Memo To: Institutional Purchasers
Regarding: Contracts for IT/Electronic Equipment
From: Sue Chiang, Center for Environmental Health/Health Care Without Harm
Date: October 9, 2007
Asking questions about environmental attributes of electronic equipment can help your institution prefer companies that
are taking the lead in reducing the environmental impact of these products, and can also be used to educate your
departments about the environmentally preferable products available to them through your contracts.
The RFI/RFP questions are included on the pages following this memo.
Below is a short explanation of why these RFI/RFP questions are important:
1. RoHS Directive. The first question asks whether the product meets the European Union Restriction on Hazardous
Substances (RoHS) Directive. This directive requires that electric and electronic products meet strict thresholds for
heavy metals and some flame retardants, thus reducing the environmental contamination attributable to these
products. Responsible manufacturers should be able to indicate that all their products meet this Directive, as this
Directive is already in force in Europe. (Electronic medical devices are currently exempt but the exemption may be
lifted in the future. It would be good to collect information about whether any electronic medical device
manufacturers are already RoHS-compliant).
2. Short Chain Chlorinated Paraffins (SCCPs). The second question asks about short-chain chlorinated paraffins
(SCCPs). These chemicals are generally persistent, bioaccumulative, and toxic, and have been identified as
problematic environmental contaminants in the North Atlantic by the OSPAR Commission for the Protection of the
Marine Environment of the North-East Atlantic.1 These chemicals may be present in any electronic device, and
responsible manufacturers should already be addressing them.
3. Flame Retardants in Housings & External Enclosures. Most halogenated organic flame retardants are persistent,
bioaccumulative, and toxic. We believe that at this time all electronics manufacturers are still using halogenated
organic flame retardants in printed circuit boards; however, the progressive companies are using alternatives in
electronic housings and enclosures. Thus, responsible manufacturers should be able to provide products without
halogenated organic flame retardants in electronic housings and enclosures. For more information on these
problematic flame retardants, see What Health Care Purchasers Can Do to Reduce Flame Retardants at
http://www.noharm.org/details.cfm?type=document&id=1108.
4. Flame Retardants in Printed Circuit Boards. We believe that at this time electronics manufacturers have identified
alternatives to halogenated organic flame retardants for most electronic applications but are still researching suitable
alternatives for TBBPA (Tetrabromobisphenol A), which is used in printed circuit boards. Responsible companies
should be able to provide products without halogenated organic flame retardants in all electronic applications except
for circuit boards at this time.
[There are more recent studies suggesting that TBBPA, which was considered the least toxic of the brominated flame
retardants, is actually more harmful than previously thought. Depending on how positive initial responses from
manufacturers are on question #3, you could eventually skip question #3, and then start by asking question 4 and
adding a specific question about whether or not the company has a plan to completely eliminate TBBPA (and all
halogenated organic flame retardants) in printed circuit boards and by what date.]
5. Polyvinyl Chloride and Halogenated Organic Chemicals except in Cabling & Wiring. Polyvinyl chloride
production and disposal contributes to the release of dioxin, a highly toxic, very persistent and bioaccumulative
chemical. The last major obstacle to obtaining PVC-free electronics is in the wiring and cables. Halogenated organic
chemicals are referred to in questions #3 and #4 above.
6. Product Takeback Program Qualified Under the Pledge of True Stewardship. Takeback programs
encourage vendors to design products for easy upgrade and recycling. The reason that we have included a
requirement that the takeback program is qualified under the Pledge is because many electronic recycling
companies in the US are exporting hazardous waste to developing countries, using prison labor, or in other
ways engaging in unethical and problematic practices. The Electronics Recycler’s Pledge of True
Stewardship is a program of the Basel Action Network and recycling who sign the pledge agree not to
export hazardous waste or use prison labor, and agree to adhere to other environmentally responsible
practices. For more information about the Pledge, see http://www.ban.org/pledge1.html. Thirty-one
companies have signed the Pledge (including Redemtech), and many of those companies are large, national
recyclers. Note: HCWH has provided a form to collect detailed information from vendors/manufacturers
about product takeback programs.
7. Packaging Takeback & Reusable Shipping Containers. Companies can minimize their ecological
footprint through packaging takeback or reusable packaging programs, and many have also found that they
can significantly reduce cost as well. Packaging takeback programs encourage vendors to choose packaging
that is easy to reuse or recycle. Reusable shipping containers reduce waste and can cut company costs while
conserving energy and natural resources. For more information about reusable shipping containers, see
1
The OSPAR Commission is a result of the OSPAR Convention, which replaces the Oslo and Paris Conventions, and has been ratified by most
northern and western European nations. More information is available at http://www.ospar.org/eng/html/welcome.html.
