Voter Comments Collected During Ballot Voting

   All Document Comments    Voter Comments
Submitter Subject Comment, Proposal, and Response Status(Resolution)
Peters-Michaud, Neil - Cascade Asset Management

I do support all the requirements (and optional points) of this standard.  At the same time, this standard is very comprehensive and fairly complex which ...

New
Wood, Jonathan - Department of the Environment Food and Rural Affairs (DEFRA) UK

Ideally would like to see it as a pre-requisite for bronze.


Include crtierion for bronze level.

New
Wood, Jonathan - Department of the Environment Food and Rural Affairs (DEFRA) UK

Drafting point: The numbering in Annex A refers to 9.2.1 'Reduction of materials incompatible with recycling', which doesn't appear in the document.


Include 9.2.1

New
Wood, Jonathan - Department of the Environment Food and Rural Affairs (DEFRA) UK

How does the ILCD 2011 methodology relate to the European Commission's further development of PEF methodologies and the IT equipment pilot currently runni...

New
Wood, Jonathan - Department of the Environment Food and Rural Affairs (DEFRA) UK

However, there are differences between the categories in 12.1.1 and in 12.2.1, where energy recovery and disposal are separated.  In addition, should ther...

New
Wood, Jonathan - Department of the Environment Food and Rural Affairs (DEFRA) UK

The batteries Directive also contains labelling requirements. Could these be included?


Include labelling requirements. 

New
Wood, Jonathan - Department of the Environment Food and Rural Affairs (DEFRA) UK

Criteria could be included on power management such as: default enabling, presence of remote power management capability, latency and stability requiremen...

New
Wood, Jonathan - Department of the Environment Food and Rural Affairs (DEFRA) UK

The product longevity section is not sufficiently ambitious could be expanded, for example address software considerations:



Availability of firmwa...

New
Rifer, Wayne - Green Electronics Council

Please see the attached file for comments on several sections.

New
Rifer, Wayne - Green Electronics Council

Comments on several sections in attached file

New
Rifer, Wayne - Green Electronics Council

7.2.2 asks for documentation to be provided (for verification) but only states that the disk drive supplier must confirm that the drive contains PCR REE m...


In the second sentence of the criterion add, after the words "Manufacturer shall provide documentation ...",  the following words "containing evidence (i....

New
Liu, Jinshui - Huawei

Current statement:



Countries or regions that are not ENERGY STAR international partners --



? Product shall conform with the current versio...


For Countries or regions that are not ENERGY STAR international partners, change the Energy Efficiency prerequisite to:



? Product shall conform wi...

New
Liu, Jinshui - Huawei

As Energy Star has already included 80 Plus Power certification and Rating, thus suggest to remove duplicated 80 Plus certification from EPAT by making th...


The product shall include power supplies meeting the requirements in Table 5.3 below. Manufacturer may claim the points associated with only one 80 Plus l...

New
Liu, Jinshui - Huawei

As HVDC reduces power conversion and is attracting a lot of interests, would suggest adding 240VDC/400VDC to Table 5.4 with Point value of 4.

New
Parkinson, Paul - In Win Developments

It was discussed in the development of this criteria that cables cannot be manufactured using recycled plastic and achieve a safety approval from UL speci...


It is suggested that like the printed circuit boards, cables should be added to the parts that are excluded from the calculation. 

New
Ho, Catherine - Koi Computers, Inc.

We are a system integrator that configures white box systems.  In reviewing the proposed standards, sections such as 5, 6, 7 will depend on the manufactur...

New
Buoniconti, Ralph - SABIC

With the very large number of substances on lists in this standard (RoHS, REACH, and Annex C), this section, as a prerequisite, needs modification or elim...


This section should be deleted.  However, if consensus cannot be reached, this section should be optional and consideration should be given to wiring and ...

New
Buoniconti, Ralph - SABIC

The request is knowingly being made for proprietary formulation information, specifically for individual substances with their masses


Consider eliminating the request for individual masses of each substance.  If less that 100% of substances are disclosed, request that a total mass percen...

New
Buoniconti, Ralph - SABIC

Disclosure of all ingredients does not provide any human health nor environmental benefits beyond what is already found in Section 6 and in other parts of...


I recommend deleting 6.3.3 and re-evaluating the need for 6.3.2 in this standard.  If 6.3.3 remains in the standard, then change the ?5% by mass? to ?10% ...

New
Buoniconti, Ralph - SABIC

This section needs re-thinking.The huge number of substances on the lists with no reference at all to concentrations can easily lead to needless and facet...


Eliminate or add some reference to concentration levels to avoid meaningless LCAs.

New
Buoniconti, Ralph - SABIC

A minimum percentage of PCR for only one class of materials is unfair.  Many discussions during the Joint Committee meetings revolved around the assumptio...


