Facing up to the changing hazards
04 January 2008
Even in those countries where RoHS legislation is now firmly in place there is still continuous change and continued confusion. Neil Stanton explores the issues in the UK.
The frequent news of product withdrawals and prosecutions against RoHS demonstrates that not all manufacturers are really in control of Hazardous Substances in their products. As the RoHS Directive is currently under review it is a good time to look at the current situation and what needs to be considered for the future.
It has reached the stage where almost too much has been written on the subject of Electrical and Electronic Equipment and the environment and the message has become diluted. Lead-free, RoHS, REACh, EuP and Hazardous Substances in Electrical and Electronic Equipment are all subjects which have come under close scrutiny in magazine articles, seminars and on web pages and blogs. All have been subjected to an overload of information on this subject to such an extent that many are almost numb and possibly don¡¦t take in the salient points anymore.
This ¡§information overload¡¨ poses a problem. It is of the utmost importance that we read, review and make judgements on the information we receive on this subject, not least of all the compliance information we get from our suppliers. It is often the case that, when there is a response to a request for compliance information from a supplier, the result is a flurry of standard letters, disclaimers, caveats and a few Governmental documents. The temptation is to simply ¡§file¡¨ all of this information as sifting through it can be confusing, painful and often inconclusive. When faced with a surfeit of compliance information how does one sort the good from the bad?
RoHS compliance data
I suppose the first question is ¡§what do you want to know?¡¨ Suppliers are often happy to tell you about the requirements of the RoHS Directive, the six Restricted Substances, the Maximum Concentration Values and provide you with various links and documents but this does not tell you anything about your supplier¡¦s approach or commitment to ensuring that a component is compliant. When attempting to ascertain if a component is compliant it is useful to ask yourself questions such as:
„« How is the Directive likely to affect these products?
„« Does your supplier understand all the current requirements and implications?
„« Do they understand your requirements with regard to this?
„« What steps have they taken to ensure compliance?
„« What steps are they taking to ensure compliance in the future?
„« How much responsibility is this supplier taking for compliance?
„« How will the compliance status of a product be communicated?
The temptation may be to send out questionnaires or surveys to your suppliers but this may not give you the right information. There is also the danger that the action of asking the question leads the supplier to giving the ¡§correct¡¨ or expected answer. Perhaps the best start is to evaluate information volunteered by suppliers in conjunction with what you know about product compliance with the Directive.
In order to do this, a good knowledge of the Directive and its amendments is essential. You can then consider what you already know about the product or component you are sourcing; has it historically used the restricted substances? Does it have metal parts which may have a chromate finish on them? Are there plastic parts which may contain lead, cadmium or the restricted flame retardants?
Once the type of part or product has been considered, you should then consider your supplier. Where are they in the supply chain? Do they manufacture, assemble or distribute? How much influence do they have on the compliance of the product? What is your experience of this supplier? Any information you gather should be treated in the context of your relationship and experience of the supplier. Some suppliers are more ¡§technical¡¨ than others and some have a closer relationship with suppliers than others so the more you can bring to your evaluation the better.
From here, the next step may well be a visit to the supplier¡¦s website or a request for compliance information. This often concludes in one of two results: a huge amount of information or almost no information at all!
When faced with numerous pages of RoHS compliance data you can usually sift through and disregard the standard-issue material. If you deal with this type of information on a regular basis you will quickly recognise such documentation. A copy of the Directive gives a small insight into the fact that the supplier knows of its existence and knows where to find it but cannot ensure that they have read and understood it. Similarly, pages and flow-charts from the DTI (BERR) guidance give further evidence that the supplier has carried out some research into the matter but still doesn¡¦t tell you if they are doing what is required.
By following the above, you should be able to gauge a level of confidence in the supplier¡¦s ability to supply you a RoHS-compliant product. If that level of confidence is low, then it is your responsibility to try to mitigate the risk by seeking further information or perhaps conducting some testing or XRF screening of the product. Testing is unlikely to be cheap so it is essential that you minimise this need by carrying out thorough, documented evaluations.
¡§It has now all become business as usual¡¨ is a phrase I frequently hear when discussing the requirements for RoHS compliance. This appears to be a defence which relies on all parties having established the requirements for the legislation that affects you in your market and your part of the globe. The fact is that many of the restricted materials for EEE in Europe may still be permitted in other parts of the world or even in other sectors within Europe. This problem was recently illustrated by adverse publicity regarding the use of lead in paint on toys. The common response was that of surprise as we don¡¦t expect this to be an issue anymore. The truth may be that this has been a problem for many years and has only recently come to light due to the use of hand-held XRF units by enforcement agencies. Indeed it may be the case that, as the tools of the policing authorities become more sophisticated, we are more likely to see incidents like this for many long-established Directives.
The changing face of RoHS
What also has to be considered is the way that the RoHS Directive, and how it affects the industry, does not and will not remain constant. The Directive itself has had numerous amendments, often with the addition of exemptions but also, in one case, with the withdrawal of an exemption. The way the Directive is enforced has also been changing. In the UK, enforcement is gathering momentum as more and more products in different market sectors come under scrutiny. The UK Statutory Instrument has also been revised on more than one occasion and continues to be reviewed.
These changes are still ongoing. Studies have been undertaken by the European Commission to review all the existing exemptions, the Scope and the Hazardous Substances covered by RoHS. Changes to any of these areas will have a significant affect on the industry.
The global face of RoHS
The RoHS Directive has rippled around the world: Argentina is one of the latest nations to introduce RoHS requirements and Norway has introduced an enhanced ¡§PoHS¡¨ (RoHS for products not covered by the RoHS Directive) which addresses Electrical and Electronic products not covered by RoHS as well as non-electrical or electronic consumer items.
Many products today enjoy a global market place, therefore the requirements of RoHS outside Europe cannot be ignored.
Action is needed now
In light of these changes, no-one can afford to just sit back and wait for them to happen; there are a couple of things which should be considered. Firstly, be aware of the exemptions you and your suppliers are utilising. You may have components on your shelves marked as compliant which will be non-compliant when one of these exemption is withdrawn; will you be in a position to know which components are affected? Also, manufacturers depending on an exemption for their product should submit credible arguments for the continuation of this exemption otherwise there is a very real risk that this exemption will be withdrawn.
Conclusion
The transfer of accurate information is key in ensuring and demonstrating RoHS compliance. As we move towards a potentially wider scope of RoHS alongside other forthcoming legislation, such as REACh, a thorough knowledge of the requirements, combined with clear communication throughout the supply-chain, is essential to ensuring compliance for today and tomorrow.
Neil Stanton is Scheme Manager, Electrical & Electronic - BSI Product Services, and was writing on behalf of Nepcon UK.
Contact Details and Archive...
Most Viewed Articles...