NSF 426 Ballot Comments
For Discussion at June 25-26 Joint Committee Meeting
Section 9 Design for repair, reuse and recycling & 10 Product Longevity
Criteria Summary
9 Design for repair, reuse and recycling
Pts
9.1 Prerequisites
9.1.1 Design for repair, reuse and recycling
9.1.2 Design for plastics recycling
9.1.3 Product recyclability calculation and minimum 90% recyclability rate
9.1.4 Information and reporting in preparation for reuse and recycling (prerequisite for Silver
and Gold)
9.1.5 Functionality testing software tools
9.1.6 Informing reuse operators and treatment operators of information available for their
assistance (Corporate)
9.2, 9.3, 9.4 & 9.5 Optional Criteria
9.2.1 Reduction of materials incompatible with recycling
2
9.3.1 Product marked to identify components and materials with special handling needs
2
9.4.1 Consultation for recyclability rate calculation
3
9.5.1 Information and reporting on disk drive magnet type and location
2
10 Product longevity
10.1 Prerequisites
10.1.1 Replacement components availability
Ballot Comment Summary – from JC members and Public Review (Note: see Excel spreadsheet for
complete compilation of comments on this Section of the draft standard.)

Total comments
o Section 9: 35 comments (Note: some comments addressed multiple criteria.)
 9.1.1: 3 comments
 9.1.2: 1 comment
 9.1.3: 4 comments
 9.1.4: 12 comments
 9.1.5: 6 comments
 9.1.6: 1 comment
 9.2: 1 comment
 9.3.1: 3 comments
 9.4.1: 4 comments
 9.5.1: 3 comments
o Section 10: 1 comment