I suggest following the structure of other sustainability standards (such as IEEE 1680.1) that set no minimum PCR requirements, but rather ...

New
Buoniconti, Ralph - SABIC

Due to the number of comments and rationale provied by our experts, I have included both comments and recommendations here and in the Proposed Solution se...


Due to the number of comments and rationale provied by our experts, I have included both comments and recommendations here and in the Comment section:

...

New
Elwood, Holly - U.S. Environmental Protection Agency

Please refer to the attachment for the details of my suggested comments.

New
Hoffman, William - Underwriters Laboratories, Inc.

The current definition is vague and open to interpretation.  By removing ?widely used? and ?readily? the definition is much easier to interpret.


Should read, ?A tool which is available for purchase by any individual or business without restriction.?

New
Hoffman, William - Underwriters Laboratories, Inc.

Having ?necessary to the functionality or production of that product? in the definition adds unnecessary complications to assessing compliance.  If a manu...


Delete ?necessary to the functionality or production of that product? from the definition.

New
Hoffman, William - Underwriters Laboratories, Inc.

The criterion borders on commercial terms but does allow for meeting the requirements of the 80 Plus program.   In addition the wording ?or shall meet the...


Rewrite the first sentence to read:



"Points are awarded as described in Table 5.3 for products which include power supplies meeting the requiremen...

New
Hoffman, William - Underwriters Laboratories, Inc.

While logging the parameters included in the this criterion would appear to be feasable there is an interaction between the OS and the hardware which is r...


Unfortunatly there isn't a direct easy way to rewrite the criterion to solve this issue.  I'd suggest rewriting the criterion to include hardware capabili...

New
Hoffman, William - Underwriters Laboratories, Inc.

The criterion as written today would include the PWB which is a Brominated polymer.  This may have the unintended consequence of limiting the use of high ...


Either exclude the PWB or add "when fire and/or electrical safety requires the use of a brominated or chlorinated material to achieve the required level o...

New
Hoffman, William - Underwriters Laboratories, Inc.

The test method specified is intended for testing of waste materials not specifically electronics.  Instead IEC 62321 and parts should be specified or at ...


Replace EN14582 with IEC 62321 or add IEC 62321 and parts as an alternative test method.

New
Hoffman, William - Underwriters Laboratories, Inc.

Since the criteria specifically refers to the EU guidance document and includes that document as part of the criterion by reference, ?Guidance on requirem...


Add a reference and link to the guidance document.

New
Hoffman, William - Underwriters Laboratories, Inc.

References to EPA should include US EPA since this standard intended to be used internationally.


Every use of EPA should be replaced with U.S. EPA

New
Hoffman, William - Underwriters Laboratories, Inc.

The last bullet allowing for a material with lower environmental impact seems like a loophole to allow any material.  Virgin aluminum is one of the most e...


The last bullet, "- A material demonstrated to have lower environmental impact than those listed above based on an LCA conducted in accordance with criter...

New
Hoffman, William - Underwriters Laboratories, Inc.

The second paragraph starting with ?The Global Protocol?..? should be clearly labeled as a non-normative


Add ?Note:? to be beginning of the paragraph or use some other way to clarify that this is non-normative.

New
Hoffman, William - Underwriters Laboratories, Inc.

in the fourth bulles (page 31) the phrase, "unless required for technical or safety reasons." is rather open to interpretation.  what constitues a valid t...


replace the phrase,"unless required for technical or safety reasons.", with "unless required as part of compliance with safety regulations, safety standar...

New
Hoffman, William - Underwriters Laboratories, Inc.

the prase "same material type" should be defined.


Use the phrase "compatible or compatible with limitations " and reference

the phrase "at the time of assessment ...

New
Hoffman, William - Underwriters Laboratories, Inc.

This criterion would seem in part to be redundant with the collection of efficiency data as part of earlier criterion.  In addition the software tools req...

New
Hoffman, William - Underwriters Laboratories, Inc.

the consultation has to be performed by a certified recycler but also a note at the end of the criterion would indicate an "eco-design consultant" may als...


The bullet should  be struck or additional clarity on what constitutes an acceptible deisgn improvement added. 

New
Hoffman, William - Underwriters Laboratories, Inc.

the final boxes are not the % mass of .... but are the mass of .....



Each of the boxes should have the % struck.

New
Berard, Cate - US Department of Energy

Scope 2 GHG emissions should not be limited to purchased electricity, and should be aligned with GRI definitions.


Change to "Scope 2 = Purchased electricity, heating, cooling, and steam"

New
Berard, Cate - US Department of Energy

Table heading and indicator titles in Table 13.1should align with the GRI G4 titles to avoid confusion with G3 titles. New titles have "G4" in the indicat...


