NSF 426 Ballot Comments – Section 6
For Discussion at June 25-26 Joint Committee Meeting
Criteria Summary
Criterion & Section / Optional Points6 Management of substances
6.1 Prerequisites
6.1.1 Conformance with European Union RoHS Directive
6.1.2 Conformance with European Union Battery Directive
6.1.3 Inventory of declarable substances
6.1.4 Reduction of bromine and chlorine content of plastic parts > 25 Grams
6.2, 6.3 & 6.4 Optional Criteria
6.2.1 Reduction of substances on the European Union REACH Regulation Candidate List of Substances of Very High Concern / 1
6.3.1 Disclosure of declarable substances / 1
6.3.2 Requesting full substance inventory / 2
6.3.3 Acquiring substance inventory / 4
6.3.4 Alternatives assessment / 2
6.3.5 Making alternatives assessment publicly available / 1
6.4.1 Reduce fluorinated greenhouse gas/N2O emissions resulting from semiconductor manufacturing / 1
Ballot Comment Summary – from JC members and Public Review
· Total comments: 81 (Note: some comments addressed multiple criteria.)
o Overarching Section 6 – 1 comment
o 6.1.1 - 3 comments
o 6.1.2 - 1 comment
o 6.1.3 – 3 comments
o 6.1.4 – 17 comments
o 6.2.1 – 9 comments
o 6.3.1 – 4 comments
o 6.3.2 & 6.3.3 – 14 comments
o 6.3.4 – 18 comments
o 6.3.5 – 3 comments
o 6.4.1 – 4 comments
o Annex C – 4 comments
Proposed Discussion Topics for June 25-26 F2F
High Priority
1) 6.1.4 Reduction of bromine and chlorine content of plastic parts > 25 Grams
a. Given small amount of plastic in servers, value of this criterion?
b. Scientific basis and technical justification for eliminating all chlorine and bromine? Impacts to fire safety?
c. Exemption for printed circuit boards, and wires/cables?
d. Basis for selection of 3000 ppm threshold for plastics containing 25% PCR?
2) 6.3.2 Requesting full substance inventory & 6.3.3 Acquiring substance inventory
a. Allow use of representative parts?
b. CBI issues – raise threshold; do not require reporting of mass of individual substances
c. Does the environmental benefit justify the tremendous effort?
3) 6.3.4 Alternatives assessment & Annex C
a. Does this criterion provide value given that server manufacturers will likely be able to find a supplier or third party that has conducted an alternatives assessment on at least one material in a server and claim these points? Should the criterion reward manufacturers that conduct more than one AA?
b. Concerns that Annex C is too extensive
c. Should AA be added to all criteria which include restrictions to substances?
4) 6.3.5 Making alternatives assessment publicly available
a. Concerns about public disclosure potentially creating legal and liability vulnerability for manufacturers.
Medium Priority
5) Reduction of substances on the European Union REACH Regulation Candidate List of Substances of Very High Concern
6) 6.3.1 Disclosure of declarable substances
Assign to NSF, Individual or Small Group
7) 6.1.1 Conformance with European Union RoHS Directive
8) 6.1.2 Conformance with European Union Battery Directive
9) 6.1.3 Inventory of declarable substances
10) 6.4.1 Reduce fluorinated greenhouse gas/N2O emissions resulting from semiconductor manufacturing
6.1.1 Conformance with European Union RoHS Directive
Name / Comment / Proposal / Proposed ResponseTim Earl/GBH / 6.1.1 The footnote states that “Technical documentation can be generated per standard EN 50581 or equivalent.” There is no basis for what might be equivalent to EN 50581. This needs to be better defined, in such a manner as to not require the release of proprietary information.
Stephanie Voyles/IPC / Including language that states the standard will be automatically updated when the regulation is updated removes all control over criteria tied to that regulation. This text should be deleted. / Delete text that states the standard will be automatically updated when the regulation is updated.