Some common threads
o Request for additional clarity in text (multiple criteria)
o Given recyclability and modularity of servers is there environmental benefit that justifies
requirement, potential burden to manufacturers, and possible tradeoff with reliability?
o Concern about intellectual property and liability from information disclosures
Page 1
Proposed Discussion Topics for June 25-26 F2F
High Priority
1) Value of the recyclability criteria for a server standard?
Discuss comments on criteria 9.1.1, 9.1.3, and 9.4.1
2) Concerns about intellectual property and liability associated with information disclosures.
Discuss comments on criteria 9.1.4 and 9.1.5.
3) Plastics criteria
Discuss 9.1.2 (inadvertently omitted from draft standard that was balloted) and 9.2.
4) Are rare earth metals a sustainability (e.g., environmental or social responsibility) issue?
Discuss comments on 9.5.1 as well as 7.2.2
Assign to NSF, Individual or Small Group
5) Resolution of comments on remaining Section 9 & 10 criteria
Discuss comments on 9.1.6, 9.3.1, and 10.1.1
Discussion Topic 1: Are these recyclability criteria worthwhile for a server standard?
Discuss within context of comments on criteria 9.1.1, 9.1.3, and 9.4.1.
(Note: all comments on this criterion are shown below. Those comments relevant to the discussion topic
are highlighted in gray.)
9.1.1
Name
Chris
Cleet/ITI
Design for repair, reuse and recycling
Comment
Proposal
Possible
Response
Most of this criterion mirrors requirements in 1680.2,
however, the NSF version excludes important exemptions
in the 1680.2 criterion for regulatory and safety purposes.
- Much of the criteria for repair and reuse are already
considered and inherent in the modularity of data center
equipment, especially servers. Rack mount and bladed
servers are mechanically designed for multi-generational
modularity and serviceability. Features such as hotswappable fans, power supplies, and other modules are
also testaments to this general approach.
Additional independent criteria or interpretation may
conflict with industry’s ongoing development in
modularity and serviceability.
Page 2
Bill
Hoffman/UL
in the fourth bullet (page 31) the phrase, "unless required
for technical or safety reasons." is rather open to
interpretation. what constitutes a valid technical or safety
reason? Because the safety compliance engineer says
so? I would suggest at least for the safety question to
require this to be exempted when the safety concern is
part of a certification or compliance to a safety standard
so there is some structure around how the exemption is
allowed.
Tim
Mann/IBM
We do not support this criterion as it is too prescriptive.
Some components such as power supplies may be riveted
shut for safety purposes. Other components may be
enclosed such as HDDs for quality and reliability reasons.
replace the phrase,"unless
required for technical or
safety reasons.", with
"unless required as part of
compliance with safety
regulations, safety
standards or as part of a
safety certification". this
can be documented
directly by review of the
regulation, standard or
certification.
In addition the requirements that all data drives or cards,
processor, memory DIMMs, power supply, fans and I/O
cards be visible without removal of other components is
likely unrealistic.
Servers are extremely complex products with extremely
high reliability requirements. While we certainly support
designing products to be more easily recycled, the
performance and reliability requirements of servers must
take precedence over what will be a very small
environmental improvements associated with making the
products to be easily disassembled.
We would also point out that manufacturers already have
ample incentives to make key components easily
removable for service. As such, it is not likely that this
criteria will have any significant effect on server design.
9.1.1 Revision Options
1) Leave as is
2) Address comments regarding:
a. Edit wording for safety and technical exemptions (comment from Bill Hoffman) – see
above redline/strikeout
b. Including additional exemptions such as those in a similar criterion in 1680.2 (comment
from Chris Cleet)
c. Prescriptiveness of criterion (comment from Tim Mann)
3) Delete criterion (implied by comment from Tim Mann and Chris Cleet)
Page 3
9.1.3 & 9.4.1
Name
Product recyclability criteria
Comment
Cate
Berard/DOE
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 the end-ofwaste status for fractions is achieved." It is not clear
what "fractions" is. Is this a term used in IEC TR62635?
Chris Cleet/ITI
9.1.3. The phrase “end-of-waste status for fractions” is
not defined in the NSF or IEC standards and it is not clear
when this would be achieved.
Bill
Hoffman/UL
9.1.3. The last paragraph of the section is somewhat
redundant since IEC 62635 is supposed to document the
processes and efficiencies used to achieve the calculated
recycling rate. This paragraph can be eliminated or
simplified to require the documented process must
reflect actual processes at the facility(ies) being used for
the calculation.
Tim
Mann/IBM
Proposal
Possible
Response