Change header to "GRI Indicator Code" and each line item to include the G4 prefix: G4-EN4, G4-EN5, G4-EN6, etc.

New
Berard, Cate - US Department of Energy

Differences between 13.2.2 and 13.2.3 aren't immediately obvious based on titles; 13.2.2 is missing "reporting."


Change 13.2.2 to "Environmental and social responsibility reporting on top nine suppliers (corporate)" (note that the word reporting should be added)


...

New
Berard, Cate - US Department of Energy

The definition of reuse should not be limited to the "originally intended purposes." Reuse should include reuse for either the originally intended or a re...


Change to "Reuse: Using again, equipment or components for the originally intended purpose, a similar purpose, or in an upgraded state, p...

New
Berard, Cate - US Department of Energy

The definition of treatment should not include disposal. Disposal is separate and distinct from treatment in the U.S.


Change to: "Treatment: Material recovery or material handling operations including preparation prior to recovery or disposal."



No...

New
Berard, Cate - US Department of Energy

The definition of disposal should include spills, leaks and releases. "Deposits" may not be broad enough to address spills, leaks and relases, dumping, ab...


Change to: "Disposal: Any operation which does not lead to materials recovery, recycling, reclamation, or reuse of equipment or component...

New
Berard, Cate - US Department of Energy

There are multiple phrases used throughout the standard to describe requirements to disclose on a public website.  Examples include ?publicly disclosed on...


The JC should develop two phrases: one for public websites (not otherwise specified) and one for specifically the manufacturer?s public website, and use t...

New
Berard, Cate - US Department of Energy

The definition for "recyclable" provides that materials or components can be declared recyclable "using standard technologies, or as otherwise demonstrate...


Delete "or as otherwise demonstrated" or clarify who can demonstrate this - independent recyclers?

New
Berard, Cate - US Department of Energy

The text of criterion 5.3.2 includes the explanatory language "to reduce energy loss from power conversion during distribution and provide an overall high...


Delete "to reduce energy loss from power conversion during distribution and provide an overall higher system efficiency"

New
Berard, Cate - US Department of Energy

Criterion 5.3.2 says "The product shall be tested using the methodology specified in the ENERGY STAR Program Requirements for Computer Servers."  Recommen...


Revise to "...ENERGY STAR Program Requirements for Computer Servers Version 2.0."

New
Berard, Cate - US Department of Energy

Criterion 5.3.2 says "The product shall be tested using the methodology specified in the ENERGY STAR Program Requirements for Computer Servers."  Tested f...


Clarify test methodology and purpose.  If the intention is to ensure that qualification/certification testing for ENERGY STAR (needed for criterion 5.1.1)...

New
Berard, Cate - US Department of Energy

Criterion 6.1.3 and 6.2.1 refer to "supply chain management process" and "supply chain management system," respectively.  If these are the same thing, rec...


Review and determine if same process/system is required by both criteria.  If so, use one term, define it; and make language consistent across both criter...

New
Berard, Cate - US Department of Energy

Criterion 8.3.1b says "If the amount of packaging material is reduced due to the use of an alternative material, the manufacturer must demonstrate a net r...


Review and determine which process is applicable (LCA methodology in 11.2.1 or alternatives assessment in 6.3.4).  Require use of appropriate process to d...

New
Berard, Cate - US Department of Energy

Criterion 8.3.1b says "Manufacturer shall document at least a 10% reduction in the amount of packaging materials used in the delivery of the product. Tabl...


Clarify the minimum performance required to claim the reuse rate point.  Is it a reduction in single use packages?  If so, the metric in Table 8.3 must be...

New
Berard, Cate - US Department of Energy

Criterion 9.1.3 says "Determination of the recyclability rate shall start with the receipt of the untreated waste equipment (if beyond reuse) and end when...


If the idea of "end-of-waste status for fractions is achieved" is from IEC TR62635, recommend adding to that sentence "as required in IEC TR62635" or some...

New
Berard, Cate - US Department of Energy

Criteria 12.1.1, 12.1.3 and 12.2.1 require the manufacturer to obtain/maintain/provide "objective evidence."  This seems like an odd and unnecessary term....


Delete the term "objective."

New
Berard, Cate - US Department of Energy

The second bullet in criterion 12.1.3 implies that the manufacturer's management system applies only to "a manufacturer or its service providers."  Howeve...


The JC should determine, and specify, which actors this criterion applies to.  If it is just manufacturers and its service providers that should be specif...

New
Berard, Cate - US Department of Energy

"Printed circuit board" is not listed alphabetically in the definitions.  Also, 3.46 is missing.


Move "printed circuit board" to the appropriate location, alphabetically.

New
Berard, Cate - US Department of Energy

Criterion 5.1.3 refers to declaration of the "performance tier (Bronze, Silver, or Gold) for the product."  "Performance tier" is not used in the standard...


