Voices: Newark/Premier Farnell's Gary Nevison: scoping out the Environmental Design of Electrical Equipment Act
Gary Nevison, legislation and environmental affairs manager at UK-based distributor Farnell and its US company Newark, recently discussed the Environmental Design of Electrical Equipment Act and compared it with ROHS.
By Suzanne Deffree, Managing Editor, News -- EDN, September 17, 2009
As a proposed amendment to the 1976 Toxic Substances Control Act, the Environmental Design of Electrical Equipment Act (Bill HR2420) has stirred much controversy within the electronics supply chain about whether a US version of the EU (European Union) ROHS (restriction-of-hazardous-substances) directive is coming. Gary Nevison, legislation and environmental-affairs manager at global Premier Farnell and its US business Newark, recently discussed the bill and compared it with ROHS. The following text includes excerpts from that conversation.
Is the Environmental Design of Electrical Equipment Act (HR2420), along with the US Toxic Substances Control Act, similar to a US version of ROHS for electronics designers?
First, this new legislation is clearly not ROHS. It would be misleading to talk about US ROHS compliance. The proposed HR2420 is different from EU ROHS, and, although it is claimed to be legislation designed to control hazardous substances, its main aim appears to be preventing states from imposing substance restrictions on products within the scope of this legislation. It would introduce some limited restrictions, but the exemptions list is so comprehensive that these [restrictions] would be few.
So, this act is not the US ROHS that many members of the electronics supply chain have been waiting for?
Initially, this [act] might appear to be so; however, closer scrutiny of the scope and structure of HR2420 reveals that it is ... an effort to limit uncoordinated piecemeal legislation on this issue by individual states. At present, there is no federal US equivalent to EU ROHS, although some states have introduced limited ROHS-like laws. Many manufacturers would welcome a single uniform US ROHS law, as this [law] would remove the need to meet multiple, changing requirements across US states, although others, which predominantly sell internally, may be concerned about this extra restriction.
The main implications of HR2420 are for new chemicals or major new uses of existing ones. For example, products containing substances that are not included in the TSCA [Toxic Substances Control Act] register require certification before they can be imported. TSCA currently imposes very few restrictions on substances, but it does affect lead-based paints, asbestos, and polychlorinated biphenyls.
Please elaborate on how HR2420 differs from ROHS.
Although the bill proposes to restrict the same six substances as EU ROHS at the same concentration values in homogeneous materials, there are no apparent equivalents to 17 EU ROHS exemptions, and there is no use of the EU ROHS product categories. The product scope appears quite different from EU ROHS, as it seems to exclude household or consumer products and include products not covered by EU ROHS, such as electricity-distribution equipment. Another significant difference is that EU ROHS excludes products designed for use with voltages above 1000V ac or 1500V dc, whereas HR2420 has a limit of 300V. The restrictions would apply to products manufactured after July 1, 2010.
So, in summary, the scope of the bill is quite limited and is clearly different from EU ROHS and mainly consists of a detailed list of exclusions and exemptions. As the scope includes many items currently excluded from EU ROHS, HR2420 does not appear to be a federal ROHS bill—more an attempt to avoid disjointed ROHS requirements emerging for products currently outside or on the fringe of the scope of EU ROHS.
Many engineers think that, once the original ROHS hubbub concluded, all of the environmental compliance issues were behind us. Why is it important for engineers and OEMs to continue to work with distributors on environmental compliance issues?
That [ending of controversy] was never the case. Under the original ROHS scope, it was always going to be reviewed, there were always going to be more substances, product categories, etcetera. And now we have the REACH [registration/evaluation/authorization-of-chemicals] directive. There will be more and more and more products and substance [limitations] in the short, medium, and long term, [which] will probably be the biggest issue for design engineers around the world. They will have to seek suitable alternatives to these ever-increasing [number of] substances. This [situation] is kind of a nightmare. It is going to roll and roll and roll for many years.
Sure, engineers could look at all of this on the Web, but there is so much information and so much misinformation that is now dated that a distributor is a good route to take. There are good distributors doing this [work] and there are not so good, but one of the biggest issues for me is whether things ever get deleted from the Web. For the designer, the simple reason would be getting the latest information, providing the distributor is doing the job well.
