REACH out for what?
11 August 2008
Hot on the heels of the ROHS legislation we have REACH, and last week’s report from the IPC that we are not ready should really come as no surprise.
The consequences of REACH, according to the IPC report, is not understood by 40% of manufacturing and purchasing personnel in North America and Europe (Industry not prepared for REACH, EMTww, 4 August 2008). If I am surprised by that figure, it is only that it is not more.
I think the first problem comes from the use of the word chemical – REACH stands for Registration, Evaluation, Authorisation and Restriction of Chemicals. Chemicals, according to my dictionary are: ‘A substance used by or created by a chemical process’. Or, if you go back through a substance’s lifecycle, everything. So before you even start there is the ambiguity that it is not clear what substances we are talking about. When people think of unpleasant chemicals in our industry they tend to think mostly about the chemicals used in PCB manufacture – not those in board assembly. Then you move on to the rest of the words in REACH and I suspect that a common reaction of an engineer involved in electronics manufacturing is that they are involved in making stuff – not registering, evaluating, authorising or restricting.
But let us suppose that we have been responsible enough to not dismiss REACH immediately. The next thought would be, ‘but we do this already in RoHS, which is more specific to the electronics industry, so why bother?’ The logic behind this is hard to argue with. If a substance is ‘hazardous to health’ then it would have been banned under the RoHS Directive, if it isn’t then why should it be banned? So what is REACH for?
But now let us suppose that we have accepted that REACH does affect us and we need to do something about it. Or do we? If we are to learn anything from recent history it is that if we don’t do anything then we will not be caught? We are all grown-ups and it is up to you to weigh up the risks (‘I was told in EMTww that I would not be caught’ is no defence if you are!), but so far there have been hardly any prosecutions going as far back as the EMC Directive, let alone RoHS. What is actually driving RoHS through is the increasing scarcity of non-ROHS-compliant components and the well documented technical problems of processing both leaded and unleaded assemblies.
REACH legislation, as I am sure you all know, became law on 1 June 2007 and is now in the process of being written into the legislature of the EU members states. If you would like to find out more about it then follow this link to the EU web site: http://ec.europa.eu/environment/chemicals/reach/reach_intro.htm
There is an upside to all this. The vast majority of manufacturers will obviously want to do their civic duty and follow the legislation. In most cases this is no more than a paper trail and will follow the same systems that are in place for RoHS, ISO 14001 or any aerospace, defence, automotive etc standards. The actual work will need to be done further down the line by the companies that supply the boards, components, fluxes conformal coatings and so on. For a manufacturer with these systems already in place then it could settle down to being no more than a few added columns on the spreadsheet.
So for all that, it once again feels like our industry is being attacked from the outside by people with no grasp of how the industry works, no reasonable explanation about what they are doing, or any logic about how they are doing it, it may well pass relatively smoothly. On the other hand, it could emerge that REACH throws up something that affects the whole board electronics industry, in the same way as lead-free did with RoHS. Do we, for example, know the future of the FR4 substrate…?
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