Change "performance tier" to "level of conformance."

New
Berard, Cate - US Department of Energy

The title "Environmental Leadership Standards For Servers" on page 1 is erroneously pluralized.


Remove extra "s"

New
Berard, Cate - US Department of Energy

Criterion 5.2.1 says "The product shall include power supplies rated through the 80 Plus program and listed on the 80 Plus program and listed on the 80 Pl...


Change to "The product shall include power supplies rated through the 80 Plus program and listed on the 80 Plus program website as certified..."

New
Berard, Cate - US Department of Energy

Criterion 5.3.1 does not specify that the integrated circuits or PCBs must be part of the product meeting the standard.


Change to: "The product shall include integrated circuits or printed circuit boards (PCBs) that are manufactured by at least one supplier..."

New
Berard, Cate - US Department of Energy

Criterion 6.3.1 says "The link to the inventory shall be placed on the product specification or documentation web page." and "The product specification or...


Delete "or documentation."  This will require the manufacture to disclose this inventory on their product specification page, which will be seen by many m...

New
Berard, Cate - US Department of Energy

Criterion 6.4.1 says "This declaration shall be supported with a letter provided by the CPU and, or DRAM supplier."  The language for allow for more than ...


Change to "This declaration shall be supported by one or more letters provided by the compliant CPU and, or DRAM supplier(s)."

New
Berard, Cate - US Department of Energy

Criterion 6.4.1 says "...manufacturers shall demonstrate implementation of such methods (e.g., use of alternatives) to reduce emissions to the extent poss...


If so, change to "...reduce emissions to the maximum extent possible."

New
Berard, Cate - US Department of Energy

Criterion 7.2.2 says "The neodymium or dysprosium shall be provided through the recycling of magnets from used devices."  There are other sources of these...


Remove ""The neodymium or dysprosium shall be provided through the recycling of magnets from used devices." OR Split points to specifcally incentivize rec...

New
Berard, Cate - US Department of Energy

There are a number of criteria (6.2.1, 6.3.4, 8.3.1, 9.1.4, 9.1.5, 10.1.1, 11.2.1, 13.2.2, 13.5.2) which have timeframes associated with required manufact...


Add language to section 4 somewhere (new section?): "Unless otherwise specified in the criterion, products that have been declared as meeting a criterion ...

New
Berard, Cate - US Department of Energy

Criterion 8.3.1c says "A manufacturer may claim 8.3.1c and packaging reuse or use of multipacks (1 point)."  This reads that the point is awarded for this...


Move "(1 point)" to the end of the first sentence in this section.

New
Berard, Cate - US Department of Energy

Criterion 9.1.4 starts "The manufacturer shall publish a manual for third-party reuse and recycling organizations, in at least English, with the informati...


Change to: "The manufacturer shall publish a manual for third-party reuse and recycling organizations, in at least English.  The manual shall be available...

New
Berard, Cate - US Department of Energy

Criterion 9.1.4 requires the specific manual include information about "The different components and materials;"  This seems overly vague.  Is this just a...


Change to "A complete parts, components and materials list"  If needed, additional language on any details required should be added.

New
Berard, Cate - US Department of Energy

Criterion 9.1.4 says "The function specified in the manufacturer?s user manual, repair manual or technical manual should be used to determine original int...


If "manufacturer?s user manual, repair manual or technical manual" is the manual specified by this criterion, change to "The original intended function of...

New
Berard, Cate - US Department of Energy

Criterion 11.2.3 says "One additional point shall be awarded for either of the following qualifying data disclosures."  However, the requirement for the f...


Add to the end of the first paragraph, before the first numbered list: "LCA inventory data can be made publically available either through (1 point):"  (T...

New
Berard, Cate - US Department of Energy

Criterion 11.2.1 says "...either an increase or decrease of 10% or more on any one of the impact assessment categories from the list in 11.2.1)."  This is...


Change to  "...either an increase or decrease of 10% or more on any one of the impact assessment categories listed above)."

New
Berard, Cate - US Department of Energy

Criteria 13.2.2, 13.3, 13.5.1 and 13.5.2 still refer to "primary circuit board."  "Primary circuit board" was removed as a separate definition since it wa...


Change "primary circuit board" to "printed circuit board."

New

Non-Voter Comments Collected During Ballot Voting

   All Document Comments    Voter Comments
Submitter Subject Comment, Proposal, and Response Status(Resolution)
Berthoud, Françoise - CNRS

Sorry to join you so late ! very good work !



1 - I'm surprised that the 80 plus GOLD is not in the prerequired for all servers. I think it should ...

New
Voyles, Stephanie - IPC

It is disingenuous for the NSF to ballot, and subsequently publish, this draft standard given the on-going negotiations regarding duplicative standards. T...


