NSF 426 Ballot Comments – Section 8
For Discussion at June 25-26 Joint Committee Meeting
Criteria Summary
8 Product packaging
8.1 Prerequisites
8.1.1 Elimination of substances of concern in product packaging
8.1.2 Enhancing recyclability of packaging materials
8.1.3 Recycled content fiber in packaging
8.1.4 Elimination of individual packaging for hardware and components
8.1.5 Elimination of chlorine in processing packaging materials
8.2 & 8.3 Optional Criteria
8.2.1 Higher total recycled fiber
1
8.3.1 Optimization of packaging system to reduce excess packaging
4
Ballot Comment Summary – from JC members and Public Review
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Total comments: 22 comments (Note: some comments addressed multiple criteria.)
o 8.1.2: 2 comments
o 8.1.3: 4 comments
o 8.1.4: 4 comments
o 8.1.5: 3 comments
o 8.2.1: 2 comments
o 8.3.1: 8 comments
Some common themes
o Some criteria might compromise product integrity
o Recycled content fiber might not be preferable
Proposed Discussion Topics for June 25-26 F2F
High Priority
1) 8.1.3/8.2.1: Is recycled fiber content packaging environmentally preferable for server
products, given server design and distribution?
2) 8.1.4: Is elimination of individual packaging for hardware and components practical for
servers?
3) 8.1.5: Should criterion restrict bleaching to only elemental chlorine?
4) 8.3.1: Should the criterion award points for improvement or achieving specific technical
performance requirement?
Assign to NSF, Individual or Small Group
8.1.2: Misc. comments separable packaging and marking plastics.
Discussion Topic 1: Is recycled fiber content packaging environmentally preferable for server
products, given server design and distribution?
8.1.3 Recycled content fiber in packaging
8.2.1 Higher recycled content fiber in packaging
Name
Comment
Proposal
Proposed
Response
Server
Manufacturer
Chris Cleet/ITI
Brian
Martin/Seagate
Tim Mann/IBM
(8.1.3/8.2.1) Servers are considerably
heavier and up to 15x or more expensive
than laptops and printers. As the % of
recycled fiber in the carton increases, the
integrity of the carton degrades and the risk
of damage to the product increases. A
scientific approach must be used to optimize
product protection while minimizing
environmental impact.
(8.1.3) Increasing recycled content to these
levels causes degradation of material
performance. Servers and data center
equipment are usually commercially shipped
with structurally based shipping
requirements. Installed electronic options
(components, cards, etc…) may require
additional packaging to prevent non-humanvisible damage under shock and vibration
conditions during shipment. Additionally,
server components are sometimes shipped
in multi-unit custom containers that should
be constructed for maximum reuse.
- These levels cannot reasonably be achieved
for “all other fiber-based packaging.” For
printed cartons, recycled content fiber
compromises the color quality and
distinguishable markings of printed
packaging. Distinguishable markings are
required on commercial products to advise
on safety conditions such as weight,
handling procedures, and/or content (such
as commercial batteries).
(8.1.3) Suggest allowing LCA data in support
of alternatives to targeted recycled fiber
content percentages.
(8.1.3/8.2.1) Supplies of PCRC packaging
materials can be spotty, so we are fine with
the idea of stating a "preference" towards
PCRC. However, we cannot support the
overall minimum percentages for recycled
content or increased optional points for
higher recycled content. In speaking with
clients and carriers, we have noted a marked
increase in cosmetic damages in containers
with higher recycled content. We believe
additional performance studies need to be
completed before rushing to higher recycled
content percentages, particularly for the
primary containers.
Server products are shipped globally and are
a very demanding application for packaging.
They are often shipped through several tiers
in supply chain (OEM>> Brand Owner>>
Distributor>> End client) using express parcel
shipping systems (UPS, FedEx, etc.). Recycled
content weakens the material, which leads
to MORE materials used (additional layers
required) as well as potentially higher
damage rates and higher percentages of
returns due to unmarketability. None of
these outcomes are good for the
environment. As such, for recycled content
in packaging, more is not necessarily better.
Chris Cleet/ITI
Furthermore, as demand for PCRC grows to
meet these types of requirements, the
recycled fibers will likely need to be reused
several times, causing additional shortening
of the fibers (causing more weakness). Thus,
a package with equivalent percentage of
recycled content may actually be weaker
than another with equivalent percentages if
the fibers have been recycled multiple times.
We need to find a balance between package
performance and the incentive to blindly
increase the consumption of recycled
materials. The package must work in the
first place in order to achieve optimal
environmental performance.
The supply of Post-consumer content is
inconsistent globally; while this may work in
some jurisdictions, it will definitely not work
in all. Additionally, higher % PCR fibers tend
to have reduced compression and burst
strength, and may require the use of more
packaging.
