ROHS changes keep design engineers vigilant
New changes to the European Union’s ROHS (restriction of hazardous substances) directive will force design engineers to watch their BOMs (bill of materials) carefully as a number of exemptions have been targeted to be phased out and still other exemptions will expire in coming years. Companies can apply for individual exemptions, but they have to show evidence that alternatives to the banned substances are not currently available and that future availability comes with scientific barriers.
The challenge for design engineers is to track changes in the ROHS directive and match those changes against their current and future BOMs. The EC (European Commission) with guidance from its technical consultants – Oko Institute and Fraunhofer IZM – has permitted exemptions where there is no technical alternative. With the revised ROHS directive, exemptions will be valid for four years. The exemptions then may be reviewed and eliminated. Manufacturers will need to reapply for exemptions at least 18 months before expiration.
Ultimately, the EC seeks to eliminate exemptions. “The theory is it will stimulate efforts to find alternatives that are more environmentally friendly,” said Gary Nevison, director of legislation and environmental affairs at UK-based Farnell and its US-based sister company Newark.
The EC proposes to withdraw six of the directive’s 29 exemptions (see sidebar). “The announcement of the exemption eliminations is likely to be in 2010, and the Oko Institute is suggesting an 18-month grace period for manufacturers to comply, so we’re looking at 2012,” said Nevison.
That gives manufacturers little time to comply if alternatives are not readily available. “The key point is whether there will be sufficient time for engineers to respond and look for alternatives,” said Nevison. “And where there are no alternatives, they can say, ‘So this is why we need an exemption.’”
Moves to retire exemptions will likely continue over the coming years and additional restricted substances will likely be added to the ROHS directive over time, according to experts. “This is a trend," said Fern Abrams, director of environmental policy and government relations at IPC--the Association Connecting Electronics Industries. "It was clear from the beginning that the European Commission did not want to give any exemptions. They resisted exemptions and viewed them as evasive. The fact that there were exemptions showed that some part of the Commission was receptive to reality and what was technically feasible.”
One of the big challenges for engineers comes when a product has a long lifecycle. While the BOM of a cell phone – with its short lifecycle – can be changed quickly, many other products have lifecycles that span years. “There is always the possibility that exemptions will change during the lifetime of the product,” said Ken Stanvick, VP at Design Chain Associates, a company in San Francisco that helps manufacturers with environmental compliance. “If you look at an exemption that expires in 2011, that’s a short exemption period.”
Industries such as automotive, aerospace, and medical equipment are particularly affected because of the long lifecycle of their products. “The aerospace, automotive, and medical equipment companies are probably the most concerned because of their lead times,” said Abrams. “Engineers are designing in components they might not be able to use. They need to be in touch with this or use consultants to stay on top of these changes.”
Tracking changes to ROHS
A lot of the compliance with ROHS and other directives such as the European Union’s REACH (registration, evaluation, and authorization of chemicals) legislation falls on the shoulders of the design engineer who selects components for the product. It’s not as simple as choosing ROHS-compliant parts -- not when exemptions are changing.
“People will have to redesign some of their products because of restrictions,” said Stanvick from Design Chain Associates. “You may lose one of your suppliers because an exemption went away. It becomes a guessing game as to what will affect your product, so you need a system to alert you.”
Some engineers use consultants for help in predicting whether components will be safe from changes in environmental laws. Others turn to their distributors. “If you’re designing a product that will have a long lifetime, you need to have a process in place that assigns someone to look at all of the changes and check them against your BOM so you can accommodate these directives sufficiently in advance,” said Steve Schultz (pictured), director of strategic planning and communications at Avnet Inc. “We take a high-level view, but we also zoom down to the individual component and work with our customers to review their BOMs.”
So far, it seems the electronics industry is coping well with the announcement that six of the exemptions will be eliminated. “I don’t know how important the revocation of these six exemptions is,” said Abrams of IPC. “I haven’t heard any calls in real panic or even mild panic.”
The quiet phones at IPC may indicate the industry has simply become accustomed to progressive restrictions in substances contained in components. “The lifting of exemptions shouldn’t surprise anyone,” said Pam Gordon, president of Technology Forecasters Inc. “Design engineers now have a methodology for determining which components should go into the work, and they can use that same methodology to restrict the new materials.”
That methodology needs to include a systematic review of the legislation. “One just needs to continually be abreast of the consideration in process and the decisions made as soon as the ink is dry,” said Gordon. “It’s a given that more and more substances will be restricted in your city, state, nation or around the world.”
Gordon noted that some exemptions will probably continue for years to come. “I don’t think anyone, not even the regulators, can predict there will be zero exemptions, even in 2013 or later,” she said. “I met with people in England recently who are responsible for ROHS, and it’s a sane and measured process.”
Another indication that the electronics industry has accepted the ongoing restriction of substances is enforcement. It has been years since there have been major infractions. The last big story goes back to 2001 when Sony’s PlayStation cables were rejected by the Dutch government for too much cadmium. “I hear of very few breeches,” said Nevison. “That suggests that businesses are fairly comfortable with the ROHS directive.”