NSF should continue negotiations with IEEE and ANSI and not publish this standard.

New
Voyles, Stephanie - IPC

Although the committee is balanced per NSF definitions, there has been very little industry participation in the development of this standard. I am concer...


NSF should have more representation from server manufacturers on the Joint Committee.

New
Voyles, Stephanie - IPC

Suggested changes underlined/strikethrough:



A thin board made of fiberglass, composite epoxy, or other laminate material with conductive pa...


Suggested changes underlined/strikethrough:



A thin board made of fiberglass, composite epoxy, or other laminate material with conductive pa...

New
Voyles, Stephanie - IPC

Prior to restricting or banning a substance, an alternatives assessment should be conducted in order to ensure the replacement substance is, in fact, bett...


Prior to restricting or banning a substance, an alternatives assessment should be conducted in order to ensure the replacement substance is, in fact, bett...

New
Voyles, Stephanie - IPC

Delete this criteria or require an alternatives assessment (AA) for the six substances restricted under the RoHS Directive to ensure environmental benefit...


Delete this criteria or require an alternatives assessment (AA) for the six substances restricted under the RoHS Directive to ensure environmental benefit...

New
Voyles, Stephanie - IPC

Including language that states the standard will be automatically updated when the regulation is updated removes all control over criteria tied to that re...


Delete text that states the standard will be automatically updated when the regulation is updated.

New
Voyles, Stephanie - IPC

This criteria should be deleted as it does not provide an environmental benefit. As a prerequisite criteria, if this criteria is met it should show a prov...


Delete criteria.

New
Voyles, Stephanie - IPC

The criteria contains an additional requirement to have an ?effective supply chain management process? to maintain and manage the data and requires the ma...


Delete additional requirement to have an ?effective supply chain management process.?

New
Voyles, Stephanie - IPC

Plastic is not predominately used in servers. Therefore, this criteria is arbitrary, unnecessary and should be removed or included as optional. If the rat...


1. Delete criteria.



2. If criteria is kept, make it optional and clarify that printed circuit boards and wire and cable are excluded, consistent w...

New
Voyles, Stephanie - IPC

If this criteria remains in the standard then an optional credit in Section 6.3.4 should be allowed for conducting an alternatives assessment.


Allow optional credit in Section 6.3.4 for conducting an alternatives assessment.

New
Voyles, Stephanie - IPC

This criterion references ?EN 14582.? We assume this means BS EN 14582, Characterization of waste. Halogen and sulfur content. This standard is for charac...


Delete reference to test method.

New
Voyles, Stephanie - IPC

This criteria should be deleted. The EU REACH Regulation does not require manufacturers to remove all SVHCs from their product if that SVHC is present abo...


Delete critiera.

New
Voyles, Stephanie - IPC

Although we believe this criteria should be deleted, if it is maintained, the standard should not require the elimination of substances without first cond...


Criteria should require an alternatives assessment for substances.

New
Voyles, Stephanie - IPC

The criteria contains an additional requirement to have a ?supply chain management system, which may include supplier management and grading procedures, m...


If this criteria is maintained, delete additional requirement to have a supply chain management system.

New
Voyles, Stephanie - IPC

The collection of a full substance inventory is cumbersome and counter-productive to a focus on substances of interest. Keeping an inventory of substances...


Delete criteria.

New
Voyles, Stephanie - IPC

The collection of a full substance inventory is cumbersome and counter-productive to a focus on substances of interest. Keeping an inventory of substances...


Delete criteria.

New
Voyles, Stephanie - IPC

The collection of a full substance inventory is cumbersome and counter-productive to a focus on substances of interest. Keeping an inventory of substances...


Delete criteria.

New
Voyles, Stephanie - IPC

The draft standard should not specify AA test methods. This criteria only lists 2 AA methods that can be used. There is no justification for why these met...


 Add ?or equivalent? or identify a set of criteria for the framework to be used.

New
Voyles, Stephanie - IPC

Alternatives assessment criteria should outline criteria that an AA must include rather than listing specific methods. The standard could then reference s...


Criteria should outline criteria fhat an AA must include.

New
Voyles, Stephanie - IPC

This criteria, as an optional criteria, under values the importance of an AA. All substances required or suggested to be replaced in this standard should ...


All substances required or suggested to be replaced in this standard should undergo and AA.

New
Voyles, Stephanie - IPC

This criteria gives credit for doing an AA for substances listed in Annex C of the standard, yet it fails to address the possibility of a product or manuf...


Manufacturers should be able to receive credit for not having any substances identified in Annex C of the standard in their product or manufacturing proce...

New
Voyles, Stephanie - IPC

Criteria should be worth more points - life cycle assessment is an important, but intensive, endeavor. Awarding more points will encourage companies to pu...