If the idea of "end-ofwaste status for fractions
is achieved" is from IEC
TR62635, recommend
adding to that sentence
"as required in IEC
TR62635" or something
similar. If not, this may
need some rewording to
make it clear what this
means.
We do not support these criteria (9.1.3 and 9.4.1) as we
do not think they will result in any environmental benefit.
Servers are already highly recyclable, with metals and
printed circuit boards being the largest percentage of
weight. It is likely that virtually all servers will be able to
demonstrate 90% recyclability.
Criterion 9.4.1 is simply unnecessary. We are not aware
of any significant issue with recycling of servers.
Server
Manufacturer
Bill
Hoffman/UL
9.4.1 This criterion (recyclability rate calculation) puts the
manufacturer at risk to exposure of IP and competitive
disadvantage.
9.4.1 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 also be used.
"eco-design consultant" needs to be defined - can anyone
who calls themselves an eco-design consultant perform
the assessment? it should also be clear that eco-design
consultants are allowed by adding that category of
reviewer to the first paragraph and striking the note.
The bullet should be
struck or additional clarity
on what constitutes an
acceptable design
improvement added.
The bullet for an additional point is pointless. several
potential improvements can always be pointed out that
are useless and would never be implemented. Using gold
Page 4
instead of copper for the PWB electrical connections
would improve the recyclability by making the PWB more
valuable but it's not technically feasible nor is it
likely. yet it would appear that this would comply with
the criterion and allow an additional point to be
awarded.
Michael
Kirschner/DCA
9.4.1 – Manufacturers may balk at having to publish a
report publicly documenting, in particular, "potential
improvements in product design and materials applicable
to the product and next generation products that could
increase their recyclability and potential for reuse". This is
internal product design-related information and can be
considered proprietary. This also may not be worth
asking for as the review is done during the design stage
and improvements may be incorporated into the design
itself. Also "printed circuit boards destined to be sent to a
smelter shall be reported as a single recyclable material.”
Is this normally done? Does this not go against the data in
the TR that says they are between 10% and 20% RCR?
"Note: The consultation may also include an eco-design
consultant." - unclear why this sentence is in here;
manufacturers can choose to use consultants or not to
use consultants for many aspects of their business.
9.1.3 Revision Options
1) Leave as is
2) Address comments regarding:
a. Explaining “end-of-waste status for fractions” (comments from Cate Berard and Chris
Cleet)
b. Whether the last paragraph is needed (comment from Bill Hoffman)
3) Delete criterion (implied by comment from Tim Mann)
9.4.1 Revision Options
1) Leave as is
2) Address comments regarding:
a. The “eco-design consultant” note (comment from Bill Hoffman and Mike Kirschner)
b. Printed circuit boards destined to be sent to a smelter shall be reported as a single
recyclable material. (comment from Mike Kirschner)
c. Additional point for documenting potential improvements (comment from Bill Hoffman)
d. Intellectual property and the requirement that the report be made publicly available.
(comment from server manufacturer and Mike Kirschner)
3) Delete criterion. (to address comments from server manufacturer, Tim Mann and Mike
Kirschner)
Page 5
Discussion Topic 2: Concerns about confidential business information and liability associated
with public disclosure
Discuss comments on 9.1.4 and 9.1.5.
9.1.4 Information and reporting in preparation for reuse and recycling (prerequisite for Silver and
Gold)
Name
Cate
Berard/DOE
Comment
Proposal
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 intended function, and to assist with the
preparation for reuse or treatment
operations." Is the "manufacturer’s user manual,
repair manual or technical manual" the manual
specified by this criterion OR is this referring to
other documents? Recommend one of the
changes in proposed solution.
If "manufacturer’s user manual,
repair manual or technical
manual" is the manual specified
by this criterion, change to "The
original intended function of the
product, parts and components
shall be specified in the manual
to assist with the preparation for
reuse or treatment operations."
Possible
Response
If this is referring to other
documents, change to "If the
original intended function of the
product, parts and components
is specified in separate
manufacturer’s user manual,
repair manual or technical
manual, the manual required in
this criterion shall provide a link
to the appropriate manuals to
assist with the preparation for
reuse or treatment operations."
Cate
Berard/DOE
Chris Cleet/ITI
Criterion 9.1.4 requires the specific manual
include information about "The different
components and materials;" This seems overly
vague. Is this just a
