NSF 426 Ballot Comments – Section 11

For Discussion at June 25-26 Joint Committee Meeting

Criteria Summary

11 Life cycle assessment
11.1 Prerequisites
None
11.2 Optional Criteria
11.2.1 Conduct life cycle assessment / 1
11.2.2 Public disclosure of LCA results / 1
11.2.3 Public disclosure of LCA inventory data / 2

Ballot Comment Summary – from JC members and Public Review

  • Total comments: 13 comments(Note: some comments addressed multiple criteria.)
  • Section 11 LCA criteria overall: 1 comment
  • 11.2.1: 6comments
  • 11.2.2: 2comments
  • 11.2.3: 4comments
  • Some common themes
  • Criteria in section should have more points
  • Public disclosure of proprietary information

Proposed Discussion Topics for June 25-26 F2F

1)11.2.1 Conduct life cycle assessment

2) 11.2.2 Public disclosure of LCA results

3) 11.2.3 Public disclosure of LCA inventory data

11.2.1 Conduct life cycle assessment

Name / Comment / Proposal / Proposed Response
Tim Mann/ IBM / We do not support these criteria. Completion of a full LCA as described by these criteria is not practical or necessary for each “declared product.” LCA is more effectively used as a design tool to evaluate new materials or significant process changes. Its routine use on large complex products is of limited use as the complexity of the analysis and the inherent errors introduced by use of non-primary data typically yield general results that are already largely known.
Chris Cleet/ ITI / - Most manufacturers do conduct LCAs, but based on investigations during the 1680.4 (and previously in the .2 and .3 standards processes) LCA methodologies are not mature enough to include their use in a criterion. Further, this criterion assumes (as did all previously considered and removed iterations) that a certain substance will “win” an LCA and there will be a clear “best material” in a given comparison.
- A typical LCA for a single material costs between $75-$100K.
Steve Risotto/ ACC / This provision should be worth more points - life cycle assessment is an important, but intensive, endeavor. Awarding more points will encourage companies to pursue LCAs and help make the information more generally available. One approach to increasing the maximum points to be awarded under this Section is to award points for the implementation of actions to reduce impacts in any of the assessment categories evaluated in the LCA.
Impact assessment methodologies should not be limited to TRACI 2.1, CML 2001, and ILCD 2011. Other methodologies may exist that provide comparable results.Add ?or equivalent? or identify the criteria to be included in the methodology. / Increase points awarded for conducting LCAs.
Add “or equivalent” or identify the criteria to be included in the methodology.
Stephanie Voyles/ IPC / Provide optional points for the implementation of actions to reduce impacts in any of the assessment categories evaluated in the LCA. / Provide optional points for the implementation of actions to reduce impacts in any of the assessment categories evaluated in the LCA.
Stephanie Voyles/ IPC / Impact assessment methodologies should not be limited to TRACI 2.1, CML 2001, and ILCD 2011. Other methodologies may exist that provide comparable results. / Add "or equivalent" or identify the criteria to be included in the methodology.
Stephanie Voyles/ IPC / Criteria should be worth more points - life cycle assessment is an important, but intensive, endeavor. Awarding more points will encourage companies to pursue LCAs and help to make the information more generally available. / Criteria should be worth more points.
Jonathan Wood/ DEFRA / How does the ILCD 2011 methodology relate to the European Commission's further development of PEF methodologies and the IT equipment pilot currently running? We would want to see this methodology be accepted.

11.2.1Revision options:

1)Retain as is

2)Consider revisions

  1. Add “or equivalent” to methodologies (comment by Steve Risotto & Stephanie Voyles)
  2. Add European Commission methodology (comment by Jonathan Wood)
  3. Add points for implementation of actions to reduce environmental impacts

3)Award more points to criterion (comment by Steve Risotto & Stephanie Voyles)

4)Delete criterion (comments by Tim Mann, Chris Cleet)

11.2.2Public disclosure of LCA results

Name / Comment / Proposal / Proposed Response
Françoise Berthoud/ GroupeEcoinfo / "Public disclosure of LCA results": 1 point is too small. It is not very incitative and yet it is important ! (2 ?)
Chris Cleet/ ITI / This is an extension of 11.2.1. However, public disclosure of the LCA is not likely to provide any environmental benefit.

11.2.2Revision options:

1)Retain as is

2)Consider revisions increasing points to 2 for criterion (Francoise Berthoud comment)

3)Delete criterion (implied from Chris Cleetcomment)

11.2.3Public disclosure of LCA inventory data

Name / Comment / Proposal / Proposed Response
Server Manufacturer / This criterion (public disclosure of LCA inventory data) puts the manufacturer at risk to exposure of IP and competitive disadvantage.
Chris Cleet/ ITI / This is an extension of 11.2.1. It is not clear how disclosing the underlying LCA data will provide an environmental benefit. Much of this data is likely to be CBI.
Michael Kirschner/ Design Chain Associates / Inconsistent with standard LCA practice. This data is proprietary to the manufacturer and the source of the data. Remove this criterion.
Brian Martin/ Seagate / Public disclosure of LCA inventory data will be hampered by the proprietary nature of third party data sources. Manufacturers often rely heavily on third party resources for LCAs, and will not be allowed to publicly disclose those data. Suggest the verbiage me modified to require disclosure of only those primary and secondary data that are not restricted by NDA or BCI restrictions.

11.2.3Revision options:

4)Retain as is

5)Consider revisions to address CBI

6)Delete criterion