Stephanie Voyles/IPC / Delete this criteria or require an alternatives assessment (AA) for the six substances restricted under the RoHS Directive to ensure environmental benefit. As a prerequisite criteria, if it is met it should show a proven increase in environment. The environmental benefit of the RoHS Directive is questionable, specifically regarding the restriction of lead in electronics. The U.S. EPA conducted a lead-free solder study (http://www2.epa.gov/saferchoice/life-cycle-assessment-lead-free-solder-electronics) that evaluated the environmental impacts of tin-lead solder versus lead-free alternative solders. The study found that the increased energy use associated with the higher operating temperatures required for manufacturing lead-free soldered electronics would cause higher air pollution, acid rain, stream eutrophication and global warming impacts than tin-lead soldered electronics. EPA?s study serves as an important reminder that there are environmental trade-offs when substituting one substance for another. This criteria takes for granted that following the RoHS Directive equates an environmental benefit. / Delete this criteria or require an alternatives assessment (AA) for the six substances restricted under the RoHS Directive to ensure environmental benefit.
Revision options
1) Retain as is
2) Revision options as follows:
a. Provide better definition of “or equivalent” to EN 50581 (comment from Tim Earl)
b. Remove language for automatically updated for future versions (comment from Stephanie Voyles)
c. Delete or add AA requirement (comment from Stephanie Voyles)
6.1.2 Conformance with European Union Battery Directive
Name / Comment / Proposal / Proposed ResponseJonathan Wood/Defra / The batteries Directive also contains labelling requirements. Could these be included? / Include labelling requirements. / The criterion focuses on the technical performance requirements, and as countries beyond the EU may have their own labelling requirements, does not include the labelling requirements.
Revision options
1) Retain as is as respond as above
2) Revise to include labelling requirements (comment from Jonathan Wood)
6.1.3 Inventory of declarable substances
Name / Comment / Proposal / Proposed ResponseHolly Elwood /EPA / Suggest striking the whole sentence “The manufacturer shall have an effective…” / “Effective supply chain management system” is a vague, undefined term. Suggest just keeping the second sentence which specifies what the mfg. needs to do.
Stephanie Voyles/IPC / The criteria contains an additional requirement to have an ?effective supply chain management process? to maintain and manage the data and requires the manufacturer to provide document on the processes used to collect, manage and keep data current. According the scope in Section 1.2 the ?[s]tandard establishes measurable criteria for multiple levels of environmental leadership achievement and performance throughout the lifecycle of the product? (emphasis added). The criteria does not specify what an ?effective supply chain management process? is nor does it specify how such a process is measured and evaluated. If this criteria remains, this additional requirement should be deleted from the criteria as it is not measureable and therefore conflicts with the standard?s scope. / Delete additional requirement to have an ?effective supply chain management process.?
Stephanie Voyles/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 proven increase in environment benefit. Keeping an inventory of substances in a product is not correlated with an environmental benefit. / Delete criteria.
Revision options
1) Retain as is
2) Revision options as follows:
a. Strike first sentence of second paragraph with “Effective supply chain management system” and retain the documentation requirements (comment from Holly Elwood):
The manufacturer shall have an effective supply chain management process to manage, maintain, and update all data received on declarable substances as listed in IEC 62474. The manufacturer shall provide documentation of 1) the process to collect and manage the data; and 2) a process to keep the data current.
b. Remove full requirement for “Effective supply chain management system” (comment from Stephanie Voyles)
3) Delete criterion (comment from Stephanie Voyles)
6.1.4 Reduction of bromine and chlorine content of plastic parts > 25 Grams
Name / Comment / Proposal / Proposed ResponseRalph Buoniconti/ 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 elimination. There is no scientific basis for eliminating all chlorine and bromine. Some substances containing these chemical are ubiquitous (ex: table salt, pool cleaners, public drinking water). To force substitution or an alternatives assessment for a material with no scientific evidence of risk is simply adopting a ?me too? position based on other standards. The goal is for this to be a leadership standard and leading with evidence and sound science would increase its credibility and effectiveness. / This section should be deleted. However, if consensus cannot be reached, this section should be optional and consideration should be given to wiring and printed circuit boards.
Chris Cleet/ITI / - As written, will require testing of all plastic parts > 25 grams. If Br or Cl is present, must perform an alternatives assessment. Currently, all PWB material contains Br (TBBPA) and performing an AA on every PWB material in a server is not realistically feasible. The testing and AA requirements are significant expansion of requirements in the Br reduction criterion in 1680.2 and will add significant costs for compliance with this criterion.
