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computers for conformity with two criteria of the EPEAT PC registry requirements. The investigation was prompted by concerns raised earlier this year in professional publications that speculated whether certain ultra-thin notebooks might not meet several key environmental criteria of the EPEAT rating system. EPEAT has an established set of procedures to ensure the integrity of its registry for cases such as these. In this case the process included: A. Identification of the specific technical areas of concern. These were: a. Upgradeability of components b. Common availability of tools for disassembly c. The ability to safely and easily remove key components as part of product disassembly for recycling. B. Clarification: EPEAT staff requested a "Clarification" (guidance produced through a formal review of the standard) of ambiguities in the wording of the relevant IEEE 1680.1 criteria from the Product Verification Committee (PVC) - the independent panel of experts that determines product conformity in EPEAT. On July 30, EPEAT received and published clarification #14 addressing the relevant criteria (see http://www.epeat.net/verification-clarifications#clarification14 ). That Clarification resolved several key issues for criterion 126.96.36.199, which requires that products be upgradeable, as follows: Products containing externally accessible ports such as a high performance serial bus or a USB are capable of being upgraded by adding a hard disk, DVD, floppy drive, memory and cards, and therefore conform to this criterion. A tool is deemed to be “commonly available” as long as it can be purchased by any individual or business without restrictions and is readily available for purchase on the open market. The tools may be purchasable at a local retail store, or by any individual or business via a mail or web-based retailer. Tools that are proprietary or require licensing or other agreements between the buyer and seller are not considered commonly available. However the PVC did not provide a final determination on the definition of the "ease and safety" required by criteria 188.8.131.52 and 184.108.40.206 at end of life. They ruled these qualities must be "demonstrated". C. Surveillance: EPEAT staff conducted a broad surveillance investigation reviewing publiclyavailable technical material for registered products, to determine whether specific products and criteria were at risk of nonconformance. This review of publicly available data for the universe of smaller, lighter products on the registry determined that unibody construction appeared to
create significant risk of issues with the criteria of concern. This eliminated the majority of products under review, which did not employ unibody construction, leaving 5 products from 4 manufacturers subject to ongoing investigation. D. Verification: EPEAT staff launched a full Verification investigation into the products whose conformance appeared at highest risk after this surveillance process. This investigation was conducted, per standard practice, by independent investigators. 1. EPEAT designated one of its technical laboratory partners to conduct tests to assess whether the products did or did not conform to requirements for ease of disassembly. Lab personnel were not trained recycling professionals and were not experts in the quick disassembly of products. Therefore, the times reported would be expected to be greater than trained recycling professionals 2. EPEAT requested disassembly information from Subscribers for the 5 products identified as being at risk of nonconformance, and forwarded the instruction materials provided to the contracted lab. 3. The lab purchased the identified products on the open market, then disassembled them in accordance with the manufacturer instructions, using commonly available tools. Records were kept of the process, including time for disassembly and notes on the operations for disassembly. For each investigation, the lab made recommendations to the PVC on a "conforms/does not conform" basis. 4. Following detailed review of the lab reports and supporting material, the PVC rendered a final conformity decision for each product. Verification Findings: The lab investigators reported that the time required for total disassembly of each of the 5 subject products was less than 20 minutes and the time required for removal of batteries was under 2.5 minutes for each product. Based on the information provided by the lab, the PVC ruled that all of the subject products were in conformance with the requirements of the criteria under investigation, because removal of batteries and other key components could be conducted "easily and safely" in professional recycling environments, as required. EPEAT has notified affected subscribers of the outcome of the investigation of their products and will provide them with a copy of their investigation report. As is our standard practice, we will also provide the Outcomes Report to all Subscribers and instruct them to take careful notice of any of the findings that might impact their own design and engineering of similar products. Due to the finding that all investigated products are in conformance, no further action is required by the Subscribers whose products were investigated or by EPEAT to complete this Verification Round.