Maintaining Environmental Compliance
Are you a manufacturer who frequently introduces new and updated version of your products in the market? Have you ever checked whether your products maintain environmental compliance or do they contribute to the increasing electronic waste? Ensuring the proper disposal of your old and obsolete products is one of the primary measures to obtain environmental compliance. Focus on maintaining a safe environment. Review the guidelines of the laws and rules regarding environmental compliance, and find out which all are applicable for your product. Be aware about the laws of European Union, before the manufacturing of a product. The European Union opines that manufacturers should themselves take the responsibility to curb down the hazards caused by their products. RoHS and WEEE are two of the laws that are implemented by the European Union, aiming the same. RoHS (Restriction of Hazardous Substances) restricts the use of certain harmful substances, such as lead, cadmium, mercury and polybrominated flame retardants from being used in the manufacturing of a product. The European Union (EU) also asks the manufacturers to maintain WEEE compliance for their products, according to the guidelines mentioned in the Waste Electrical and Electronic Equipment (WEEE) Directive. Make proper arrangements to collect back the used equipments and recycle or reuse them. If not, create a proper waste disposal system. Also, go through the principles of REACH (Registration, Evaluation, Authorization and Restriction of Chemicals) and make sure that your product abides by them. According to REACH EU, you have to collect the safety information about the chemicals used and register your product with ECHA (European Chemicals Agency).
RoHS and WEEE – to minimize e-waste
The Directive on the restriction of the use of certain hazardous substances in electrical and electronic equipment, popularly known as the Restriction of Hazardous Substances Directive (RoHS), and the Waste Electrical and Electronic Equipment Directive (WEEE), were two of the initiatives adopted by the European Union, in order to solve the issues of increasing electronic waste (e-waste), which pose threat to life, health and environment. Each member state of the European Union is bound to abide by the guidelines mentioned in the directives and manufacture RoHS and WEEE compliant products. However, they can resort to take their own measures for implementing the rules. The RoHS directive restricts the use of certain substances in the manufacture of the Electrical and Electronic Equipments (EEEs). It is commonly known as the lead-free directive, but the use of certain other harmful substances is also prohibited under the RoHS Directive. These include mercury, cadmium, hexavalent chromium and the polybrominated flame retardants such as, polybrominated biphenyls (PBB) and polybrominated diphenyl ether (PBDE). These cause harm not only to the environment, but also to the health conditions of the employees in the firm and users of the product. The WEEE directive assigns the responsibility of managing the e-wastes to the manufacturing firm. It directs the manufacturers to collect the e-waste and make provisions for its reuse or recycle. The obsolete or used electrical and electronic goods also are termed as e-waste. WEEE directive applies to the small and large scale household appliances, electrical and electronic tools, lighting equipments, etc. Some of the medical devices, monitoring and control instruments and IT and telecommunications equipments are, however, exempted from being WEEE compliant.
Environmental compliance services – beyond the EU
For the average office, environmental compliance management probably rotates around waste recycling and energy usage. However, for the electrical or mechanical engineering company things are far more complex, especially if you ship goods abroad. RoHS, WEEE and REACH EU regulations don’t just affect companies based within Europe – they affect any company trading with the European Union. What is more, many other markets are now governed by laws related to those within the EU. RoHS and REACH compliance have become global issues, making environmental compliance management mandatory for engineering firms, even those trading at a local level. When considering environmental compliance management, you have to consider world conflict and political issues, as well as the harm your products may be doing to the environment. For example, is your company guilty of using conflict minerals? This has nothing to do with the REACH directive, but with the Dodd–Frank Wall Street Reform and Consumer Protection Act, which was signed by President Obama in July 2010, and came into effect in April 2011. The Act called for a sweeping reform of the US financial regulatory system, which among other things required that any company listed on the US Stock Exchange must declare any Conflict Minerals mined in the DRC zone. In other words, any minerals mined in the Democratic Republic of Congo, and adjoining African countries suffering armed conflict. With so many global mandates now in force, many engineering companies are turning to us at Enventure Technologies. We offer a comprehensive range of environmental compliance services which cover everything from ROHS compliance to the Dodd–Frank mandate.
GADSL and the ELV directive – how do they affect your company?
