UL RoHS Presentation

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UL RoHS Presentation

• Flint 21st January 2004
• David Hiscott
• Stephen Street

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Agenda

• UL History
• RoHS the basics
• ULs expertise and Knowledge services
• What are we offering?
• How can we add value to Component Distribution?
• Questions/Discussion

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Underwriters Laboratories Inc.

• Founded 1894
• Private, not-for-profit
• Dedicated to public safety
• Largest certification organisation in North
  America
• 16,500 product categories
• Over 9 billion Marks issuedeach year
• Clients in over 80 countries

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UL Mission Statement

• To be the Leading Certifier in providing global
  compliance service

WORKING FOR A SAFER WORLD
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UL Expertise

• Historically known for our product and Material
  testing
• UL Flammability ratings known the world over,
  UL94V0, V1, V2, HB
• Our services must balance Fire safety and
  Environmental sustainability
• Leading provider of Quality management services
  ie. ISO14001
• Using our Material knowledge to offer cost
  effective testing for the content of banned
  substances (RoSH)
• Providing end to end Knowledge based solutions

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Our services help customers at all phases of
their product lifecycle
What requirements does my product
need to meet? What ECO Design Rules must be
followed
Are there any requirements for
recycling or disposal?
How do I verify the quality
of goods from my
Suppliers and whether they Meet the latest
Directives?
-

How do I keep up with
shifting trade regulations
and compliance issues Around the world?
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Sponsors of Hazardous Programmes in UL

• Loring Knoblauch, CEO
• Joe Bhatia, SVP, International Operations, senior
  management Sponsor of program
• Greg Monty, Director of Research and Development,
  Champion of Hazardous Substance Testing Project,
• Maxime Elbaz, General Manager ,Fire, Water
  HazMat SBU Cluster
• Mohammed Faraj, North American CITS Manager
• George Fechtmann, Operations manager in Melville,
  New York,
• Scott MacLeod, Chemist, Primary Designated
  Engineer for Analytical Chemistry, the go-to
  person for technical knowledge, methods
  leadership, RD into new methods

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RoHS Directive Whats Covered?

• In the EU, from July 2006, the following are
  banned
• Lead (PCB solders)
• Mercury (Switches, Relays and Batteries)
• Cadmium (Switches and Relays)
• Hexavalent Chromium (Metal Treatment)
• Polybrominated biphenyls (PBBs no longer made
  in EU)
• Polybrominated diphenyl ethers (PBDEs soon to
  be phased out in EU).

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Chemistry of PBB and PBDE
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PCBs Some Background
In 1968, 1,300 residents of Kyush, Japan, fell
ill after eating PCB-contaminated rice
In 1969, the New Scientist published a report
revealing the capacity of PCBs to "bioaccumulate
along the food chain."
In 1988, the journal Environmental Pollution
published an article revealing the extent of
contamination borne in particular by marine
mammals
In 1995, it was revealed that women who had eaten
fish from the contaminated waters of the Great
Lakes, Canada, gave birth to children with an
unusually high susceptibility to bacterial
infection.
Monsanto in 700m pollution settlement
The payment settles two Alabama court cases
involving thousands of people who said their
homes and lives were damaged by PCB
contamination.
PCBs have now been banned in most countries...
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(No Transcript)
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The other side of the Coin...
The Bromine Science and Environmental Forum has
been on the defensive Brominated flame
retardants have saved thousands of lives. The
Commission itself has gone on record that, in the
last 10 years, a 20 reduction in fire deaths is
a result of the use of flame retardants. We are
not aware of any case of a brominated flame
retardant costing a life.
There is a perception that BFRs in some way
affect adversely the potential to recover
plastics. In fact there is a wide range of data
and practical experience demonstrating that the
end-of-life (EOL) management of plastics
containing BFRs is fully compatible with an
integrated waste management concept, in line with
EU waste policy.
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RoHS Time Lines

• Jan 03 EU Published WEEE ROHS
• WEEE (Waste Electrical Electronic Equip.)
• ROHS (Restriction of Hazardous Substances)
• Aug 04 Both Directive come into force
• Feb 05 Final review due
• Aug 05 Producer responsibility demonstrated
• ??? ?? Establish max concentration values
• Jul 06 Hazardous Substance Restriction begins
• Dec 06 Member State targets met
• Dec 08 New targets and Medical targets

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DTIs latest Information

• Penalties
• DTI will implement under Sec. 2.2 of the ECA
• Penalties will be up to 3 months imprisonment
  /or
• a fine of up to 5,000 on summary conviction
  
• Likely that Trading Standards will enforce this
• The EU Commission
• Yet to decide what test methods (if any) will be
  accepted
• Yet to decide whether they will accept
  self-regulation or
• whether 3rd party testing will be required.

