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RoHS Compliance Date July 1, 2006 -
What is Your Plan to Mitigate The Potential Risks?
by Capaccio Environmental Engineering, Inc.
The
Restriction of
the use of certain Hazardous Substances (RoHS) in
electrical and electronic equipment, 2002/95/EC European
Directive deadline of July 1, 2006 is right around the
corner. Electrical and electronic manufacturers and
component suppliers are diligently working towards RoHS
compliance. A broad range of risks are being introduced by
manufacturers of electrical and electronic equipment and
their suppliers, as they develop new processes, create new
products, and integrate manufacturing strategies for RoHS
compliance. The RoHS Directive, requires the removal of
regulated materials from electrical and electronic
products creating various risks for the producer of the
electrical and electronic equipment. Developing
contingency plans and applying external expertise in
managing risks should be a key part of the transition to
RoHS compliance.
Background
The
RoHS Directive is a European Union (EU) Directive
requiring producers of Electrical and Electronic Equipment
to remove specified hazardous substances from their
electrical and electronic equipment. The substances
identified by the directive are Mercury (Hg), Lead (Pb),
Cadmium (Cd), Hexavalent chromium (CrVI), and Brominated
flame retardants: polybrominated biphenyls (PBB), and
polybrominated diphenyl ethers (PBDE). The European
community created the RoHS Directive to protect the
quality of life for the citizens of the European Union. A
study of landfill wastes found that decomposing electrical
and electronic equipment was releasing hazardous
substances from landfills into the environment, resulting
in a direct impact on the health of European Union
citizens. Thus, the restriction of the use of
certain hazardous substances (RoHS) Directive was born to
phase out hazardous substances from electrical and
electronic materials.
RoHS Risks
Electrical and electronic suppliers are expected to
provide “RoHS compliant” equipment into the European Union
(by July 1, 2006). Meeting the RoHS compliance deadline is
becoming more and more difficult for many electrical and
electronic manufacturers and is resulting in various risks
for RoHS transition teams. For instance, some component
suppliers are only offering the “next generation”
component as “RoHS compliant”, resulting in various risks,
from software revisions, validation, verification, and
customer approval implications, for electrical and
electronic manufacturers to become RoHS compliant.
In another example of a potential risk, in
some cases the component suppliers’ change in materials to
meet RoHS requirements is based on the suppliers’
expectation of no change to form, fit, or function.
However, the suppliers are unaware that during their
customers’ design process for critical and or sensitive
functionality components, there is a potential for an end
product’s specific electrical parameters to be set to a
tighter or skewed electrical distribution. Thus, when the
“change in materials” to RoHS compliance is made by the
supplier, the new version of the component may not fit
within the customers’ designed parametric distribution
needs. This results in the possibility of nonconforming
end products by the electrical and electronic producers.
In addition, the RoHS Directive is
impacting all industries regardless of electrical product
applicability to EU regulations. Component suppliers are
diligently transitioning products to RoHS compliance. In
order to limit the manufacturing cost ramifications of
running multiple manufacturing lines, a single RoHS
compliant product is being introduced by component
suppliers as a single solution product. This industry
trend is forcing all industries producing electrical
products to adhere to the RoHS requirements.
RoHS Risk Management Conclusion
RoHS Risk Management can provide a clear vision to the
team of the identified risks, potential risks, and
consideration of unknown risks, towards a data driven
decision process. RoHS risk impacts can include
change control, new product introduction, component cycle
management, or component conversion.
A key component to risk management success
is the inclusion of external assistance. External
assistance brings hands on experience, industry compliance
trends, and enhances the data driven risk management
process for RoHS compliance teams. Outside expertise and
experience in risk management can be a value added tool to
a RoHS team. RoHS risk management can breakdown
tunnel vision and drive fact-based decision making towards
RoHS compliance.
The July 1, 2006 deadline for restriction
of the use of certain hazardous substances (RoHS) in
electrical and electronic equipment, is right around the
corner. The RoHS directive requires the removing of
regulated materials from electrical and electronic
products and introduces a broad range of risks by
manufacturers of electrical and electronic equipment and
their suppliers, as they develop new processes, create new
products, and integrate manufacturing strategies for RoHS
compliance. What is your plan to mitigate the potential
risks of RoHS compliance?
For further information on European Union
Directives, contact Paula Esty at Capaccio Environmental
Engineering, Inc. 508-970-0033 x128
or click here to
request more information.
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