component/part list? Materials list? Should it
include any details other than what is specified in
the later bullets?
- Having a “gatekeeper” criterion (similar to
criterion 5.1.3) for the higher levels disincentivizes
achieving optional points. Manufacturers may opt
out of all the optional criteria given the high
burden and low environmental benefit of this
criterion. If manufacturers cannot get this
criterion and 5.1.3, there will be no pursuit of any
optional points, resulting in no differentiation
between manufacturers.
(I prefer the first...)
Change to "A complete parts,
components and materials
list" If needed, additional
language on any details required
should be added.
Page 6
- This criterion goes significantly beyond the
recycling information necessary for the WEEE
Directive, and as written, calls for the public
release of CBI. Much of this information is made
available on demand to recyclers, usually with a
non-disclosure agreement.
Tim Earl/GBH
- Products are designed for the safe use of
customers. Who will assume liability for misuse of
the materials in this criterion?
9.1.4 The manual must include “A list, updated at
least annually, of any components provided by the
manufacturer that are compatible or equivalent
with original components.” This must be available
for at least 7 years after production ceases. Did
we really intend for manufacturers to review and
update the list annually for discontinued
products? This seems onerous, especially as it is
required for Silver or Gold.
Page 7
Bill
Hoffman/UL
this section has several issues that will lead to
confusion and difficulty determining
compliance. some examples include:
- requiring the manual to be available "without
restriction of access". Does requiring the creation
of an account and logging in, even though anyone
can do so, represent a "restriction of access"
- requiring that the manual be "available in any
region or country in which the criterion is
declared" could also be an issue if the government
of said country is blocking the publishing web site.
"updated at least annually"
should be struck and replaced
with "at the time of assessment
to the standard".
the phrase "at the time of
assessment to the standard"
could also be used for make and
model/connectors
requirements.
- the "different components and materials" is
open to interpretation on how deep or detailed to
go. Does this include each resistor, or only the
PWB as a whole? or in some cases the
components such as microprossesor which are
valuable, but in others the whole assembly is
sufficient. This needs to be further detailed.
- make and model of each connector implies that
only one make and model is used for each
connector, there are likely several which are
changed over the production life of the product. A
statement as suggested below that look at the
current components used only should be
included.
- "a list, updated at least annually" is future
looking. This standard can only be used to assess
the compliance of the product to the standard the
time of assesssment.
Michael
Kirschner/
DCA
9.1.4 – This criterion should either be deleted or
reduced to “The location of materials with special
handling needs as identified in European WEEE
Directive 2012/19/EU Annex VII”. The purpose of
it seems to be to allow continued use beyond the
useful life of the product and that is very
dangerous. Forcing continued provision of support
and materials that may have gone obsolete long
ago and may, in fact, be near or past their useful
life and be increasingly unreliable carries high risk
with it. Electronics are not designed to function
forever, in fact - there is a "bathtub curve"
electronic product reliability follows: as they age
they become less and less reliable.
This is due to chemical changes accelerated by
thermal force and electrical stresses - these are
Page 8
taken into account during product design so the
product has an adequately long useful life with a
low enough early and mid-life failure rate.
Furthermore, requiring the manual to be
machine-readable does not make sense,
particularly requiring use of a standard that was
written by a small group that does not appear to
have been developed in an open and inclusive
manner that did not include representatives of
this industry.
Brian Martin/
Seagate
Finally, under no circumstances would a
manufacturer allow anything but a full "All Rights
Reserved" copyright on a repair manual; what
would the purpose be for allowing anybody to
modify the manual? There is plenty of electrical,
mechanical, thermal and potentially optical
danger lurking inside servers; manufacturers will
have the best understanding of how repair should
be conducted and the task of describing that
should be left to them and only them.
Additionally, forcing the information and tools to
be available for 7 years after the end of
production to any 3rd party who wants it instead
of just authorized service providers is dangerous
for the same reason - there are qualifications
technicians must meet in order to deal with
electronic products safely; how do you make sure
the manufacturer does not take on liability