The ELV (end of life vehicle) directive is similar to the RoHS and WEEE compliance schemes, in that it was an EU directive designed to restrict the amount of hazardous materials reaching the environment. This was achieved in two ways: by restricting the substances used in the manufacture of new vehicles and their components, and by environmentally aware recycling methods. Unlike RoHS, WEEE and REACH, the ELV directive is specific to automotive engineering. However, with ASIC and VLSI designs being integral to modern automotive engineering, it has an impact on many electronic and component engineering firms, both in the EU and globally. Like the REACH directive, ELV compliance has been adopted across the world, with most countries on the global manufacturing platform having their own versions in place. The GADSL (Global Automotive Declarable Substance List) is intrinsically linked to both the ELV directive and the IMDS (International Material Data System), which was established in response to the directives being put in place. The IMDS was established by OEMs in order to establish a global tracking and logging system for materials being used in automotive parts and accessories. It requires that all parts and components used in automotive assemblies and sub-assemblies list the chemicals used in their manufacture. The lynch pin of this is the GADSL, which is a list of all prohibited and declarable substances used in automotive applications, together with threshold limits. If you engineer mechanical or electronic components for the automotive industry, these rules affect you. We at Enventure Technologies offer environmental compliance solutions for all engineering sectors, with particular expertise in the area of GADSL and ELV compliance.
Does your ASIC design reflect a conflict of material interests?
Every printed circuit board and VLSI design seems to rotate around checking if solders are RoHS compliant, and if corrosion coatings obey the REACH directive. Now, there’s a new question – does it involve using conflict minerals? Conflict minerals have nothing to do with WEEE and RoHS directives, but with the humanitarian crisis in Africa, and the passing of the Dodd-Frank Wall Street Reform and Consumer Protection Act, signed by President Obama in July 2010. At the time seemingly of little relevance to PCB design materials, it represented the biggest financial shake-up in the US since the Depression. But a number of statutes regarding overseas trading were introduced, including that concerning conflict minerals. Conflict minerals are certain ores which have been mined in the DRC Zone, an area of conflict which encompasses the Democratic Republic of the Congo and the adjoining countries of Angola, Congo, Rwanda, Burundi, Tanzania, Sudan, Uganda, Zambia, and the Central African Republic. This is an area of extreme and ongoing violence, involving civilian atrocities on an unimaginable scale. An estimated seven million people – many of them women and children – have died since hostilities began. The list of conflict minerals includes Tantalum, Wolframite and Cassiterite – all of which are used in electronic circuitry and VHDL design. By law, any engineering company listed with the US stock exchange, who uses these products, must declare if they originated from the DRC Zone. No engineering company in the US wants to fund the DRC hostilities, but it’s often hard to gauge where products originate. We at Enventure Technologies offer a wide range of environmental compliance services, and are one of the few companies covering conflict minerals legislation.
Annex II of the ELV directive relaxes rules for automotive system development
Automotive hardware design is a lucrative area for mechanical engineering professionals – but fraught with environmental compliance management issues. As well as GADSL and the international material data system, there’s also the ELV (end of life vehicle) directive. Like the RoHS and WEEE compliance schemes, ELV restricts the use of four toxic metals – lead, cadmium, mercury, and hexavalent chromium. However, the EU now realizes there are certain applications where the use of these substances cannot be avoided and have relaxed the rules accordingly. ELV includes mechanical design (Unlike the WEEE/ROHS directives, which focus on electronic and electrical equipment). For example, ELV covers the use of lead in galvanized steel; not just sheet metal, but that used for machining purposes and hot-dip galvanized steel components. These have been subcategorized and clarified. Other exemptions cover the use of lead in vibration dampers and lead in glass and ceramics. The latter category covers VHDL design and even FPGA design, as it describes lead used in dielectric ceramic materials of capacitors, both in integrated circuits and as discrete semiconductors. Interestingly, a new exemption has been added for lead-containing thermoelectric materials used in automotive system designs which reduce CO2 emissions. New changes regarding the use of hexavalent chromium in absorption refrigerators (used in motor caravans) and mercury in lamps were also described. In many cases, existing exemption dates have simply been shifted, or wording changed. In others, the changes are more significant. We at Enventure Technologies offer a wide range of services to the auto industry, including data cleansing solutions to aid ELV compliance management.
Changes to ELV directive make life easier for automotive system designers
ELV compliance management can be a time-consuming and confusing issue for those involved with automotive mechanical engineering, or who make embedded firmware for the automotive industry. However, a recently added annex to the ELV directive has made environmental compliance management just a little easier for the automotive engineering industry. The ELV directive was introduced to address the impact that dismantled end of life vehicles have on the environment, with regard to toxic waste reaching landfill sites. It was issued in line with the WEEE/RoHS directives, and among other things placed strict limits on the levels of lead, mercury, cadmium and hexavalent chromium to be used in the design and manufacture of motor vehicles and their components. This made things extremely difficult for many automotive design engineers, who found the new rules unfeasible for certain system designs and engineering applications. Evidently, the message reached the right people, because on March 30, 2011, Annex II of the ELV directive was unveiled. This is a list of ELV exemptions, which acknowledges the fact that the use of the four heavy metals mentioned above is technically unavoidable for certain components and materials. The new exemptions make regular data cleaning an essential part of your environmental compliance management strategy, as the exemptions are periodically reviewed to see if they are still warranted, in a process known as ATP, or Adaptation to Technical Progress. We at Enventure Technologies offer targeted environmental compliance solutions for the automotive engineering industry, ensuring you are always up-to-date with the latest WEEE, RoHS and ELV compliance changes.
