INTRODUCTION IEEE Conformity Assessment Protocols

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1 1. Instructions INTRODUCTION IEEE Conformity Assessment Protocols These verification protocols are derived from and consistent with the Verification Requirements included for each criterion in the IEEE Standard. The protocols elaborate on those requirements in order to provide more specific guidance to subscribers about what the Product Verification Committee (PVC) considers to be adequate evidence to demonstrate conformance. Subscribers may provide conformance evidence that is different from but equivalent in its adequacy to demonstrate conformance to the data submission items called out in these protocols. The overarching purpose of these protocols is to provide consistency and predictability in the verification process. It is essential in the IEEE self-declaration and after-market verification system that the evidence provided by subscribers be adequate for a verifier to fully and accurately assess conformance of the product. The requests in these protocols for submission of evidence are provided with that intent. These protocols relate specifically to level 1 investigations. The verification system includes three levels of investigations: Level 1 investigations are based on the desk inspection of evidence for conformance provided by the subscriber. These are by far the most frequent level of investigation. Level 2 investigations are empirical investigations of conformance with the Standard that may include interviews with 3 rd parties (contract recyclers, suppliers, purchasers, technical experts, etc.), product examinations possibly with partial disassembly, etc., and may also include a level 1 investigation. Often they are conducted when level 1 investigations are not definitive. Level 3 investigations are a fully analytical investigation of conformance with the Standard that may include destructive disassembly, lab tests, etc. and may also include a level 1 and/or level 2 investigation. This document is intended to be used as a companion guidance document to the IEEE Standard. Please refer to the IEEE Standard for the exact product criterion wording and details. In addition the Verification pages on outline verification policies and procedures. This is a living document that will be updated periodically. Please ensure that the most current version is being utilized. 2. Verification Paperwork The subscriber shall provide requested verification data to the Qualified Verifier upon request and within 30 days. For most criteria, more than one Verification Requirement is specified in the Standard. All of the Verification Requirements must be provided, except where an or specifically provides a choice. The subscriber shall provide an index or inventory of the verification data provided. The index or inventory shall identify and explain each item and how it contributes to demonstration of conformance with the criterion in question. -1

2 English Language Verification data shall be provided in English wherever possible, except when a mutual arrangement can be made with the Verifier to obtain translation of other-language material. 3. Items Included in the Verification Protocols for Each Criterion This section defines the contents of the specific sections in the protocol tables for each criterion. Request for data submission to subscriber This is text that a Verifier may use, or adapt and use, in communicating with the subscriber to request the submission of verification data within 30 days. Examples of potential evidence for conformance generally more than one item of evidence may be provided such that conformance is adequately demonstrated This provides examples of the data or documents that the subscriber may provide to the Verifier in response to the request. The subscriber has flexibility in what documents they provide. The key principle is that whatever is provided adequately demonstrate conformance. The examples provided are not comprehensive, and though all of them need not be provided, in general the verification system will require multiple documents to adequately demonstrate conformance. Questions to assess conformance These are the key questions that the provided data must address. The Verifier will need to be able to answer these questions based on the data provided when providing their recommendation to the PVC. Evaluation guidance This section simply includes comments based on verification investigations that may be valuable for the Verifier, or subscriber. 4. Annexes 1 & 2 Plastics and Packaging Materials Forms Attached to this Verification Protocols document are two forms that are provided for the convenience of, and as an option for, subscribers in submitting conformance evidence for certain criteria relative to plastics and packaging the EPEAT Plastic Materials Form and the EPEAT Packaging Materials Form. Each form is linked to the protocols of specific criteria, as noted in the protocols and on the forms. Note the following about those two forms: The subscriber would only fill out a form if and when being verified for a criterion that references the form. The subscriber would only fill out either form once per verification round, even if being verified on more than one criterion referenced on the form. The subscriber would only fill out the specific columns where the criterion being verified is listed. 5. Verification Data Flexibility Subscribers may provide evidence in support of conformance that differs from those items identified in these protocols. Verifiers shall use these protocols to evaluate if the evidence provided by a subscriber meets the following criteria: 1. It is consistent with the Verification Requirements in the Standard. -2