- This criterion references “EN 14582.” We assume this means BS EN 14582, Characterization of waste. Halogen and sulfur content. This standard is for characterization of wastes. There is no evidence to suggest applying this test method to products would be useful.
- Over 1000ppm Cl/Br in the plastic does not mean that the plastic contains flame retardant or PVC. The Br or Cl could be from the polymer matrix or inorganic additives. There is no value by doing alternative assessment for this scenario. Furthermore, currently there are no widely accepted alternative assessment frameworks and tools that could be used for alternative assessment.
- Any substitution of a halogen to a non-halogen material including simply eliminating halogens all together could risk the UL94 flammability rating of the plastic (circuit board, chassis, others). Plastics that held a V0 rating could potentially move into a V1 or V2 rating. Careful consideration must be done before an environmental criteria (for a preferred product scheme) impacts or supersedes a product safety attribute. If this criteria increases the risk of products catching fire in increases their burn-ability, it needs to be removed.
Tim Earl/GBH / 6.1.4 There is still no technical justification for singling out bromine and chlorine, two elements which are present in many different compounds with vastly different toxicities. Users have the option of conducting an alternatives assessment on materials listed on IEC 62474 or the lists in Annex C. So, if a brominated or chlorinated substance appears on that list, they can received credit for an alternatives assessment. Bromine and chlorine have been arbitrarily chosen as automatically undesirable in any form. This is not sound science. Recommend removing this section since manufacturers are already permitted to conduct alternatives assessments on substances of concern, which includes some brominated and chlorinated substances.
Tim Earl/GBH / 6.1.4 The 3000 ppm figure is completely arbitrary and not related to any particular manufacturing situation. If the goal is to encourage recycling, this number should be much higher. (Assuming this section is not deleted).
Tim Earl/GBH / 6.1.4 After discussions with manufacturers, it has become clear to me that this will require alternatives assessments for virtually every printed circuit board, which is an unnecessary burden. If this section remains in the standard, printed circuit boards should be specifically exempted.
Holly Elwood/EPA / Inconsistent requirements for a mandatory criterion. Need to keep either blanket prohibition (2nd paragraph) or allow with AA (1st paragraph) / The two paragraphs are inconsistent –1st paragraph allows parts >25g that have high Br/Cl, as long as there is an alternative analysis justifying it, but the second paragraph says parts can’t have Br/Cl levels over the threshold. Need to pick one or the other
Bill Hoffman/UL / The test method specified is intended for testing of waste materials not specifically electronics. Instead IEC 62321 and parts should be specified or at a minimum added as an alternative method. / Replace EN14582 with IEC 62321 or add IEC 62321 and parts as an alternative test method.
Bill Hoffman/UL / 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 voltage power supplies because of the concern of fire safety for the device as a whole. The PWB should be excluded from consideration when there are safety issues using other materials. This may be covered in the alternatives analysis but should be explicitly included in the criterion since it is likely to be a consideration. / 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 of protection that part is excluded from the criterion"
Rick Krock/Vinyl Institute / This is an overly broad requirement and should either be eliminated or moved to the optional criteria as explained further. There are three parts to this requirement that the Vinyl Institute would ask the select Joint Committee to reconsider.
First, this is an arbitrary foreclosure of two classes of chemistry that functionally make safer server products. This restriction, copied from IEEE’s 1680.2 standard, predates EPA’s Design for Environment (DfE) Alternatives Assessment of decabromodiphenyl ether1 flame retardant which showed that several polymeric brominated flame retardants have comparable performance criteria in all safety and human health considerations to those for several non-brominated flame retardants. No weight of evidence was considered by the subcommittee nor were any studies examined that showed that by maintaining this restriction, which has been adopted in many other eco-labels beginning in 19962, that human health or the environment has benefited or will benefit in the future. The reasoning presented to the committee was that this complete foreclosure is needed for this standard to have credibility. Rather than eliminate a class of chemistry that can provide proven benefits for this industry, NSF should rely on authoritative alternative assessments such as EPA’s which provides the credible evidence in support of certain brominated flame retardants for such a standard. The requirement for RoHS compliance prerequisite should be considered as satisfying the global need for control of certain halogenated flame retardant use. Innovation and safety suffer as a result of the foreclosure of halogen chemistry for electronics.