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One major uncertainty facing the process control and instrumentation industry in particular concerns so-called Category 9 products, “monitoring and control instruments,” which do fall within the scope of the WEEE directive, but are currently excluded from the scope of RoHS.
Paul Goodman, senior materials consultant in the reliability and failure analysis section of ERA Technology, has just completed on behalf of the European Commission a comprehensive review of the RoHS directive and its exclusions under Categories 8 (medical devices) and 9. He says most manufacturers he consulted for the review “know that Categories 8 and 9 will eventually be brought into scope, and they’re working towards making compliant products.” The earliest they’ll fall under RoHS is 2010, “because it’s impossible for the EC to make the changes before then,” and his recommendation in the report is “that it not be done before 2012.”
For industrial test and measurement equipment (including control equipment), however, Goodman has recommended an even longer time frame (2016, or possibly 2018) because “manufacturers in this group produce many complex products and each is sold in relatively small numbers. Many of these are safety-critical, and require lengthy testing and regulatory approvals after modifications are made.”
Given this possible 10-year breathing space, can control and instrumentation manufacturers rest easy for the moment about the impact of RoHS on their products? Goodman certainly sees no sign of that happening. “In my experience,” he says, “U.S. manufacturers have been working very hard. They’re very aware of the legislation and have been dealing with it, if anything, faster than some European manufacturers. They are way ahead of the game.”
Some major players in the sector support that view. “I believe that product stewardship has been fully embraced by the control industry,” says Al Samson, product support director for Emerson Process Management’s () Micro Motion company. “Most companies that I’m aware of aren’t waiting to redesign products. The design changes [required] are typically small from a lead-free perspective. Eliminating cadmium, mercury and other substances could be more involved, but the only advantage I see in waiting is hoping exemptions will be extended or a new solution surfaces. I wouldn’t be willing to gamble on either, so I’d be working on design changes now.”
Taking a wider Emerson perspective is Aart Pruysen, approval director for all of Emerson’s European divisions. He advises the company’s worldwide design centers on European legislation. “We’re quite busy with the RoHS directive,” he says, “looking at alternative materials and, in particular, investigating their long-term stability. [Lead-free] solder is one of our main concerns, of course, because we’d like to retain the same lifecycle for our equipment. We take a proactive role. Our main goal is to give the same quality to our customers as before. That’s why we started out early on this investigation program; to be sure we have good alternatives for all the hazardous substances.”
Sean Keeping, technology vice president for ABB Instrumentation, paints a similar picture. “At the moment, our products [in Category 9] are exempt, but our new generation of instruments coming through this year are all designed to be RoHS and WEEE compliant,” he says—with one caveat—lead-free solder on printed circuit boards. “There are still some concerns about the reliability of lead-free solders in terms of ‘whiskering,’ the potential for shorting between tracks on the board, and the temperature characteristics of the solders. In safety-critical conditions, we don’t feel comfortable—and I don’t think the industry feels comfortable—with using lead-free solders. In the meantime, we’re investigating and researching their reliability to make sure we’ll be ready when we do have to comply by law.”
Rockwell Automation has also committed itself to compliance with both WEEE and RoHS. In a June 2006 letter to its customers, Sujeet Chand, senior vice president and chief technical officer for advanced technology, stated that all products that fall within the scope of RoHS would be fully compliant, and that the company’s long-term goal is to meet the RoHS material restrictions on products “even when compliance isn’t legally required.” The company also has a program to ensure compliance with WEEE for in-scope products.
Control manufacturers’ suppliers are adding to the momentum toward compliance. Many also serve the consumer market and already comply with RoHS.
Emerson’s Pruysen adds, “Our suppliers, of printed circuit boards are changing over to [lead-free] RoHS-compliant components, and asking us to do the same because they don’t want to run two production lines. We’re debating with them too about the reliability issues. We’ll switch when we’re sure we have the same long-term reliability as before. Reducing lifecycles isn’t an option for us, and we’re looking at this full-time. We take it very seriously.”
At ABB, Keeping says, “We’re also being lead by our suppliers to some extent, but we’ll gauge the time when we can really switch to complete compliance.”
Semiconductor and component manufacturers like Vishay Intertechnology already produce RoHS-compliant products, but this can cause problems for manufacturers that don’t want to switch to entirely lead-free yet. David Valetta, Vishay’s senior vice president of global strategic sales, stated last May that the firm “was seeing much bigger demand for leaded chip resistors than we anticipated. Lead times have gone out dramatically.”
Environ’s Turnbull is also seeing declining availability of non-compliant components. “It’s early days,” he says, “but by the end of this year, for example, any Category 9 manufacturers still specifying non-compliant components will find that their purchasing costs have increased considerably.”
To some extent, this is the price of good product stewardship. Given sufficient time—which now seems increasingly likely—control manufacturers are more than willing to play their part by designing environmentally sound products.
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