Complying with the developing environmental legislation within the electronics industry has become increasingly difficult, especially within the last few years. As environmental legislation changes, having up-to-date information is like trying to successfully shoot a moving target. As more restrictions are put in place, more information is required to prove compliance.
Certificates of compliance and test reports are no longer adequate to document compliance. The best solution to managing compliance is to obtain full materials declarations. Doing so will allow for ongoing compliance verification as environmental legislation changes and allow for monitoring compliance data as new substances are restricted.
Manufacturers face many challenges when trying to determine if the products they produce comply with all existing legislation; a one- time compliance determination is no longer sufficient. For example, with the RoHS II update, exemptions are now subject to a four-year time span, after which time the exemption will expire and must be re-evaluated. This means that the compliance status of exempted parts will need to be re-evaluated as well. In addition, new substances are being considered for inclusion in the RoHS directive. Another major challenge facing manufacturers is staying current with the REACH (Registration, Evaluation, Authorization and Restriction of Chemicals) legislation. Article 33 of REACH requires article suppliers to provide information on the presence of Substances of Very High Concern (SVHCs) in their products. This is a difficult task as new SVHCs are added to the Candidate list every six months. When first introduced in 2008, 15 substances made up the Candidate list. Today the list sits at 38 with 11 more expected to be added soon.
Obtaining full materials declarations is the only way to stay current with the legislation as it changes. When the full chemical breakdown of a component is known, it can be compared to any substance list to determine compliance. This can be a benefit as well to compare to lists like the Substitute it Now (SIN) list which provides substances which are not currently banned but have the potential to be banned in the future. The ever-changing list of restricted substances provides further evidence that certificates of compliance and test reports will no longer be sufficient to determine compliance.
In addition to keeping up with the ever-changing legislation, verifying the accuracy of manufacturer's data can be a task in itself. There are many common mistakes made when filling out materials declaration forms. Quality checks should always be performed to ensure that the data being provided is accurate. Some common mistakes include: exemptions used incorrectly; CAS numbers used incorrectly; and calculation errors.
Exemptions used incorrectly. Always verify that any exemptions being claimed are used correctly. For example, if a supplier is claiming exemption 7a for lead in high temperature solder, the solder composition should be evaluated to verify that the lead concentration is 85 percent or higher. If not, the exemption cannot be used. In addition, the exemptions were renumbered in September 2010 and in many cases it will be necessary to evaluate the exemption for its new number and verify if it has a set expiration date.
CAS numbers used incorrectly. It is necessary to validate the CAS numbers being provided. Oftentimes there is a disconnect between the substances listed in the chemical breakdown and the CAS numbers provided. Having an accurate chemical breakdown is critical for comparing the composition to environmental restrictions.
Calculation errors. It is also important to make sure that the total mass given for the component is equal to the sum of its chemical breakdown. Mass errors are common and data must be sent back to the supplier for corrections. Determining that the mass value for each component is correct is important when performing a roll-up analysis.
The good news is that there are environmental compliance tools available to help minimize risk in the data collection process. Services are available to meet almost any compliance needs. Some companies prefer to utilize a system which allows them to collect and manage their data in-house, while others prefer to have the data collected and delivered to them.
Supply chain services are available for manufacturers who want to outsource the data collection process related to environmental compliance. These companies typically take the process from start to finish by performing an initial scrub of the BOM and determining any problem parts. From there the supplier is contacted for environmental data. Typical environmental data collected includes RoHS status, exemptions, REACH SVHC status, halogen free status, PFOS (Perfluorooctane Sulfonate) status, China RoHS documentation and conflict mineral documentation. Once all the environmental information is collected the data are delivered back to the manufacturer.
Tools Are Available
In the event that the manufacturer wants to collect and manage its own environmental data, there are tools available. A compliance management tool would allow the manufacturer to load a BOM and perform an initial scrub. From there it would allow the company to contact suppliers for environmental data and to track replies. Once the data were received, the tool would accept new entries so that entire BOMs could be evaluated for compliance.
IPC has developed a standard to make the process of collecting environmental data easier. The IPC-1752 was first developed simply as a materials declaration standard. Today it has been updated to the IPC-175x which allows for many environmental aspects to be tracked. The new version tracks RoHS and REACH and allows for detailed manufacturing process information to be provided. In addition, the IPC is considering adding a function that will allow for the tracking of conflict minerals.
The key to being successful in complying with the ever-changing world of environmental regulations is having the proper tool(s) for the task at hand. Finding the tool(s) that work for you will allow you to more easily collect and manage environmental compliance data. As legislation changes you need a tool and a solution that have the ability to change as well.
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