Criteria should be worth more points.

New
Voyles, Stephanie - IPC

Impact assessment methodologies should not be limited to TRACI 2.1, CML 2001, and ILCD 2011.  Other methodologies may exist that provide comparable result...


Add ?or equivalent? or identify the criteria to be included in the methodology.

New
Voyles, Stephanie - IPC

Provide optional points for the implementation of actions to reduce impacts in any of the assessment categories evaluated in the LCA.


Provide optional points for the implementation of actions to reduce impacts in any of the assessment categories evaluated in the LCA.

New
Voyles, Stephanie - IPC

The purpose of the standard states, ?The purpose of this standard for servers is to establish product environmental performance criteria and corporate per...


Conflict minerals, occupational health and safety and labor, and societal issues are outside the scope of environmental leadership and the critieria relat...

New
Voyles, Stephanie - IPC

The atrocities occurring in the DRC and adjacent countries are deplorable. Section 1502 of the Dodd-Frank Act and SEC conflict minerals regulations are co...


Criteria should be deleted.

New
Voyles, Stephanie - IPC

This criteria is outside the scope of this environmental leadership standard and should be deleted. Further, this criteria should not be a prerequisite.


Delete criteria.



Criteria should not be a prerequisite.

New
Voyles, Stephanie - IPC

This criteria is outside the scope of this environmental leadership standard and should be deleted.


Delete critiera.

New
Voyles, Stephanie - IPC

Table 13.1 contains indicators that are not indicative of environmental leadership and therefore should be deleted. These indicators are HR4 Freedom of as...


Delete inappropriate indicators in Table 13.1

New
Voyles, Stephanie - IPC

This criteria is outside the scope of this environmental leadership standard and should be deleted.


Delete criteria.

New
Voyles, Stephanie - IPC

Table 13.2 contains indicators that are not indicative of environmental leadership and therefore should be deleted. These indicators are LA14 Percentage o...


Delete inappropriate indicators from Table 13.2

New
Voyles, Stephanie - IPC

This criteria should be deleted as there is no environmental benefit to reporting Toxic Release inventory (TRI) data from suppliers. The TRI data is alrea...


Delete criteria.

New
Voyles, Stephanie - IPC

This criteria is outside the scope of this environmental leadership standard and should be deleted.


Delete criteria.

New
Voyles, Stephanie - IPC

The atrocities occurring in the DRC and adjacent countries are deplorable. Section 1502 of the Dodd-Frank Act and SEC conflict minerals regulations are co...


Delete criteria.

New
Voyles, Stephanie - IPC

This criteria is outside the scope of this environmental leadership standard and should be deleted.


Delete criteria.

New
Voyles, Stephanie - IPC

The atrocities occurring in the DRC and adjacent countries are deplorable. Section 1502 of the Dodd-Frank Act and SEC conflict minerals regulations are co...


Delete criteria.

New
Voyles, Stephanie - IPC

Although we believe conflict minerals criteria is out of scope of this standard, should the criteria be included, CFSI should not be the only program refe...


Either list other examples of programs that validate smelters or delete reference to CFSI.

New
Voyles, Stephanie - IPC

Although we believe conflict minerals criteria is out of scope of this standard, should the criteria be included, the criteria should not include a requir...


Delete requirement to conduct a third party audit.

New
Voyles, Stephanie - IPC

This criteria is outside the scope of this environmental leadership standard and should be deleted.


Delete criteria.

New
Voyles, Stephanie - IPC

This criteria is outside the scope of this environmental leadership standard and should be deleted.


Delete criteria.

New
Voyles, Stephanie - IPC

The second bullet under #2 of this criteria states that closure of VAP audit report findings must be confirmed. Generally, closure of VAP audit findings i...


Delete requirement that VAP audit findings must be confirmed.

New
Krock, Richard - The Vinyl Institute

General Remarks:  As NSF is aware, IEEE has a parallel effort underway that involves many server manufacturers and other stakehold...


Merge standard with IEEE 1680.4

New
Krock, Richard - The Vinyl Institute

3 Definitions



 



 



Section 3.39 Plastic:



 


Change to include silicone

New
Krock, Richard - The Vinyl Institute

Please include the comments from the attached file.  Attempts to add individually appear to have failed. Thank you.


See comments.

New
Cleet, Chris - Information Technology Industry Council (ITI)

Please see attached file

New
Risotto, Steve - American Chemistry Council

As a participant in the IEEE 1680.4 Working Group on Environmental Assessment of Servers, the American Chemistry Council (ACC) is concerned that both IEEE...


Continue effort to join NSF and IEEE standard development processes.

New
Risotto, Steve - American Chemistry Council

The proposal for performance requirements for the Silver and Gold performance levels may discourage companies from achieving other aspects of the standard...