unnecessarily here? Also, documenting
proprietary interconnect (which there is little of in
servers) risks exposing IP as well as enabling risky
and unsanctioned behavior - this exposes the
original manufacturer to brand equity damage.
Finally, disassembly of servers is generally trivial.
Documentation is quite unnecessary - ask
recyclers.
Manufacturers are generally aligned with efforts
to recover and recycle materials from products.
Publishing information in support of recycling and
materials recovery is fundamental to enable those
efforts. However, publishing manuals that enable
end user or technical repair outside of authorized
repair technicians and authorized repair and
refurbishment is problematic. Repair of server
products involves high voltages, physical hazards,
and hazards from accumulators/batteries.
Publishing repair manuals is generally not
supported by manufacturers due to the inherent
risk in these activities. Documentation of
troubleshooting would be confined to non-
Recommended 9.1.4
Amendments – 9.1.4 is split into
two criteria, a required criterion
(9.1.4) with some of the manual
content requirements deleted
and one optional criterion (9.6.1)
containing the manual content
requirements that were deleted
in the new 9.1.4 and one other
text deletion. A new section of
optional criteria 9.6 is proposed
(see next comment for additional
input on newly proposed
Page 9
hazardous, low risk troubleshooting.
optional criterion)
(see below for proposed text)
Brian
Martin/Seagate
Steve
Risotto/ACC
Jonathan
Wood/Defra
Tim Mann/IBM
Holly
Elwood/EPA
While this (newly proposed) criterion is optional
(9.6.1), the requirements would be extremely
challenging to meet without exposing the
manufacturer to liabilities. In addition, since
specific repair processes/routings are the
intellectual property of refurbishment third
parties, manufacturers are typically unable to
provide full details of effective refurbishment
other than “level 1” repairs, typically involving
non-physical repairs.
Since components are often configured
specifically to enable or support specific machineconfiguration specific functions, most component
replacements will require OEM-specific
components. As an example, while almost any
SATA interface disk drive will function in any SATA
port, using disk drives designed for desktop
applications would result in reduced function and
early failures. While the component replacement
“functions,” the component will not function in
support of OEM specs.
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 audience for this information is
organizations interested in the legitimate reuse
and recycling of equipment, the provision should
be revised to require that the specified
information be provided to recyclers upon request
in a manner that protects CBI.
Ideally would like to see it as a pre-requisite for
bronze.
9.1.4. We do not support these criteria. IBM fully
supports the reuse and recycling of server
products, and makes significant amounts of
information available regarding repair of products
and replacement of components and parts.
However, some of the information/materials that
are required to be disclosed by these criteria are
proprietary, confidential, and/or IBM intellectual
property and should not be subject to compulsory
disclosure or licensing.
9.1.4 and 9.1.5 require information and items be
available for 7 years after placement on the
market. 10.1.1 requires that replacement
products and product service be available for 5
years.
The specified information should
only be provided to recyclers
upon request in a manner that
protects CBI.
Include criterion for bronze
level.
It seems that the two different
requirements should be brought
into line (7 years for each).
Page 10
9.1.4 Revision Options
1) Leave as is
2) Require for bronze (comment Jonathon Wood)
3) Revise criterion to limit scope to WEEE (comment from Chris Cleet, Mike Kirchner)
4) Split into two criteria – see proposal below (comment from Brian Martin, partially addresses
comments from Chris Cleet & Steve Risotto)
a. prerequisite for all levels limited to scope of WEEE
b. optional for all levels with broader public disclosure
c. Also consider other comments
i. Changing 7 years to 5 years (comments from Tim Earl and Holly Elwood)
ii. Text clarifications (comments from Cate Berard and Bill Hoffman)
5) Make optional for all levels (comment from Chris Cleet and Brian Martin) and consider other
comments:
a. Changing 7 years to 5 years (comments from Tim Earl and Holly Elwood)
b. Text clarifications (comments from Cate Berard and Bill Hoffman)
6) Delete criterion (Mike Kirschner, implied by Tim Mann comment)
Proposal for splitting criterion into a perquisite and optional (from Brian Martin)
9.1.4 Information and Reporting in Preparation for Re-use and Recycling (Prerequisite
for Silver and Gold)
The manufacturer shall publish a “manual” for third party re-use and recycling organizations, in at
least English, with the information listed below, including the same information as provided by the
manufacturer for use by its technicians for the same purposes as follows:

Manual shall be available on a publically accessible website without restriction for
access. The manufacturer shall declare the URL of the public disclosure.

The manual shall be published in any region or country and the manufacturer shall have a
written procedure that makes the manual publically available for a minimum of 7 years
following the end of production of the product.
The manual shall contain the following information about preparation for re-use and recycling:

The different EEE components and materials; and

The location of materials with special handling needs as identified in WEEE Directive
2012/19/EU Annex VII ; and

A disassembly or end of life characterization report that demonstrates conformity to all the
prerequisites in Section 9.1 and includes, at a minimum, step-by-step disassembly
instructions with required tools, product specifications and troubleshooting information.
The function specified in the manufacturer’s user manual, repair manual or technical manual should
be used to determine original intended function, and to assist with the preparation for re-use or
treatment operations.
The manual shall meet the following formatting requirements:

Available in user-friendly formatting on the web and as downloadable PDFs for offline
viewing; and

Available in machine-friendly file format: either XML or oManual/IEEE 1874 – IEEE Standard
for Documentation Schema for Repair and Assembly of Electronic Devices; and
Page 11

Provided under an open-source license that allows redistribution and modification such as
Creative Commons (www.creativecommons.org) (CC-BY).
9.6.1 Information and Reporting in Preparation for Re-use and Recycling (New
optional criterion)
The manufacturer shall publish a “manual” for third party re-use and recycling organizations, in at
least English, with the information listed below:

Manual shall be available on a publically accessible website without restriction for
access. The manufacturer shall declare the URL of the public disclosure.