Is your Californian VHDL design RoHS compliant enough for the EU?
California has adopted its own versions of the EU WEEE and ROHS compliance laws – but if you are exporting goods to EU states, you still need to follow the EU ROHS/WEEE rulings, because Californian protocol may not be enough. The RoHS and WEEE directives have become global acronyms, generic terms for the regulation of hazardous materials used in electrical and electronic equipment, and for its disposal. Each country and state manages its criteria differently. Therefore, you should not assume that RoHS WEEE legislation outside the EU mirrors that within it. The California SB 20/SB 50 statutes were introduced in January 2007, under the California Electronic Waste Recycling Act of 2003. Although similar to the EU directives, the Californian versions have important differences which those exporting printed circuit boards and other EEE products to the European Union must be made aware of. Although the SB 20 ruling has banned the sale of electronic devices prohibited under the EU RoHS directive, this is across a far narrower range of products and materials. It covers only the four heavy metals (lead, cadmium, hexavalent chromium and mercury), and applies only to CRT, LCD and plasma screens which are diagonally four inches or larger across. There have been some changes to bring Californian RoHS more inline with that of Europe. For example, the SB 50 ruling has extended the range to include manufacturer-refurbished products. In 2010, the Lighting Efficiency and Toxics Reduction Act brought lamps and bulbs into the picture – adding another tier of complexity! Being WEEE/RoHS compliant is a minefield wherever your business is located. We at Enventure Technologies offer a full range of environmental compliance services to help you cope.
The RoHS directive: Can we really live with lead-free solders?
The RoHS/REACH directive bans the use of lead in PCB layouts, ASIC designs and other electronic systems, which has had far-reaching consequences for the engineering industry worldwide. Following the global adoption of the RoHS regulations, there has been a monumental shift towards lead-free solders by component manufacturers and PCB designers. However, the decision has proven both controversial and costly, not least to the customers. The problem with omitting lead from tin solders is that, in its absence, spontaneous crystalline ‘whiskers’ can form. Electrically conductive, they can take anything from a few days to several years to develop, and sometimes (no-one knows why) don’t grow at all. They can bridge contacts, short electrical circuits, bridge traces, and no printed circuit board or VLSI design is exempt. In a piece of military (or civil) avionic hardware, the results can be catastrophic. There is currently no fail-proof way to test susceptibility of new PCB designs to whiskering, no way of predicting its occurrence, and no guaranteed prevention, except a minimum 3% lead addition. Many of the hardware systems using embedded firmware – for example, military applications – are exempt from environmental legislation. However, in a predominantly OTS (off the shelf) industry, component manufacturers aren’t prepared to start making specialist one-off products. It costs them money. Can we live without lead solders? It seems we may have to. The race is on to find suitable alternatives, but in the meantime those still using traditional lead-containing components will find them harder and harder to obtain. Part obsolescence management and PCN alerts are just two of the solutions we at Enventure Technologies offer, to help you cope with problems caused by environmental compliance.
Environmental compliance and EMC emissions
Environmental compliance is not confined to the RoHS/WEEE directive and International Material Data System. As well as the materials used in manufacturing, there is the environmental impact of the system design itself to consider, such as EM (electromagnetic) emissions. EM compliance is a major issue for any electrical/electronic hardware designer, whether their product produces EM intentionally (as in some digital signal processing applications) or unintentionally, as in computer design. Electromagnetic emissions are released from any system which has a current running through it, either as a series of pulses or a continual stream. If not kept to a safe level they can be a danger to health, causing nausea, headaches, depression, sensory hallucinations and even cancer. However, the risks can be minimized by effective system design and screening. As with many areas of environmental compliance, the EU has a stringent EMC directive, which all OEMs exporting products to Europe must adhere to. US directives are more limited. The FCC (Federal Communications Commission) ruling covers digital signal processing in broadcasting and telecommunications, while the SAE (Society of Automotive Engineers) has a protocol in line with the EU automotive EMC directive, which became law in 2006. All electrical systems must undergo stringent testing to ensure they meet EM environmental compliance regulations. However, around 50% of prototypes fail the first test. New Pre-test EMC system software, similar to that used in computational fluid dynamics, is helping to minimize this. We at Enventure Technologies offer an extensive range of engineering services for those affected by EMC legislation, from part obsolescence management to DSP programming.