8.1.3/8.2.1. Revision options:
1) Retain both 8.1.3 and 8.2.1 as is
2) Consider revisions such as
a. Exemption based on performance issue
b. Use of LCA to demonstrate alternative to fiber based (Brian Martin comment)
c. Other?
3) Include only an optional criterion to provide manufacturer with flexibility to claim point based on
specific server product
4) Delete one or both criteria
Discussion Topic 2: Is elimination of individual packaging for hardware and components practical
for servers?
8.1.4 Elimination of individual packaging for hardware and components
Name
Comment
Server
Manufacturer
This may not be practical for all components.
Some components (i.e. SFPs, drives, PCAs)
cannot be pre-installed in a rack as they could
be physically or functionally damaged or
disengaged during shipment. Customers may
request that drives not be installed. Servers
Proposal
Proposed
Response
Chris
Cleet/ITI
Patty Dillon
Tim
Mann/IBM
are highly configurable, and customers may
order additional memory, hard drives, etc. for
that or other servers, which would require
individual packaging.
As written this criterion may increase the
amount of packaging. For servers with
sensitive components, the entire package for
the server will need to be padded for extra
protection rather than packaging sensitive
components individually. It is probable that
very sensitive omponents (memory and hard
drives in particular) cannot be shipped
installed and/or must be shipped separately
because they can be easily damaged during
shipment.
- The damage that may occur in unsecured
sensitive components are not only limited to
the component but to the main system and
its connections. Well known issues such as
electrical contact fretting will reduce the life
and serviceability of the main system.
Inducing these non-human-visible latent
failure modes, jeopardizes the useful life (and
material content of the main system) in lieu
of a relatively small amount of packaging
material (which can be recycled).
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 striking "normal".
Could the operating parameters used to
qualify for ENERGY STAR compliance be used
to define "normal operation"?
Meeting the requirements of 8.1.4 will likely
require that some higher end products (racks)
be shipped with additional packaging and
customized pallets that contain commingling
of various types of cushions, shock absorbers
or brackets. These customized pallets will not
likely meet the criteria of 8.1.2 which requires
that all materials be easily separable.
In addition, it is likely that some sensitive
components and parts may need to be
shipped separately to avoid adding even
more packaging to the higher level product
where it will be installed.
While we appreciate the desire to minimize
packaging and ensure its recyclability, this
desire should be tempered by the need to
ensure that servers are not damaged during
shipment. The environmental benefits of
reduced packaging will disappear quickly if
only a few servers are damaged and require
replacement due to poor packaging.
Replace "normal operation"
with "operation"
Or define "normal operation"
8.1.4. Revision options:
1) Retain as is
2) Consider revisions such as
a. Component exemption – either list or require demonstration of need for separate packaging
3) Make optional criterion to provide manufacturer with flexibility to claim point based on specific
server product
4) Delete criterion
Discussion Topic 3: Should restriction on bleaching fibers be limited to elemental chlorine?
8.1.5 Elimination of chlorine in processing packaging materials
Name
Comment
Michael
Kirschner/
Design Chain
Associates
8.1.5 – Recommend changing this criterion to
require elemental chlorine-free (which most
manufacturers are already requiring) and
making totally chlorine free/processed
chlorine free optional
This requirement is unnecessary and could
lead to unintended consequences for
packaging manufacturers who need
disinfectants in their processes. Elemental
chlorine has been phased out for the most
part as a bleaching agent for pulp and paper
in favor of alternative chlorine compounds.
Again, no information or data was provided
to lead one to require foreclosure of chlorine
compounds from this use, since chlorinated
compounds are currently widely used to
produce safe and bacteria free packaging
materials. The impact of this requirement
must be heavily weighed, since few facilities
on a global basis now practice chlorine-free
fiber processing, thereby making this type of
packaging material available only on a limited
basis and in limited regions yet a full
requirement for this standard. The language
should be revised as follows:
Richard
Krock/Vinyl
Institute
Steve
Risotto/ACC
“Manufacturer shall document with a
supplier letter that any fiber-based materials
used in packaging was not bleached with
elemental chlorine compounds.”
This provision provides little or no
environmental benefit. Reductions in use of
chlorine compounds for bleaching should be
addressed as an optional provision.
8.1.5 Revision options
1) Retain as is
Proposal
Revise provision to be
optional.
Proposed
Response
2) Revise to elemental chlorine free (Mike Kirschner & Richard Krock comments)
3) Make optional criterion (Steve Risotto comment)
4) Delete criterion
Discussion Topic 4: Should the criterion award points for improvement or specific technical
performance requirement?