The manual shall be published in any region or country and the manufacturer shall have a
written procedure that makes the manual publically available for a minimum of 7 years
following the end of production of the product.
The manual shall contain the following information about preparation for re-use and recycling:

Technical reference of each individual sub-assembly providing pin diagram and make and
model of each connector capable of being field terminated as provided to manufacturer
repair/authorized service centers; and

The components that cannot be replaced by non-manufacturer supplied components; and

An updated list, at least annually, of any components provided by the manufacturer that are
compatible or equivalent with original components; and
The function specified in the manufacturer’s user manual, repair manual or technical manual should
be used to determine original intended function, and to assist with the preparation for re-use or
treatment operations.
The manual shall meet the following formatting requirements:

Available in user-friendly formatting on the web and as downloadable PDFs for offline
viewing; and

Available in machine-friendly file format: either XML or oManual/IEEE 1874 – IEEE Standard
for Documentation Schema for Repair and Assembly of Electronic Devices; and
Provided under an open-source license that allows redistribution and modification such as
Creative Commons (www.creativecommons.org) (CC-BY).
9.1.5 Functionality testing software tools
Name
Comment
Tim Mann/IBM
9.1.5. We do not support these criteria. IBM fully
supports the reuse and recycling of server products, and
makes significant amounts of information available
regarding repair of products and replacement of
components and parts. However, some of the
information/materials that are required to be disclosed
by these criteria are proprietary, confidential, and/or
IBM intellectual property and should not be subject to
compulsory disclosure or licensing.
9.1.4 and 9.1.5 require information and items be
available for 7 years after placement on the market.
10.1.1 requires that replacement products and product
Holly
Elwood/EPA
Proposal
Possible
Response
It seems that the two
different requirements
should be brought into
Page 12
service be available for 5 years.
Chris Cleet/ITI
Bill Hoffman
line (7 years for each).
Industry practice is to provide this level of support for
five years after end of production. Since the refurbished
goods market has its own capability to provide
continued support, this criterion is burdensome to
manufacturers without providing any environmental
benefit.
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 required to
comply with this criterion may be dependent on a
proprietary OS which is not under the control of the
manufacturer. IN addition the tools don't ensure the
product meets operating specifications but supply
diagnostic data which can be used to assess whether or
not the server is operating to original specifications.
the phrase "can be returned to service as provided by
the manufacturer's repair/authorized service
centers." is difficult to understand the intent. Returned
to service in what form? original as shipped software,
updated to current software, or replaced with an
equivalent unit(not every unit sent for service is
replaced with the original unit)
Mike
Kirschner/DCA
Brian
Martin/Seagate
This whole criterion needs to either be rewritten or
struck.
9.1.5 –The requirement of public availability should be
removed. If this only applies to “as provided by the
manufacturer’s repair/authorized service centers” then
why does the manufacturer have to provide the tools to
the public? Make clear that test software, updates,
drivers and firmware do not have to support versions of
the OS newer than the last version officially supported
by the manufacturer. Peripheral support should only
cover peripherals sold and supported by the
manufacturer, not 3rd party products.
9.1.5 is recommended to become an optional criterion
with one text deletion.
See below
9.1.5 Revision Options
1) Leave as is
2) Make optional (comment from Brian Martin) and consider the following revisions
a. Changing 7 years to 5 years (comment from Chris Cleet, and partially Holly Elwood)
b. Strike phrase as shown (comment from Brian Martin)
c. Strike public disclosure and limit updates to last OS supported by manufacturer
(comment from Kirschner)
Page 13
3) Delete criterion (comments from Tim Mann and Bill Hoffman)
Proposal for revising criterion (from Brian Martin)
9.1.5 x.x Functionality testing software tools (optional)
The manufacturer shall make publicly available and readily accessible, and provide access to the
necessary hardware functionality testing software tools and applicable updates to ensure the
product meets operating specifications and can be returned to service as provided by the
manufacturer’s repair/authorized service centers. Manufacturer shall also make available and
provide access to any system or peripheral firmware (BIOS, etc.) and drivers for the server
hardware.
The manufacturer shall have a written procedure that makes all of these items available for a
minimum of 57 years following the end of production of the product and identifies if there is a
cost. The manufacturer shall declare if there will be any cost associated with the provision of the
functionality testing software tool.
The manufacturer shall declare the URL of the public disclosure.
Discussion Topic 3: Plastic criteria


