More than just considering the performance categories of materials, connector manufacturers and resellers must also learn how to weigh every material’s impact on the overall environment during the entire life cycle of the product.
BY WASIM KHOKHAR
The Restriction of Hazardous Substances (RoHS), which went into effect in the European Union on July 1, 2006, is still fairly new to the North American market, and there remains misunderstanding as to what the directive requires. Effective training, however, can provide an overview of the reasons behind the directive, as well as its effect on product design, development and manufacturing.
Manufacturing companies in particular must be more cognizant of the types of materials that are specified in the design of their products-both on the manufacturing floor and in the way in which they communicate critical information regarding the directives to customers when assisting them with compliance.
In addition to the European Union, RoHS directives are in effect in China, referred to as China RoHS, and similar restrictions on hazardous substances are in place in Japan and South Korea. In the United States, various states are reviewing RoHS-type legislation and are considering the adoption of many different kinds of laws regulating electrical and electronic products. California, for instance, already has adopted RoHS requirements for video displays (referred to as California RoHS) and has has a pending bill to expand regulated product categories each coming year.
Manufacturers in the United States export billions of dollars worth of electrical equipment built with components affected by RoHS to the European Union, as well as China, Japan and South Korea. The effect so far has included increased costs for changes in product design and manufacturing, as well as the challenge of using newer, compliant raw materials while meeting existing product performance criteria.
Instead of considering only the performance categories of materials, however, manufacturers and resellers must now also consider the future impact these materials will have on the overall environment during the entire life cycle of the product.
Manufacturers have seen an increased amount of activities in their facilities in requesting, collecting and processing crucial material information from vendors. Customers are also requesting more details on the material content of products provided by manufacturers.
In addition to RoHS directives from the European Union, China and California, product compliance must consider other directives and legislation, such as the European Union’s Waste Electronic and Electrical (WEEE) Directive, Registration, Evaluation and Authorisation of Chemicals (REACH), End of Life Vehicle (ELV) Directive, and the Energy Using Products (EuP) Directive, as well as Joint Industry Guide (JIG)-101 and the International Electrotechnical Commission (IEC) requirements, among others.
Clearly, companies at each stage in the electrical and electronic industry’s supply chain must possess a clear strategy and implementation plan to deal effectively with all of these changes.
The role of training
Most directives, including RoHS, tend to be very complicated, so it becomes imperative that all individuals involved in a compliance program be trained properly to understand the details of a particular directive. Often, if the main intent of a directive is made clear during training, it is easier to grasp and understand the fine points. In RoHS, the hardest part is keeping up with the frequent exemption changes, and that can be done only with an ongoing training program.
Different types of job functions require different levels of training. Those who are applying specific RoHS information to determine compliance need to understand detailed requirements and what makes one product compliant and another not. They also need to know the difference between acceptable and non-acceptable forms of documentation from vendors. Technical service workers who answer customers’ questions about compliance require a deeper understanding of applications governed by the directive.
Training at Thomas & Betts Corp., for example, deliberately involves its operations and technical service groups in its ongoing RoHS project to ensure that all relevant participants know what to do. Regular conference calls and webinars are among the most effective ways of communicating the latest information.
Thomas & Betts Corp. has also developed a Sales Application Training module for its sales force to enable representatives to communicate the correct RoHS information to their customers. The module provides the intent of the directive, basics of the requirements, related impact to business, and details on how field sales and customers can get information from the company’s website to improve response time on inquiries.
Successful strategies
A benchmark study from the Aberdeen Group (www.aberdeen.com), presented in March at an event sponsored by IHS (www.electronics.ihs.com), indicated that companies are challenged in compliance by not only the complexity of regulations, but also the lack of reliable product data and the extraordinary effort required on the part of personnel, who often lack the necessary resources or expertise to be effective.
The research also indicated that the companies that were the most successful with compliance were the ones that most often meet or exceed the strictest standards globally, and implement compliance policies in anticipation of requirements going into effect, rather than waiting until standards are in place and enforced. These companies also tend to include full substance disclosure in their documentation, as opposed to documenting only regulated substances or indicating only if the product is or is not exempt.
The research also indicated that these leading companies’ efforts result in at least 90% of their products being compliant, and that the companies experienced fewer stopped shipments and product recalls. The costs that the most successful companies incurred when implementing these compliance policies, however, were about the same as what other non-implementing companies incurred.
In addition to implementing a policy in which products meet or exceed the strictest global standards, the study recommended that policies be incorporated into the conceptual design and new product development processes, and that companies demand more detailed information about product composition from suppliers. Other recommendations include content audits, standardized and centralized compliance processes, and automated compliance processes in a compliance infrastructure.
Managing compliance
All companies in the electrical and electronic industry supply chain are responsible for providing accurate RoHS compliance information. Failure to keep accurate compliance records and provide accurate compliance information can expose companies to civil and criminal penalties.
It’s clear that there is a major need to educate workers in the entire supply chain on this topic. Design engineers, manufacturing engineers, purchasing managers, material managers, technical support, field sales, vendors and customers need basic training on RoHS regulations to keep their products in compliance.
WASIM KHOKHAR is regulations affairs engineer with electrical components manufacturer Thomas & Betts Corp. (www.tnb.com), Memphis, TN.
Threshold percentages for homegenous materials
The RoHS directive, as most companies are now aware, restricts the use of lead, mercury, cadmium, hexavalent chromium (chromium VI), polybrominated biphenyls (PBBs) and polybrominated diphenyl ether (PBDE) in the manufacture of electrical and electronic products. It applies to manufacturers and resellers, including distributors, importers and representatives, who supply electrical or electronic products, sub-assemblies or components directly to customers in member countries of the European Union.
The European Union pursued this legislation to protect its citizens from the potential health hazards posed by these substances, as well as to increase the percentage of products that can be recycled in response to the dwindling space available for landfills.
Under RoHS, threshold percentages are defined for each substance, and these percentages should be maintained at each individual homogenous material level.
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According to the European Commission, a homogeneous material is one that cannot be mechanically disjointed into different materials and is of uniform composition throughout. Examples would include plastics, ceramics, glass, metals, alloys, paper, board, resins and coatings. A guidance notice from the British government defines “mechanically disjointed” as separating materials through mechanical actions, such as unscrewing, cutting, crushing, grinding, or an abrasive process.
RoHS requires that compliance be determined for not only each component, but also for each composition of material within each component.
The Russellstoll connector assembly is shown below with its various component parts displayed in an exploded view. When assembled, these components are joined together mechanically. The neoprene bushings and other plastic components have homogenous material throughout, making it relatively easy to determine their compliance with RoHS. Metal pins and screws, however, may have corrosion-protective coatings. In the case of plastic components, the materials will remain the same after “unscrewing, cutting, crushing, grinding and abrasive processes.” In the case of metal fasteners, however, removal of the protective coating will leave a second homogenous base material.
As this example shows, RoHS compliance must be determined for every homogenous material. - WK