October 9, 2007
http://www.usereusables.com/index.html. Note: HCWH has provided a form to collect detailed information
from vendors about their takeback or reusable packaging programs.
Questions #8, #9, and #10 may not be applicable to every device. We believe that question #8 may actually apply to
virtually every device now, since most electronics have an internal clock or back-up battery installed. If you can include
these questions in the RFI/RFP template for IT equipment and ask vendors to fill them out if applicable, that would be
preferable to remembering to insert these questions into the contracting process for individual products.
8. Batteries. Most electronic devices these days rely on either primary and/or back-up batteries. Batteries can contribute
significantly to the environmental footprint of a product. Batteries that are user-replaceable reduce costs because the
product does not need to be sent in for service just because the battery runs out. Rechargeable batteries reduce solid
waste (over single-use, non-rechargeable batteries) because they are discarded less often. A free battery takeback
program can save the customer money, because the customer will not have to pay to have the battery sent out as
hazardous or universal waste. A takeback program indicates that the manufacturer is taking financial responsibility for
the hazardous components it puts in its products.
9. Energy Star. The ninth question asks if each product is qualified by the US Department of Energy's Energy Star
program. Energy Star-qualified products are more energy efficient and thus save customers money on their electric
bill. If Energy Star standards have been developed for the product category, responsible manufacturers should have
many models of Energy Star-qualified products. For more information about the program, product categories, and a
list of products that qualify, see http://www.energystar.gov.
10. Paper. The tenth question asks if the product contains at least 30% or more post-consumer recycled content, and is
either unbleached or processed without chlorine. Buying recycled paper ‘closes the loop’ – creates demand for
recycling, boosts the value of discarded paper and thus makes recycling more economically viable. It is an essential
part of reducing the environmental impacts of office paper use. Recycled copy paper is defined as paper that contains
at least 30% post-consumer recycled content.
Chlorine bleaching of wood pulp creates and releases significant amounts of chlorinated organic substances – dioxins
and furans – that are known to be highly toxic. Many of these chlorinated pollutants are shown to cause numerous
health problems including many different kinds of cancer, reproductive disorders, genetic damage and immune
system suppression. This item is important because dioxins and furans are by-products of the production process and
will not be addressed through questions asking about chemicals in the products themselves.
October 9, 2007
Suggested Environmental Preferences and Disclosures for
Non-Computer Electronic Devices
Suggested RFI/RFP language:
1. RoHS Directive. [PURCHASER] is committed to minimizing the amount of persistent, toxic materials used in
operations and desires to avoid the acquisition of products that do not meet the threshold limits for specific chemicals
stipulated in the European Union Directive 2002/95/EC Restriction on Hazardous Substances (RoHS), even if the
product category is currently exempt from RoHS compliance. At this time RoHS stipulates the following thresholds
for the presence of each substance within homogeneous materials, with certain exceptions: Cadmium, <100 ppm;
Mercury , Lead, Hexavalent Chromium, Polybrominated Biphenyls (PBB), and Penta-, Octa-, and Decabromodiphenyl ethers, all <1000 ppm each. Details about RoHS thresholds and exceptions are available at
http://europa.eu.int/eur-lex/lex/LexUriServ/LexUriServ.do?uri=CELEX:32002L0095:EN:HTML.
2.
3.
4.
5.
___
The Products comply with the RoHS Directive.
___
The Products that do not comply with the RoHS Directive are identified in Exhibit A to this Agreement.
Short Chain Chlorinated Paraffins (SCCPs). [PURCHASER] is committed to minimizing the amount of Short
Chain Chlorinated Paraffins in its operations because they are toxic, persistent in the environment, and accumulate in
living organisms. (See http://www.ospar.org/documents/dbase/publications/P00141_BD%20on%20SCCP.pdf.)
[PURCHASER] desires to avoid the acquisition of products that contain Short Chain Chlorinated Paraffins (SCCPs,
CAS number 63449-39-8) with more than 0.1% by weight, 10-13 carbon atoms, minimum 48% chlorine by weight.
SCCPs are used as flame retardants and / or softeners and may be present in paints, coatings, plastics, rubbers and
seals. SCCPs are toxic, persistent in the environment, and accumulate in living organisms.