Criteria 9.1.2 - approved by JC, but inadvertently omitted from the ballot document. If the JC
would like to include it, the criterion will need to be added in the next balloting
Comments on 9.2 (Needs to be re-numbered as 9.2.1)
9.1.2 Design for Plastics Recycling
All plastic parts >100 g shall meet the following requirements:

Clearly marked with material type in accordance with ISO 11469/1043, with the exception of
printed circuit boards, wire and cables.

Separable by hand or with commonly available tools, such that plastic parts can be separated into
parts with the same material type.
If the product does not contain plastic parts weighing >100 g, “Not Applicable” may be declared.
Note: For components containing plastic parts, the 100 g threshold applies to the plastic part only.
Name
Bill
Hoffman
Comment
the phrase "same
material type" should
be defined.
Proposal
Possible
Response
Use the phrase "compatible or compatible with limitations "
and reference
https://www.nrcan.gc.ca/sites/www.nrcan.gc.ca/files/mineral
smetals/pdf/mms-smm/busi-indu/rad-rad/pdf/2005-42(cf)cceng.pdf appendix A for a table of compatible plastics.
9.1.2 Revision Options
1) Insert back into draft standard as is
2) Consider comment (Note: Bill Hoffman must have been reviewing a previous distributed draft
document, and others have not had the change to comment)
Page 14
3) Do not insert back into the standard based on other comments received about the amount of
plastic in servers.
9.2
Design for plastics recycling (optional)
Name
Comment
Tim Mann/IBM
We do not support this criterion. We believe the
requirement that manufacturers provide “Test results
showing no more than a 25% reduction in either the
notched Izod impact at room temperature between a
test sample made from the original plastic without
adhesives, coatings, paints, or finishes and test sample
made from the plastic with adhesives, coatings, paints,
or finishes, as measured using ASTM D256 or ISO 180, or
the Charpy impact for the same test samples as
measured using ISO 179” for plastics with coatings or
paints is extreme and unnecessary.
Proposal
Possible Response
9.2 Revision Options
1) Leave as is
2) Reduce points from 2 to 1
3) Delete criterion
Discussion Topic 4: Are rare earth metals a sustainability (e.g., environmental or social
responsibility) issue?
Discuss comments on 9.5.1 as well as 7.2.2
9.5.1
Information and reporting on disk drive magnet type and location
Name
Comment
Server
Manufacturer
What is the environmental benefit of this criterion,
especially in light of criteria 6.3.2 and 6.3.3 and 9.3.1?
Chris Cleet/ITI
This criterion mirrors 9.3.1 and we have the same
concerns with it.
Michael
Kirschner/DCA
9.5.1 – The purpose of this is unclear, particularly given
my opinion of 7.2.2. In any case it’s unnecessary since
recyclers know where these magnets are located.
Adding more labels to products is, at this time,
extremely difficult due to the regulatory requirements
taking up so much space.
Proposal
Possible Response
9.5.1 Revision Options
1) Leave as is
2) Reduce points from 2 to 1
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3) Delete criterion (implied in comments from server manufacturer, Chris Cleet and Mike
Kirschner)
7.2.2
Postconsumer recycled content of rare earth elements
Name
Comment
Proposal
Cate Berard/
DOE
Remove limitation on
source of PCR for 7.2.2
Chris Cleet/
ITI
Optional: PCR of Rare
Earth Elements
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 elements, and since they are rare - does it
really matter if the source is other magnets or some
other application? The standard should encourage
recovery and reuse of these rare earths from any
postconsumer source. If the language is intending
to incentivize recovery specifically from hard drives,
maybe 1 point can be for PCR content, and 1
additional point can be for PCR content specifically
from hard drive magnets?
There is no way to track this.
Michael
Kirschner/
DCA
Brian
Martin/
Seagate
Wayne
Rifer/GEC
Possible Response
7.2.2 – Rare earth elements are not “rare”, as in
“limited availability”. The amounts used in
electronics are minimal as well. Remove this
criterion.
Cost of PCR REMs
clarifying evidence in
verification required in
7.2.2
Increasing PCR for REMs would increase cost in the
current materials supply chain.
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 material. In order for verification to be
adequate, the criteroin should ask for evidence
relative to the supplier of the PCC REEs.
We recommend that the criterion simply call for
evidence to be provided, and not specify what
evidence, but give an example of the source of
supply. The verification process can then expand on
what is considered "evidence".
7.2.2 Revision Options
1) Leave as is
2) Consider following revisions
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a. Allow for additional sources of REM (comment from Cate Berard)
b. Address tracking/documentation of sourcing (comments from Chris Cleet & Wayne
Rifer)
3) Delete criterion (implied by comment from Brian Martin)
Discussion Topic 5: Resolution of comments on remaining Section 9 & 10 criteria
Discuss comments on 9.1.6, 9.3.1, 10.1.1
9.1.6 Informing reuse operators and treatment operators of information available for their
assistance (corporate)
Name
Comment
Chris Cleet
Proposal
Possible Response
This required criterion, requires informing
reuse/treatment operators of two criterion which are
optional, and one that should be optional, if a criterion
at all. Tying a required criterion to three others that are
unlikely to be claimed makes little sense. This criterion
builds on 9.1.4; and we have the same concerns with it.
Generally, this information is shared as part of a
business relationship with the recycler.
9.1.6 Revision Options
1) Leave as is
2) Incorporate requirements into the three criteria referenced, and delete separate criterion
3) Delete criterion
9.3.1
Product marked to identify components and materials with special handling needs
Name
Server
Manufacturer
Chris Cleet/ITI
Comment
Proposal
Possible Response
Size and space constraints may not allow for achievement of
this criterion for some servers such as blades and micro-node
servers.
This criterion is an extension of 9.1.4. However, it asks for QR
codes on certain components. It is unclear what the
requirements are for the sites these QR codes will link to. There
may be significant size and space limitations on providing
labels/codes on several of these components. Additionally,
there may be environmental impacts to printing codes on the
components as opposed to other potential means of providing
this information, such as online.
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Michael
Kirschner/DCA
9.3.1 – This criterion should be removed. Since the likelihood is
that this information will be printed on a label and stuck to the
inside of the case implies that the label itself should be
removable or compatible with recycling of the case material to
which it's attached (so if this criterion stays this should be
added to it). Further, the only items in the WEEE Directive
Annex VII that would be of concern are the printed circuit
boards and batteries, if used. These are usually obvious and
recyclers already know where to look; 1 point is enough IMHO,
if this is even worth doing as an optional criterion since it really
is just a point giveaway.
9.3.1 Revision Options
1) Leave as is
2) Reduce points from 2 to 1
3) Insert “not applicable” provision based on comment from server manufacturer “Size and space
constraints may not allow for achievement of this criterion for some servers such as blades and
micro-node servers.”
4) Delete criterion
10.1.1 Replacement components availability
Name
Françoise
Berthoud
Comment
Proposal
Possible Response
3 - "Replacement components availability": 5 years is too
short, most of the time servers are kept more than 5 years.
Could you increase this value ? (7 ?)
10.1.1 Revision Options
1) Leave as is (would harmonize with 9.1.4 and 9.1.5 if they are revised to 5 years)
2) Increase to 7 years (would harmonize with 9.1.4 and 9.1.5 if they are not changed)
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