One of the greatest challenges electronics manufacturers continue to face in complying with the ever-expanding set of regulated chemical substances today is being aware of – in advance – whether any of the regulated substances are contained in their products. Despite a decade or more of demanding information on substances from their supply chains, the vast majority of manufacturers have little knowledge about substances beyond the RoHS six: lead, mercury, cadmium, hexavalent chromium, PBBs and PBDEs. And despite the Joint Industry Guide, JIG-101, having been around since 2005 (now supplanted by IEC 62474), most manufacturers can’t even seem to get information on that set of substances from much of their supply base. And with the list of disclosable REACH Substances of Very High Concern (SVHCs) at 151 heading toward as many as 500 by 2020, the industry appears to have a long way to go.
What is going on? Why is this the case? And what needs to change? I’ll try to provide some answers and direction in this post.
Except in rare instances, Electronics OEMs historically didn’t really care what materials were in their products. Awareness of substance identity often didn’t come to light unless there was a problem with form, fit, function, quality, reliability or availability. You didn’t really care whether the ceramic of that 20pf C0G 0805 SMT capacitor contained lead or not; you just cared whether its capacitance was 20pf and its electrical properties followed C0G characteristics for stability over time and temperature. And you really didn’t care what flame retardant and colorant was in that gray plastic front bezel; you just cared that it met UL94 V-0 flammability requirements and is the right Pantone® color. Oh, and that it didn’t fade too quickly due to exposure to light.
Today OEMs do care, but mostly only to the extent that substances are regulated or not; they still are not in the same league as form, fit, and function (and cost).
Chemical substances are selected to optimize electrical, mechanical, optical, thermal, acoustic, etc. properties of a component or material, and to continue to provide those properties across the expected life of the component or material. But in addition to these desired and characterized technical properties, chemical substances also have a host of other properties that often are not meaningful or critical selection criteria. These may include other classical and well-understood technical parameters like boiling point or tensile strength, but they also include human health and environmental parameters such as carcinogenicity and eutrophication. Every chemical substance probably can be measured in these terms but surprisingly few have. The more we as a species learn about an increasing number of substances, the more likely our governments (and customers) are to identify substances that will become regulated.
And that is the crux of the challenge.
Component and material suppliers historically have been specifying substances without considering potential for regulation based on environmental or human health properties. And as we become aware of the fact that they have to consider these properties, the designers find that information allowing their assessment in these areas is wanting (as is their education about how to interpret toxicity data). They – and OEMs – further find that they are stymied when trying to find out what chemicals are contained in materials they specify, such as adhesives, paints, inks, lubricants, and plastic resins. Since the identities of these substances have never been as important as the functionality they provide, the chemical and formulator industries that supply the electronics industry have been able to treat this information as proprietary and build up intellectual property around the identity of molecules.
Secondarily, but not far behind, is the fact that the automated, standards-based system infrastructure to transfer this information to the OEM – which may be initiated many levels back up the supply chain – simply does not exist. It’s still hard enough to get accurate RoHS information in a coherent and correct manner, much less information about everything else. An OEM will receive data in a wide variety of formats, requiring human intervention (and therefore the inevitable introduction of errors) to enter it into a database.
So is the upstream chemical industry being more forthcoming about material composition? Not much. This has been creating enormous tension and frustration downstream in the supply chain for years. As OEMs have spent substantial resources to obtain and manage this information in order to be as proactive as possible while the regulatory constraints tighten, the upstream supply base generally has refused to cooperate. Believing that their only intellectual property is the identity of chemical substances and that they can’t trust the customers they signed non-disclosure agreements with to not disclose their secret sauce to their competitors, the upstream chemical and formulation industries continue to hide substance identities and refuse to provide anything more concise than a “yes” or “no” response when asked whether a product contains a specific substance.
The bottom line here is that substance identity must ultimately become a known, specifiable and disclosable property because of how the electronics industry is being regulated, and can expect to be regulated for the foreseeable future. If the industry was being regulated based on degree of carcinogenicity in a specific application then the carcinogenicity parameter would be important, but it’s not. And that’s resulted in the industry creating their own, rear-view-mirror-facing approaches to control of substances, like IEC 62474. This is not a bad thing, but it’s not forward-looking – it doesn’t provide any guidance on what substances should be used in products or what their human health and environmental properties should be, just what should not be used.
The electronics industry is often on the leading edge of using new molecules and the materials they enable. It therefore runs a significant risk of designing in substances that will later need to be replaced. A better approach would be for the upstream chemical industry to work closely with their customers to understand the needs, then develop molecules using Green Chemistry and Green Engineering principles. This, of course, requires the customers – the component manufacturers – to partner with their suppliers to a very significant degree.
If the upsteam suppliers could demonstrate that substances in use were not worthy of regulatory control due to their lack of toxicity in electronics applications, they wouldn’t be under any pressure to reveal just what those substances are. This would protect their intellectual property while at the same time dramatically improving customer satisfaction. Starting off by screening all the substances they use against these principles – or even just known toxicological data – and targeting the highest risk substances (in terms of potential for regulation) for replacement would be a great place to start.
Statements of fact and or opinions expressed in MarketEYE by its contributors are the responsibility of the authors alone and do not imply an opinion of the officers or the representatives of TTI, Inc.
Mike Kirschner is a product environmental compliance and performance expert who provides advice and expertise to manufacturers in a variety of industries. His primary areas of focus include EU RoHS, the impact of EU's REACH regulation on article manufacturers, California’s Safer Consumer Products regulation, and performance standards like IEEE-1680.x for electronics. Mike helps manufacturers define, implement and troubleshoot internal management systems that result in compliant products, and assesses and monitors environmental regulations around the world on their behalf. ( More... )
He contributed two chapters to the Governance, Risk, and Compliance Handbook, published by Wiley in 2008, and is featured in the critically acclaimed book, Exposed: The Toxic Chemistry of Everyday Products and What's at Stake for American Power. In 2009 he was appointed to the California EPA Department of Toxic Substance Control's Green Ribbon Science Panel. Prior to joining ENVIRON, Mike founded product lifecycle and environmental consultancy Design Chain Associates, LLC (DCA), where he served as president and managing partner. Before founding DCA in 2001, Mike spent 20 years in engineering and engineering management roles within the electronics industry with manufacturers including Intel and Compaq. He holds a BS in electrical engineering from Worcester Polytechnic Institute.