3 2. It is at least as effective in demonstrating conformance as the evidence requested in the protocols. As it is stated in the Verification Protocol for each criterion in the section where examples of potential evidence are provided: generally more than one item of evidence may be provided such that conformance is adequately demonstrated. The key test is that the evidence provided must be fully adequate to demonstrate conformance. Data Demonstrating Conformance at Time of Registration Consistent with Clarification 3-2, the verification data provided by the subscriber must demonstrate that the product was in conformance at the time of declaration, through dated materials or other means. 6. Definitions and Explanations Following are some terms, documents, or concepts that are used repeatedly in these protocols Conformance Assurance System (CAS) The standard defines the conformance assurance system as A process to ensure conformity to a design requirement where the key consideration is control of the supply chain of components, materials, packaging and/or services, and can also include recyclers, test laboratories and even internal designers. A conformance assurance system will include elements addressing the following elements: Plan (i.e. a description of the requirement to the supplier), Do (i.e. the collection of documents that show conformity), Check (i.e. demonstration of how conformance is assured), and Act (i.e. corrective action). The CAS is intended to be an implemented process that consistently ensures conformity to the design requirement being met, where the key consideration for conformity is control of the supply chain of components, parts, plastics, packaging and/or services, and can also include recyclers, test laboratories and even internal designers. A CAS should be based on the plan-do-check-act process (PDCA). CAS tests for conformance are identified for each of the applicable criteria, and may vary slightly depending on the criterion. When a CAS is identified in the Verification Requirements, the subscriber is required to provide the above details specific to the particular criterion being verified. The evidence examples found in the protocols are offered as an indication of the types of components and the level of detail that a Verifier would expect to see in a subscriber s system to assure conformance. The scope of information collected through a CAS will be based upon the type of relationship the subscriber has with the supplier. Generally, the supplier provides components, parts, plastics, packaging and/or services. A CAS can address two different relationships between the subscriber (OEM) and the supplier: 1. Where the subscriber has a contractual relationship with the supplier, and 2. Where the subscriber simply purchases components or services off the shelf from suppliers. An example for RoHS compliance: In a contractual relationship, the subscriber should be both specifying RoHS compliance to, and collecting documentation of RoHS compliance directly from, the supplier; in a purchasing relationship without a contract, the subscriber should have a process for purchasing only -3

4 those parts meeting RoHS and collecting component self-declarations from where they are purchasing parts. Regardless of the type of relationship with the supplier, there are common parts to any CAS that, at a minimum, must be adequately demonstrated as part of the Verification Requirements. Plan: Do: Check: Act: Description of the requirement Common Elements of a CAS How the requirement is being communicated and updated to the supplier What is required to be provided, collected or otherwise used to show the requirement is being met Collection of documents or other records that show conformity as defined by the subscribers processes (examples of records include, but are not limited to, supplier letters, declarations of conformity, analytical test data, tech sheets, certificates, purchasing records, online declarations etc.) Demonstration of how the program provides assurance of conformance that includes, or is equivalent to the following: a. Inspection: Description and details of an audit, monitoring and/or sampling program of some percentage of parts in support of the declaration of conformity for the specified requirements, and which defines its frequency and identifies corrective action procedures for findings. That process can be conducted by the subscriber and/or an identified 3 rd party such as an ODM, distributor or supplier, and typically will include the gathering of analytical test data that supports the requirements being checked. b. Samples of test results from auditing/monitoring/sampling program Description of corrective action plans regarding meeting the requirement and (if applicable) evidence of actions that have been taken in the past The CAS may consist of different kinds of elements, in some cases, for the two different relationships between the subscriber and the supplier. Plan: Different Elements of a CAS for Contractual versus Purchasing Relationships Contractual: Identification of the supplier and of the contractual relationship Contractual: An ongoing contractual commitment to meeting conformance requirements including actions to take when changes occur in production -4

5 Do: Check: Act: Purchasing: Identification of the method of selection of conforming items that assures that the requirements are met Contractual: Ongoing collection of documents of conformity. Documents are typically provided directly from the supplier to the OEM and specific to the part or family of parts being purchased as part of the contract with the OEM. Contractual: Parts are typically sourced over a period of time and the supplier is obliged to provide updates to documents of conformity if the part changes during the span of the contract. Purchasing: Point in time collection of documents of conformity. Documents are typically posted on supplier s websites, or obtained by request, and may be specific to the part or family of parts being purchased and/or may be a more generic statement of conformance for all products. Purchasing: Parts are typically bought in bulk at one time therefore a point in time document collection is done. If parts are bought again at a later date, documentation supporting that purchasing effort would need to be collected. Methods of checking parts for conformance are similar for contractual as well as purchasing relationships. Contractual: Evidence of corrective action procedure. This includes, if a part is found to not meet requirements, the stopping of use of the part and switching to an alternate part or vendor that is providing parts that are shown to meet requirements. This may also include procedures for bringing the part/supplier into conformity through engineering changes or other similarly effective means. Purchasing: Evidence of corrective action procedure. Evidence that an alternative supplier is used to provide parts that are in with the requirement Supplier Letter This is the document called for in Verification Requirements for certain criteria in the Standard that is to be provided to the subscriber by a supplier that indicates that supplier s conformance to a specified requirement. It may also be considered a Supplier Declaration of Conformity. It is acceptable for the subscriber to draft a letter detailing the requirements a supplier must meet and have the supplier sign it, use a declaration that has been created by accredited standards bodies, or use a suppliers own letter. A supplier letter is also frequently provided as part of the requirements of a CAS. Supplier letters (or equivalent) must meet the following minimum criteria to be adequate evidence of a declaration of conformance for IEEE : 1. Clearly state the criterion that the supplier letter applies to and indicate conformance to said criterion -5