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RD and technological change costs some
estimates
Industry has estimated the costs to be in the
range of 400 million to 570 million for the
retooling of lead-use machineries
It has been estimated that the cost across
Europe will be 15 billion for new investment
to deal with required technological change. This
implies costs to the UK of the order of 1.7
billion.
The European Commission estimates that additional
operating costs of using tin-based solders at
around 150 million per year for Europe as a
whole. Applying this to the UK results in an
estimate of approximately 15 million per annum.
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RD and technological change costs (contd)

• Total additional costs of the substitution of
  the substances listed in the ROHS Directive,
  capital and operating costs, are currently
  estimated to range between 55 million to 96
  million per annum.
• RD costs are currently estimated to range
  between 148 million and 500 million per annum.
  These costs will only be incurred up to the time
  the restrictions of the Directive come into force
  in the UK.

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Trends in Environmental Management Safety

• Batteries and Accumulators Directive
• Mandatory since 1992
• Control content and mandate recovery and
  controlled disposal.
• Packaging Waste Directive
• Mandatory since 1996
• Control its content, mandate recovery, and
  encourage its re-use (Varies State to State)

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Trends (continued)

• Eco-Management and Audit Scheme (EMAS)
• Established in 1995
• Voluntary Eco-Management and Audit Scheme
• incorporating ISO 14001
• ECO-Label (Flower logo)
• Established in 1992
• Voluntary life-cycle assessment for 21
  products/services
• Open to any manufacturer

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Trends (continued)

• Proposed Energy-Using Products (EuP) Directive
• Legislates eco-design requirements for EEE
• Legislation in the US
• Safe Drinking Water and Toxic Enforcement Act
  (Proposition 65).
• PBDE ban
• Video display unit waste act
• Some Asian producers ahead of the game
• Japan and now China.
• Green Peace intervening in Japan

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Trends (continued)

• The End-of-Life Vehicles (ELVs) Directive
  (2000/53/EC) passed into European law in October
  2000.
• On 3 November 2003, the End of Life Vehicles
  Regulations 2003 (SI No. 2635) came into effect.
• Restricts the use of certain heavy metals in new
  vehicles
• Introduces a certificate of destruction for
  scrapped vehicles
• Requires producers to mark certain vehicle
  components to aid recycling

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Eco-Design

• Systematic integration of environmental aspects
  into product design with an aim to improve
  environmental performance
• Life cycle risk assessment
• Resource consumption (water energy)
• Waste generation and pollution (noise, vibration,
  radiation)
• Reuse, recycling, and recovery
• Instructions for disposal
• Environmental Management System

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Different Requirements around the world
European Directives WEEE and ROHS
California Prop. 65
Massachusetts Legislation
Driving Recycling And Restricted Use Of Hazardous
Substances
Future Legislation
China Legislation WEEE and ROHS
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Hazardous Substance worldwide?

• California enacted Proposition 65, the Safe
  Drinking Water and Toxic Enforcement Act of 1986,
  to address concerns about peoples exposure to
  substances that cause cancer or reproductive
  toxicity. This law targets more than 500
  substances, including lead and cadmium, and
  prohibits the discharge of these chemicals into
  drinking water sources. It also requires that
  manufacturers of consumer products that contain
  restricted substances warn consumers of the
  substances presence.
• California Proposition 65 The Safe Water and
  Toxic Enforcement Act
• Massachusetts Toxic Use Reduction Act

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STOP PRESS!

• State of Maine Legislature
• Proposes Bill LD 1790
• "An Act To Reduce Contamination of Breast Milk
  and the Environment from the Release of
  Brominated Chemicals in Consumer Products
• The Maine bill is an aggressive piece of proposed
  legislation compared to what we have seen so far
  in the Consumer Products "Green" arena.
• It has been assigned to the Natural Resources
  committee and would still need 3 readings in both
  the state house and senate prior to the governors
  signature as law.
• Highlights of the Bill include
• Restriction and phase out dates of PBB PBDE are
  the same as EU's RoHS
• Similar labeling requirements as CAL 65 for the
  presence of restricted substances
• Restriction of the "Decabrom" PBDE by 1/1/08
• Restriction of ALL Brominated FR's by 1/1/10

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ASIA 

• Playstation One
•  
• Blocked For Sale In Europe For Cadmium Content
•  
• Japan
•  
•      Industry Driven Requirements Raising The
  Bar
• Supply Chain Component Manufacturers Certifying
  Green Partnership Compliance
•  
• China
•  
• RoHS requirements to be met by January 2006  
•  

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Fear and Anxiety
Standards Dont Exist
Different Limits are Set in Different Countries
Methods of Testing Are not uniformly Accepted
around World
Tracking Regulations Around the Globe Is a
Challenge
Unclear Rules and Regulations
No Harmonization Exists
Quality is Low, Quality Control is Missing
Some Countries Have No Regulations
Some Companies are Pushing for Standards To Make
the Rules More Clear
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RoHS Planning Considerations

• What will end product manufacturers ask of supply
  chain?
• How will alternative materials effect design and
  manufacturing?
• Are alternative materials safe and cost
  effective.
• How do I qualify vendors and can I trust their
  data?
• Statements from suppliers are ambiguous
• Will they be using new codes?
• How do I manage the clear out of non compliant
  stock
• There is no standard approach across the Supply
  chain
• Who will do testing, how will testing be done?
• How do we find alternative materials and vendors.
• How do I manage all this data and the logistics