The provision should be revised to remove prerequisites for the Silver and Gold levels.



 



Additional consideratio...

New
Risotto, Steve - American Chemistry Council

A blanket restriction on all brominated and chlorinated content above 0.1 percent in plastic products is arbitrary and overly broad.  Compliance with 6.1....


 The provision should be deleted.

New
Risotto, Steve - American Chemistry Council

If the provision is maintained as a prerequisite, the language should clarify that printed circuit boards and wire and cable are excluded, consist...


Clarify that printed circuit boards and wire and cable are excluded, consistent with Sections 7.1.2 and 9.2.



Companies co...

New
Risotto, Steve - American Chemistry Council

Eligibility for designation as an SVHC[1] is based on many of the same properties as proposed for inclusion in...


Delete both this section and Annex C and revise the optional credit under 6.3.4 for the conduct of alternative assessments for candidate SVHCs or ...

New
Risotto, Steve - American Chemistry Council

The collection of a full substance inventory is cumbersome and counter-productive to a focus on substances of interest (e.g., IEC 62474 Declarable Substan...


Both Sections 6.3.2 and 6.3.3 should be deleted.

New
Risotto, Steve - American Chemistry Council

If the provisions are maintained as optional criteria, the CBI allowance in 6.3.3 should be increased.  An allowance of 5 percent by mass...


If the provisions are maintained as optional credits, the CBI allowance in 6.3.3 should be increased.

New
Risotto, Steve - American Chemistry Council

Awarding up to 6 points gives unnecessary weight to a paperwork exercise with little practical impact.


If the provisions are maintained, the number of optional points for 6.3.2 and 6.3.3 should be reduced to a 2-point maximum (1 per Section)

New
Risotto, Steve - American Chemistry Council

The provisions of this Section should be better integrated with those of 6.2.1 since there is considerable overlap between the list of candidate SVHCs and...


The provision should be revised to award optional points for conducting an alternatives assessment for a candidate SVHC or an IEC 62474 Declarable...

New
Risotto, Steve - American Chemistry Council

In addition, the provision should not limit the allowable frameworks to those developed by the Interstate Chemicals Clearinghouse (IC2) and the National R...


The language should be revised to allow frameworks that are equivalent to the two specified or to identify the criteria to be included in the fram...

New
Risotto, Steve - American Chemistry Council

The requirement that an assessment must be no more than 1 year old should be revised to allow flexibility.  In many cases, it is likely that little will h...


Add flexibility to the 1-year timeframe.

New
Risotto, Steve - American Chemistry Council

The use of the terms ?safe? and ?safer? in the section are problematic, as it possible that alternatives to the currently used substances may present impa...


The language of the provision should be revised to avoid the use of the terms ?safe? and ?safer.?

New
Risotto, Steve - American Chemistry Council

Conducting an alternatives assessment for Br and Cl compounds under 6.1.4 is consistent with the intent of the standard and should be rewarded.  <...


Delete ?An alternative assessment performed under 6.1.4 shall not be eligible for this optional criterion.?

New
Risotto, Steve - American Chemistry Council

Since an alternatives assessment can involve a considerable amount of time, effort, and expense, the optional point total for this provision should be inc...


Increase the optional point total for this provision.

New
Risotto, Steve - American Chemistry Council

The requirements for testing performance of abatement systems are based solely on EPA criteria.  Although the provision allows for equivalent test methods...


If possible, the provision should be revised to also reference non-US criteria.

New
Risotto, Steve - American Chemistry Council

The provision arbitrarily disadvantages the use of plastics for enclosures.  It should be revised to provide optional credit for use of PCR materials rath...


Provide optional credit for use of PCR materials rather than as a prerequisite.  Include comparable PCR criteria for metals.

New
Risotto, Steve - American Chemistry Council

This provision provides little or no environmental benefit.    Reductions in use of chlorine compounds for bleaching should be addressed as an optional pr...


Revise provision to be optional.

New
Risotto, Steve - American Chemistry Council

The requirements of this section go well beyond those of the WEEE Directive and likely would require the public disclosure of CBI.  Since the target audie...


The specified information should only be provided to recyclers upon request in a manner that protects CBI.

New
Risotto, Steve - American Chemistry Council

This provision should be worth more points - life cycle assessment is an important, but intensive, endeavor.  Awarding more points will e...


Increase points awarded for conducting LCAs.



Add ?or equivalent? or identify the criteria to be included in the methodology.

New
Risotto, Steve - American Chemistry Council

The requirement for disclosure of conflict-mineral content in 13.1.2 and the optional certification under 13.4.1 and 13.4.2 appear to have little to do wi...


Delete this provision unless they can be related to environmental performance.  If the provisions are maintained, they should be carefully reviewed to ens...

