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By Mike Spear
Given the almost instant obsolescence of so many of today’s consumer electronics products, it’s not surprising that the concept of product stewardship should be gaining in popularity. It can mean different things to different people and industries, but the U.S. Environmental Protection Agency defines it as “a product-centered approach to environmental protection that calls on all those in the product lifecycle—manufacturers, retailers, users and disposers—to share responsibility for reducing the environmental impact of products.”
The electronics industry has, of course, been promoting product reuse for some years in a bid to cut down on the amount of waste requiring disposal. One example is the consortium set up in 1998 by Honeywell, General Electric and White-Rodgers to recycle thermostats. Operating under the name of the Thermostat Recycling Corp., the operation has recovered 4,000 pounds of mercury from nearly 450,000 recycled thermostats.
What has characterized product stewardship initiatives to date has been their voluntary, non-mandated implementation by manufacturers and users alike. Recent developments coming out of Europe, however, will change that approach—not least for equipment manufacturers.
Arguably the biggest impact in terms of products and companies affected will be made by the European Union’s Registration, Evaluation and Authorization of Chemicals (REACH) proposals, which were approved this past December, and are scheduled to take effect this coming June. The chemical industry and many of its customers will take the brunt of a piece of legislation that calls for the registering, testing, and, for highly hazardous materials, authorizing of some 30,000 chemicals.
As director of toxicology services for the Toxicology Group, a division of the independent testing and certifying organization, NSF International, Clif McLellan is involved in the day-to-day testing of chemical-containing products from a variety of manufacturers. “I think there’s definitely a growing interst in product stewardship from companies looking to establish that their products are safe from start to finish,” he says. “Sometimes it might be for marketing reasons, but entwined in there is some work being done as a protection against litigation.”
Toxicology Group offers a range of testing programs and services to companies requiring risk or safety assessments of their products. McLellan says NSF is “looking at the pros and cons” of starting a program to certify products under the REACH proposals, as well as considering the impact of two other EU directives of more direct and immediate relevance to the control sector—the so-called WEEE and RoHS directives.
The Waste Electrical and Electronic Equipment (WEEE) Directive 2002/96/EC is concerned with reducing the amount of electrical and electronic equipment waste going to landfills or incineration at the end of its useful life. It places the responsibility on producers of such equipment for taking it back, and recycling it where possible. Consumers are expected to be able to return their obsolete equipment to manufacturers free of charge.
Meanwhle, the Restrictions of the Use of Certain Hazardous Substances in Electrical and Electronic Equipment (RoHS) Directive 2002/95/EC has a more immediate impact on product design. Since July 1, 2006, it has banned the manufacture and import into the EU of any electrical or electronic equipment containing the heavy metals lead, mercury, cadmium and hexavalent chromium, and the flame retardants polybrominated biphenyls (PBBs) or polybrominated diphenyl ethers (PBDEs).
McClellan says NSF already is involved in certifying that products meet the RoHS directive, and is considering introducing a testing program for WEEE compliance as well. Though the initial impact of both these directives will mostly be on the huge consumer electronics markets, they’re nevertheless targeted at all electrical and electronic equipment, whether consumer or industrial.
The goals of both directives aren’t dissimilar from many of the voluntary U.S. initiatives. Laudable though they are, however, few have the same mandatory force as the EU directives. Whether that will change, either on a state or federal level, remains to be seen, but there are certainly signs of a more coercive approach being taken up around the world. “RoHS-type initiatives are being rolled out in countries like Australia, Argentina, Mexico, Taiwan, South Korea and, from next year, China,” says Aidan Turnbull, head of the global eco-design practice with international consultant Environ.
Turnbull says, “The U.S. is quite a ways behind Europe in terms of WEEE-type legislation. There is Senate Bill 50 in California, for example, which only applies to computers, TVs, monitors, and displays, focusing on a small group of household products. The EU regulations, on the other hand, cover everything listed in their 10 categories, including a huge number of B2B products.”
The problem facing importers to the EU is that each country can have its own interpretation of WEEE. Some allow foreign companies to register under the directive, while others do not. This is fundamentally different from RoHS, which Turnbull says “applies equally across all member states, and no one state can change anything.” WEEE, on the other hand, “is almost like a guideline, with 27 variations [the number of member states] across Europe.”
Environ has attempted to cut through all the uncertainty by setting up a web-based service to help companies comply with both WEEE and RoHS.
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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