Name
Tim Mann/IBM
Comment
While we are generally supportive of the
idea of awarding an optional point for
manufacturers who can demonstrate that
they performed a packaging system
evaluation (8.3.1a), we do not support
awarding optional points for packaging
reduction efforts (8.3.1b).
As a general rule, we do not favor criteria
that award points for “improvement” as
opposed to actual performance. Criteria
such as 8.3.1b which award points for
improvement penalize those manufacturers
that design products and packaging
correctly initially and cannot demonstrate
as great an improvement.
Server
Manufacturer
Chris Cleet/ITI
Regarding criteria 8.3.1.c, it is not clear
what evidence would be required to
demonstrate “minimum packaging weight
for all packaging constituents in the
packaging system (primary, secondary, and
tertiary) for product shipped to the
customer.
How are these criteria to be achieved? The
primary purpose of packaging is to protect
the product during shipment. Proof of
minimum packaging weight achievement is
a subjective assessment. Does not reward
manufacturers who have already optimized
their packaging designs.
These criteria, as written, punish
manufacturers who have already optimized
their packaging designs.
- Minimum packaging weight is not
necessarily a sound measure of packaging
optimization.
- Packaging design requires optimization
based on a list of requirements. Reducing
packaging material beyond means more
product damage.
- The phrase “…used in the immediate
previous and current packaging system” is
Proposal
Proposed
Response
not verifiable without more specificity. For
example, it is not clear how to compare
between new and previous product models,
and does not indicate what to compare to if
there is no prior similar product.
- It is not clear how a new market entrant
would compare packaging to a prior
version.
Cate
Berard/DOE
Cate
Berard/DOE
Michael
Kirschner/Design
Chain Associates
Brian
Martin/Seagate
Michael
Kirschner/Design
Chain Associates
- It is not clear how a verifier would know
the legitimacy of a manufacturer’s claim of
a change made.
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. Table 8.3 provides
examples of packaging reduction strategies
eligible for optional points..."
However, the metric in Table 8.3 for the
second point is "Packaging reuse rate: the
number of times the packaging is
used." How is this metric supposed to be
measured as a 10% reduction?
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
reduction in environmental impact (e.g.,
reduction in toxicity or life cycle energy
use)." However, there are no requirements
attached to demonstrating a net
reduction. Other criteria require use of the
LCA methodology in 11.2.1 or alternatives
assessment in 6.3.4.
8.3.1b – This is unclear and invites
gamesmanship. How do you prevent a
manufacturer from designing a specious
overpackaging approach then "revising" it
to what they actually do before packaging?
Consider comparing it to production
packaging of a previous similar product but
even that will be difficult unless the
products are effectively similar (e.g. both
are 2U servers that weigh approximately
the same).
8.3.1b - Suggest clarifying the requirements
for baseline vs 10% reduction in packaging
materials.
8.3.1c – The challenge for this criterion is
weight vs. PCR content (criterion 8.2.1): PCR
fiber is weaker than virgin material so
requires more, but that clearly increases the
weight of the packaging. So what’s more
important? Who has done the LCA?
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 changed.
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
demonstrate "net reduction
in environmental impact."
8.1.2 Revision Options
1) Retain as is
2) Consider revisions
a.
3) Delete part a, b, and/or c
Miscellaneous comments on 8.1.2
8.1.2 Enhancing recyclability of packaging materials
Name
Patty Dillon
Comment
8.1.2 includes a requirement for "nonreusable" packaging. The term should be
deleted or defined (generally or in the
context of the criterion) since this term
may be interpreted differently by
different companies/verifiers. For
example, if the packaging can be
theoretically reused by the
customer would it meet the intent of the
criterion. The JC might consider that the
manufacturer demonstrate that the
packaging is reused, not theoretically
reusable.
Proposal
Two options to consider:
1) Add a sentence such as the
following to the end of the first
bullet:
Packaging is considered "reusable" if
the manufacturer demonstrates that
a packaging reuse program is in
operation (or planned for products
on the market for less than 6
months) that recovers and
reuses the packaging for the
declared product or other products
sold by the manufacturer,
distributor or supplier.
OR
Packaging is considered 'nonreusable" unless the manufacturer
demonstrates......
2) Delete non-reusable AND add the
following to the exceptons:
"....staples, nails in pallets, and
packaging that is demonstrated to
be directly reused by the
manufacturer or its distributors."
Catherine
Ho/Koi
Computers
For Section 8.1.2, has manufacturers
indicated their willingness to mark all
plastics with material type? I do not
believe this is currently a standard
practice. Or can this be optional?
8.1.2 Revision Options
Proposed
Response
4) Retain as is
5) Consider revision
a. Strike reusable (Patty Dillon comment)
6) Make criterion optional (Catherine Ho comment)