___
The Products do not contain Short Chain Chlorinated Paraffins (CAS number 63449-39-8).
___
The Products that contain Short Chain Chlorinated Paraffins (CAS number 63449-39-8) are identified in
Exhibit A to this Agreement.
Elimination of Halogenated Flame Retardants in Housings and External Enclosures. [PURCHASER] is
committed to minimizing the amount of halogenated organic flame retardants (HFRs) used in operations and desires
to avoid the acquisition of Products that contain HFRs whenever feasible alternatives exist that do not compromise
patient care. HFRs are defined as chemicals containing a carbon-halogen bond. Halogens include fluorine, chlorine,
bromine, and iodine. (Examples of halogenated organic flame retardants include, but are not limited to,
Tetrabromobisphenol-A (TBBPA), CAS 79-94-7; Hexabromocyclododecane (HBCD), CAS 25637-99-4; Deca-BDE
(Decabromodiphenyl ether), CAS 1163-19-5; Tris(2-chloroisopropyl phosphate) (TCPP), CAS 13674-84-5; and
Tris(2-chloroethyl) phosphate (TCEP), CAS 115-96-8.) Alternatives are readily available for housings and external
enclosures.
___
The Products do not contain halogenated flame retardants in housings and external enclosures.
___
The Products that contain halogenated flame retardants in housings and external enclosures are identified
in Exhibit A to this Agreement.
Flame Retardant Elimination Except in Circuit Board. [PURCHASER] is committed to minimizing the amount
of halogenated organic flame retardants (HFRs) used in operations and desires to avoid the acquisition of Products
that contain HFRs whenever feasible alternatives exist that do not compromise patient care. Alternatives are
available for most electronic applications except for circuit boards. (See question 4 for more details on HFRs.)
___
The Products do not contain halogenated flame retardants in any location except in the circuit board.
___
The Products that contain halogenated flame retardants in locations other than the circuit board are
identified in Exhibit A to this Agreement.
PVC and Halogenated Organic Chemicals except in Cabling & Wiring: [PURCHASER] is committed to
minimizing the amount of halogenated organic chemicals (HOCs) used in operations and desires to avoid the
acquisition of Products that contain HOCs whenever feasible alternatives exist that do not compromise patient care.
HOCs are defined as chemicals containing a carbon-halogen bond. Halogens include fluorine, chlorine, bromine, and
iodine, and include polyvinyl chloride (PVC) and most fluorinated plastics. Alternatives are available for most
electronic applications except in the cables and interconnect parts (such as plugs and sockets).
___
The Products do not contain halogenated organic plastics or chemicals except cables and interconnect
parts (such as plugs and sockets).
___
The Products that contain halogenated organic plastics or chemicals except cables and interconnect parts
(such as plugs and sockets) are identified in Exhibit A to this Agreement.
October 9, 2007
6.
7.
8.
Takeback Program Qualified Under Pledge of True Stewardship. [PURCHASER] is committed to reducing its
costs and liability related to product disposal, to reducing its contribution to solid and hazardous waste, to responsible
disposal of hazardous electronic waste, and to supporting extended producer responsibility. The Electronics
Recycler’s Pledge of True Stewardship requires electronics recyclers to follow particular ethical and material
handling guidelines. For more information about the Pledge of True Stewardship, see
http://www.ban.org/pledge1.html.
___
A Takeback and Recycling Program is offered that uses only recyclers qualified under the Electronics
Recycler’s Pledge of True Stewardship. (If you check this option, you must fill out the Equipment Endof-Life Management Program Summary Form, including the name of the contracted recycling
company/ies, and indicate in Exhibit A which products are eligible for recycling.)
___
A Takeback and Recycling Program is offered that does not use recyclers qualified under the Electronics
Recycler’s Pledge of True Stewardship. (If you check this option, you must fill out the Equipment Endof-Life Management Program Summary Form, including the name of the contracted recycling
company/ies, and indicate in Exhibit A which products are eligible for recycling.)
___
No Takeback and Recycling Program is offered.
Packaging Takeback & Reusable Shipping Containers. [PURCHASER] is committed to reducing packaging
waste and supporting reusable packaging options.
___
A Packaging Takeback and/or Reusable Shipping Container System is offered or can be negotiated. (If
you check this option, you must fill out the Packaging Takeback Program Summary Form, and indicate in
Exhibit A which products are eligible for this program.)
___
A Packaging Takeback or Reusable Shipping Container System is not offered.