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What services can we offer

• Introductory seminars both general and company
  specific the wake up call
• Bespoke consultation on the Directives and how
  they effect specific companies and their products
• Providing guidance on the most Cost effective
  routes to compliance
• Developing Green Procurement Policies
• Commercial Inspection and Test
• and Material testing for Banned substances

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UL Competency and Capability

• UL has full competency with refereed methods
• EPA 3050B (Soil Testing, Pb, Cd)
• EPA 3052 (Polymeric Materials, Pb, Cd)
• EN 1122 (Polymeric Materials, Cd)
• EPA 3052 UL Variation (improved method for
  polymeric materials developed by UL)
• UL working with EPA to establish new refereed
  methods
• UL has full competency with XRF methodology
• Research ongoing to establish correlations to
  refereed methods
• UL is establishing methods for testing Hg, Cr6,
  PBB, and PBDE

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UL Competency and Capability continued

• UL has established certification experience with
  Plastics, Wire and Cable, PCBs, Components, and
  end Products
• UL maintains a Plastics and Components Database
  that is the information site for the world
• UL is ramping up test capability to handle all
  submissions expected in 2004
• Short response time is a focus (under two weeks)
• UL is planning its expansion in Asia and Eastern
  Europe
• Cost reduction is a focus
• UL also wants to be physically close to the
  component suppliers
• Ongoing Surveillance programs to negate the need
  for lot testing
• helping reduce the overall cost of compliance and
  delivering a Win Win

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UL and Distribution Solution

• UL proposes a partnership between Distribution
  and UL
• Focus on management of the supply chain for
  restricted hazardous substances
• Distributors, their suppliers and UL will-
• Interpret the regulations and requirements where
  they do business (with UL help)
• Set requirements on their suppliers to establish
  compliance to environmental regulations
• Select/define components in their supply chain to
  be tested
• Request their supply chain send their components
  to UL for testing and establishment of compliance

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The Supply-Chain Management Approach Why?

• Rather than each Supplier / Distributor setting
  up extensive internal programs, UL have a
  subcontract test service making it cheaper and
  more cost effective
• Infrastructure of our Program and Database
  already exists
• Providing services at a cost less than you could
  achieve with your own or a manufacturers own
  internal programs
• Already moving testing in low cost regions of
  China/Eastern Europe
• UL system solution custom designed
• One stop shop for advice, testing and a global
  database backed by ULs brand recognition and
  integrity
• Help Eliminate barriers to market access for
  Distributors

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UL Global databases

• One of the largest and most used components and
  plastics databases in the world
• Over 1 million hits per-annum on the plastics
  database alone
• The plastics database has over 20,000 registered
  users with links set up to manufacturers own
  databases where appropriate

• www.ul.com/plastics

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UL Global databases

• Plan is to add RoHS restricted substance
  measurement data to the database
• i.e. ppm lead, cadmium, hexavalent chromium, PBB,
  PBDE
• Links set up to global requirements for area of
  the world
• Ie . lt300 ppm lead for California's Proposition
  65
• Ie. lt100 ppm cadmium for the EU's RoHS.
• China etc
• Our initial targets are plastics, wire cable
  and component product categories.
• The manufacturer/distributor will choose from a
  menu which restricted substances they want
  evaluated (we can guide them with the selection
  process).
• We are not currently planning to indicate RoHS or
  other compliance, but rather to provide
  measurement data which can be used to ascertain
  the appropriate global compliance.

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Value for OEMs and Distributors

• The Database provides an excellent method for
  designers and purchasing alike to ensure they
  comply with world-wide regulations
• UL will work with OEMs/ Distributors to design
  this database and its access
• UL wants OEMs to be able to select components
  that already have been tested and comply
• UL will act quickly to test and enter into the
  database new components that have been tested
• OEMs/Distribution can manage their supply chain
  without setting up their own database for ROHS
  data.
• We can add hyperlinks from listed components back
  to both original manufacturers and their
  distributors visa versa

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UL - Uniquely Qualified

• Hazardous Substance testing is considered a
  perfect match to ULs Public Safety Mission
• The UL Board and the Management Team are firmly
  committed
• UL has been in the Certification business for 109
  years
• UL is a world leader in Conformity Assessment
• A respected Brand Name in countries around the
  globe
• UL is technically qualified
• UL is an Active Standards Development
  Organization (SDO)
• UL already has established Plastics and Component
  Certification programs.
• UL will leverage this strength to better
  establish the rules around the world
• UL will establish global methods for testing
  (with Regulatory groups)

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UL - Uniquely Qualified

• UL is a global company with established offices
  in crucially important places such as China,
  India, and Eastern Europe
• UL has all the necessary tools such as ICP,
  Microwave Digestion, Milling, GC/MS, XRF
• No other company has a Plastics database like UL
• This makes UL the best place in the world to
  establish a system of managing the hazardous
  substances in the supply chain.
• We are committed to designing a programme with
  Distribution and OEMs to meet this challenging
  requirement

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Questions and Discussion