6 2. Be signed by a responsible corporate authority (such as a quality control manager or engineer) that provides assurance of conformance to the subscriber; s with electronic signatures are acceptable 3. Be dated within a reasonable time based on the longevity of the part or product. Supplier letter tests for conformance are included with each of the applicable criteria, and may vary slightly depending on the criterion. Note that generally additional evidence is required beyond a declaration of conformance Product definition and scope of verification As defined in the standard a product is a marketing model and chassis type including all its included peripherals or options but not including consumables. Imaging equipment includes the following products: Copier Digital Duplicator Facsimile Machine (Fax Machine) Mailing Machine Multifunction Device (MFD) Printer Scanner According to the IEEE Standard, the definition of product is a marketing model and chassis type including all its peripherals or options but not including consumables. Examples of peripherals are the power cord, external power supply and cables. As such, verification documentation and calculations will also need to include those peripherals that are integral to the operation of the product. Examples of verification documentation that would need to include these items would be, but are not limited to, the plastic parts form (list of parts, recycled content calculation etc), the packaging form (list of peripheral packaging materials, recycled content declarations, etc), CAS/auditing systems, supplier letters, BOM etc Geographic Verification During the process of declaring a product on the Registry, a manufacturer may designate for certain criteria one or more specific geographic countries or regions for which the product declaration is applicable. In order to be conformant in a designated country or region, each unit of the product that is sold in that country or region must satisfy all of the applicable requirements provided in the IEEE standard. The criteria consist of three types: 1) Criteria that are independent of country or region and therefore are applicable wherever the product is sold This is the default type and no specific text is included in the criterion to identify it as such. 2) Criteria that are applicable only in those regions or countries for which the product is declared on the Registry. The following text is included in the criterion: This criterion is applicable only in those regions or countries for which the product is declared on the Registry. -6

7 The following criteria are of this type: (Required) End of life processing requirements (Optional) Certification of programs exempt from end of life processing requirements (Required) Provision of take-back and end-of-life management for cartridges and containers (Optional) Manufacturer recycles or reuse toner material collected through its cartridge and container take-back program (Optional) Manufacturer recyclers or reuses plastics collected through its cartridge and container take-back program 3) Criteria that are dependent on the region or country and may be declared by a manufacturer differently in different regions or countries. The following text (with possible slight variations) is included in the criterion: This criterion is dependent on the region or country and may be declared by a manufacturer differently in different regions or countries. The following criteria are of this type: (Optional) Packaging 90% compostable/recyclable (Optional) Provision of take-back program for packaging For any criteria, during the request for verification data, the manufacturer may be told for which country or region the claimed criteria is being verified, and the manufacturer will need to supply data to show conformance for the identified country or region. For criteria that are independent of country or region, verification documentation will need to show how that criterion is met wherever the product is sold, unless otherwise specified in the request for verification data, not just in the current list of designated IEEE 1680 countries and regions Institutional product versus consumer product Products must be declared as institutional or consumer as some of the criteria are verified differently based on the declaration. According to the standard, products declared as institutional products are: - Only available through authorized dealers or retailers - If sold directly, are marketed primarily as a product for business or enterprise or equivalent. A consumer product is defined by the standard as all products that are not declared as institutional products. The following criteria have verification requirements which vary based on the declaration that the product is an institutional product versus a consumer product: (Required) Ease of disassembly of product (Optional) Ease of disassembly of consumer products (Required) Early failure process -7

8 (Optional) Product upgradeability (Optional) Provision of take-back service for broader scope of products (Optional) Provision of take-back service for packaging. The declaration of a product as institutional or consumer may be verified Declaration of and Verification of Not Applicable (NA) Many criteria have Not Applicable as a declaration option. Most of these criteria have Verification Requirements for proving that they are not applicable. Please see each criterion s verification protocols for more information for what is needed to prove a Not Applicable declaration. 7. Overarching Clarifications The protocols include a listing of the PVC Clarifications that have been adopted relative to each criterion. These are also listed on and are critical information both for subscribers and Verifiers. Though most Clarifications apply to specific criteria and are provided in the protocol tables for those criteria some are global and apply generally to all criteria. The PVC will decide if the overarching Clarifications from should apply to If so, this section will be updated. If not, this section will be deleted. One noteworthy overarching clarification follows: 7.1. Clarification 1-1: Wording of criterion prevails over wording of the criterion title The wording of the criterion prevails over the title of the criterion wherever there is a conflict or inconsistency. 8. Attachments The following attachments are reference in this document and are attached as Appendices to these protocols: 1. EPEAT Plastics Materials Form 2. EPEAT Packaging Materials Form -8