New
Risotto, Steve - American Chemistry Council

The requirement for public disclosure of social responsibility performance has little to do with environmental leadership.  Although it may be reasonable ...


Make criteria optional.  Also applies to 13.2.3

New
Risotto, Steve - American Chemistry Council

U.S. EPA Toxics Release Inventory (TRI) data are publicly available by substance, location, and company.  Compliance with this provision for US facilities...


The provision should be deleted.  If the provision is maintained as an optional credit, manufacturers should be allowed the option to provide a link to EP...

New
Risotto, Steve - American Chemistry Council

As noted, there is considerable overlap between the substances to be considered in 6.2.1 and those defined in Annex C.  Rather than create another list of...


Annex C should be deleted in lieu of a revision to 6.3.4 to reference IEC 62475 Declarable Substances and candidate SVHCs.  If Annex C is maintained, the ...

New
Dillon, Patty - Dillon Environmental Associates

Both % mass and % weight are used  in the standard . Suggest using either ?mass? or ?weight? throughout standard. For most criteria ?mass? would be the ap...


Choose either % mass or % weight based on NSF protocols.

New
Kirschner, Michael - Design Chain Associates

Please see the attached document for Michael's detailed comments.

New
Earl, Tim - GBH International

Please see attachment for additional details.

New
Dillon, Patty - Dillon Environmental Associates

The definition of "cosmetic blank/dummy" includes a subjective phrase that points to the rationale for the criterion, and does not define the term.



<...


Delete the following text from the definition:



    "...and is redundant when provided in excess or redundantly along with the corresponding option...

New
Seki, Shigetaka - Vunyl Environmental Council, Japan

Please see the attached for details on comments.

New
Mann, Tim - IBM

Please see the attachment for additional details on Tim's comments.

New
Tschudi, Bill - Lawrence Berkeley National Laboratory

Paragraphs 5.1.2 and 5.3.3  reference the latest edition so this does not get locked in time.

New
Tschudi, Bill - Lawrence Berkeley National Laboratory

Paragraph 5.3.2   Include 380 V. DC and give 2 pts.

New
Dillon, Patty - Dillon Environmental Associates

8.1.2 includes a requirement for "non-reusable" packaging. The term should be deleted or defined (generally or in the context of the criterion)  since thi...


Two options to consider:



1) Addi a sentence such as the following to the end of the first bullet:



Packaging is considered "reusable" if th...

New
Dillon, Patty - Dillon Environmental Associates

8.1.4 uses the term "normal operation". Without a definition, "normal" has no meaning and cannot be verified. Suggest either defiining the term or strikin...


Replace "normal operation" with "operation"



Or define "normal operation"

New
Brody-Heine, Pamela - Green Electronics Council

This term is used in only one criterion (11.3.1), and so would be best included in that criterion.


Move definition of semiconductor manufacturing tools to criterion 11.3.1.

New
Dillon, Patty - Dillon Environmental Associates

12.1.3, a prerequisite criterion, requires a certified management system which could be a barrier for small companies.  In  Section 13 on Corporate Perfor...


Request JC discussion of issue

New
Brody-Heine, Pamela - Green Electronics Council

6.3.5 First sentence should read ?alternative assessments? not ?alternative assemblies?.


6.3.5 First sentence should read ?alternative assessments? not ?alternative assemblies?.

New
Brody-Heine, Pamela - Green Electronics Council

It is our understanding that this standard is now an EN standard "EN 50625" and "CENELEC" should be removed.


Strike "CENELEC" in 4th bullet referencing EN 50625.

New
Brody-Heine, Pamela - Green Electronics Council

Strike "plastic" from title "7.2.1 Postconsumer recycled plastic content", as the title in the actual criterion does not include "plastic".


Strike "plastic" from title "7.2.1 Postconsumer recycled plastic content" in Annex A.

New
Dillon, Patty - Dillon Environmental Associates

Prerequisite criterion 13.1.3 appears inconsistent with criterion 13.1.1. 13.1.3 requires the incorporation of ANSI Z10 or OHSAS 180001 into the manufactu...


Modify cirterion to reference criterion 13.1.1 rather than ISO 14001 as follows:



Conformance to ANSI Z10, Occupational Health and Safety Managemen...

New
Dillon, Patty - Dillon Environmental Associates

Criterion 13.4.2 requires a manufacturer to "support and participate in" an in-region sourcing program. Would financial support only meet this criterion? ...


No solution proposed since the solution depends on the intent of JC. 

New
Brody-Heine, Pamela - Green Electronics Council

7.2.1 references Annex D Plastic parts list and % post-consumer recycled content.  Recommend that this refernece is deleted and the annex is removed becau...


Remove reference to Annex D, and delete Annex D.

New