Batteries. [PURCHASER] is interested in reducing its contribution to hazardous waste and the burden of continual
battery purchasing. Thus for equipment with batteries, we prefer products where the batteries are:
 User-replaceable
 Rechargeable
 Taken back by the supplier or manufacturer at their end–of-life for no charge (supplier or manufacturer must pay
for mail-in or pickup service)
___
A Free Battery Takeback and Recycling Program is offered. (If you check this option, you must furnish
additional information about the Free Battery Takeback Program, including whether it is pick-up or mailin, geographic areas where this is available, and confirmation that it is free to the user and financed by the
manufacturer or supplier. This information should be provided on an additional sheet.)
___
A Free Battery Takeback and Recycling Program is not offered.
Please indicate in Exhibit A the types and attributes of batteries available for products with battery-operated
components.
9.
Energy Star. [PURCHASER] prefers products that meet the ENERGY STAR energy efficiency specifications for
their product category, when applicable. For a list of products that meet ENERGY STAR specifications and for the
specifications themselves, please see http://www.energystar.gov. Please indicate in Exhibit A which products are
ENERGY STAR qualified.
___
The Products comply with the latest ENERGY STAR specifications for their product category.
___
The Products that do not comply with the latest ENERGY STAR specifications for their product category
are identified in Exhibit A to this Agreement.
___
The Products do not have ENERGY STAR specifications for their product category.
10. Paper. [PURCHASER] is interested in reducing its contribution to solid waste and the use of chlorine bleaching.
Thus, for equipment with paper readouts, we prefer products where the paper refills are:
 Recycled: Contain 30% or more post-consumer recycled content
___
The Products contain 30% or more post-consumer recycled content.
___

The Products that do not contain 30% or more post-consumer recycled content are listed in Exhibit A.
Non-Chlorine bleached: Either unbleached or processed without chlorine.
___
The Products are unbleached or processed without chlorine.
___
The Products that are bleached or processed with chlorine are identified in Exhibit A to this Agreement.
Please indicate in Exhibit A the attributes of the paper available for products with paper readouts.
October 9, 2007
Exhibit A (page 1 of 2)
Use additional sheets if necessary.
Product/Item
COMPLIES
with RoHS
Directive2
(Yes/No)
CONTAINS
Short Chain
Chlorinated
Paraffins
(SCCPs)
(Yes/No)
CONTAINS
Halogenated Flame
Retardants in
housings or external
enclosures (Yes/No)
CONTAINS
Halogenated Flame
Retardants in any
location other than
circuit board
(Yes/No)
CONTAINS PVC or
Halogenated Organic
Chemicals in cables
and interconnect parts
(Yes/No)
Eligible for
Takeback/Recy
cling Program3
(Yes/No)
Eligible for
Packaging
Takeback
Program4
(Yes/No)
I certify that I have reviewed the product and packaging components and am able to produce documentation upon request for the claims made above.
_______________________________________________
Name of supplier representative
_____________________________________________________
Signature of supplier representative
2
___________
Date
EU RoHS refers to the European Union Directive 2002/95/EC Restriction on Hazardous Substances (RoHS). More information about RoHS is available at http://europa.eu.int/eurlex/lex/LexUriServ/LexUriServ.do?uri=CELEX:32002L0095:EN:HTML.
3
Vendor answering Yes in this column must submit Equipment End-Of-Life Management Program Summary Form.
4
Vendor answering Yes in this column must submit Packaging Takeback Program Summary Form.
October 9, 2007
Exhibit A (page 2 of 2)
Use additional sheets if necessary.
If Product has Batteries
Product/Item
UserReplaceable
(Yes/No)
Rechargeable (Yes/No)
Free Take
Back
Program5
(Yes/No)
Type or chemistry (Lead
acid, mercuric oxide,
etc.)
If product has paper readout,
please indicate paper attributes
Percentage
postconsumer
recycled
Non-Chlorine
Bleached Paper
(Yes/No)
If applicable,
Energy Star
Qualified
(Yes/No)
I certify that I have reviewed the product and packaging components and am able to produce documentation upon request for the claims made above.
_______________________________________________
Name of supplier representative
5
_____________________________________________________
Signature of supplier representative
___________
Date
Supplier must furnish additional information about Free Battery Takeback Program, including whether it is pick-up or mail-in, geographic areas where this is available, and confirmation that it is free to the
user and financed by the manufacturer or supplier. This should be provided on an additional sheet.