Proposal for NSF 426 Criterion 5.3.1

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NSF 426 - Section 5 Action Item: Criterion 5.3.1
PROPOSED REVISED CRITERIA
5.3.1 Energy efficient supply chains
Product shall contain components manufactured by at least one supplier that has one or more
facilities certified by an ANSI-ANAB-accredited SEP verification body(ies) as Superior Energy
PerformanceTM (SEP) Silver level or higher, at the time of manufacture. Points shall be awarded
based on the total source energy use of the suppliers’ SEP certified facilities, as outlined in table
5.x below:
Table 5.3
Total Source Energy Use
Points
>0.1 trillion BTU per year
1
>=1 trillion BTU per year
2
Point value: 1 or 2.
Verification requirements:
a) Identification of the component(s) in a bill of materials
b) Name of supplier(s) and location of facility(ies) supplying component(s)
c) Documentation of:
a. Current SEP Silver level or higher certification for the facility(ies) by an ANSIANAB-accredited SEP verification body(ies), and evidence that the SEP
certification was awarded prior to product declaration or certification.
b. Total source energy use of the SEP certified facility(ies)
PROPOSED RESPONSE TO COMMENTS
Name
Comment
Chris
Cleet/ITI
There are very few countries
enrolled in the Superior Energy
PerformanceTM (SEP) program.
Most of the countries that have
facilities/companies in the
electronics supply chain are not
enrolled.
Proposal
Proposed Response
Facilities, not countries,
participate in SEP. DOE allows
SEP participation by any energyusing industrial facility, including
those outside the U.S., and
currently has certified facilities
in Canada and Mexico. While
most electronics supply chain
companies/facilities are not
enrolled, this optional criterion
is intended to encourage
participation. Energy use in
NSF 426 - Section 5 Action Item: Criterion 5.3.1
supply chain manufacturing is
repeatedly noted as a significant
impact across the electronics
lifecycle and this criterion is
intended to provide recognition
to manufacturers attempting to
mitigate this impact through a
recognized and successful
program.
Tim
Mann/IBM
We do not support this criterion. It
provides little or no indication of
the energy efficiency of the supply
chain. Servers have thousands of
components. Giving credit for
having one supplier facility
certified to SEP out of the total
supply chain provides no effective
differentiation of server products.
Currently, there are a limited
number of suppliers of server
components on the SEP certified
facility list. The cost of the
certification, when coupled with
the cost of attaining ISO 14001 and
50001 certifications will be
prohibitive for many companies.
http://www.energy.gov/eere/amo/
certified-facilities
The criterion has been revised to
ensure that recognition is only
provided for use of an aggregate
of suppliers that represent
significant energy savings, and
has been revised to allow
recognition for participation of
any part of the supply chain.
The energy savings data does
not need to be collected by the
manufacturer, as it is kept on file
with SEP.
Analysis of SEP certified facilities
notes a marginal cost for SEP
certification above and beyond
50001 certification, but with a
significant payback.
While most electronics supply
chain companies/facilities are
not enrolled, this optional
criterion is intended to
encourage participation. Energy
use in supply chain
manufacturing is repeatedly
noted as a significant impact
across the electronics lifecycle
and this criterion is intended to
provide recognition to
manufacturers attempting to
mitigate this impact through a
recognized and successful
program.
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