Get the Lead Out - Standards Aid in RoHS Compliance
RoHS, the seminal European sustainability directive, and others like it challenge manufacturers to eliminate hazardous substances in their products. With RoHS compliance deadlines ongoing through at least the next five years, and more to come from other regions and nations, ASTM Committee F40 is helping companies with testing standards and other resources.
The recent introduction of the new Apple iPhone 6 was an occasion of great joy for tech geeks all over the world. But the effect of frequent technology updates and upgrades on the global waste stream — millions of older cell phones discarded in favor of the latest version — is equally dramatic, albeit less joyful.
Simply disposing of all this e-waste is difficult enough, but there’s an added — and very serious — complication: the presence of toxic elements like lead, mercury and cadmium. The need to deal with the massive quantity of obsolete electronic products and the hazardous materials found therein has generated a plethora of regulatory initiatives around the world and even spawned an ASTM International technical committee to help affected businesses navigate the ins and outs of compliance. (More on that later.)
One of the first, and most influential, of these protocols is RoHS, an eight-year-old regulation whose ongoing, rolling deadlines are still challenging manufacturers.
A Bit of History
RoHS is the shorthand acronym for Directive 2002/95/EC, Restriction on the Use of Certain Hazardous Substances in Electrical and Electronic Equipment. Developed by the European Union, RoHS took effect on July 1, 2006, and addressed the presence of three specific heavy metals — lead, mercury and cadmium — as well as hexavalent chromium, polybrominated biphenyls, and polybrominated diphenyl ether in eight categories of electrical and electronic equipment (see below, “RoHS: Targeted Products and Substances”).
The goal of the RoHS directive was to limit the exposure to these six targeted substances among people involved in the manufacture and use of electronic equipment. It was conceived as a “front-end” complement to the Waste Electrical and Electronic Equipment, or WEEE, directive (2002/96/EC), which established disposal and recycling goals for EEE waste on the back end. The premise: Products that are RoHS-compliant when sold will be WEEE-compliant when discarded.
RoHS2 (Directive 2011/65/EC) represented the next step in the EU’s ongoing efforts to eliminate the use of hazardous substances. Issued in July 2011 and in effect since January 2013, RoHS2 expanded the roster of targeted electronic equipment to include medical devices, monitoring and control equipment, and all other EEE not already covered by existing categories (with some exemptions). A series of rolling deadlines — July 2014 for medical devices and monitoring and control instruments, July 2016 for in vitro diagnostic devices, July 2017 for industrial monitoring and control instruments, and July 2019 for everything else — was established for the full phase-in of RoHS2.
Well aware of the impact of this regulatory regimen on manufacturers who would now have to document the material content of their products to a heretofore unprecedented degree, ASTM formed Committee F40 on Declarable Substances in Materials in 2005. The committee “addresses issues related to the development of standards for the evaluation of materials/products relative to RoHS (and similar) requirements” and has thus far developed seven standards to aid manufacturers and testers in identifying levels of hazardous substances.
The Cost of “New and Improved”
“Used to be, when your TV broke, you took it to a repair guy,” says Scott MacLeod with a wistful chuckle. But nowadays the cost of fixing that HD model is often close enough to the price of a new, even better one that people just throw out the old TV and move on. Take this scenario and expand it exponentially to encompass the myriad types of electronic devices we rely on every day — as well as all the old 8-tracks and VCRs in our attics and garages — and you begin to see the scope of the problem that RoHS2 and similar regulations are designed to address.
MacLeod is a principal chemist in the Performance Materials division of Underwriters Laboratories, Melville, New York, and chairman of ASTM Subcommittee F40.01 on Test Methods. “Before RoHS, when we talked about pollution from manufacturing, the focus was on toxic byproducts of the manufacturing process itself,” MacLeod says. “Now we’re talking about the substances that are actually in the products. This is a fundamental change.”
As a self-described “test guy,” MacLeod is especially attuned to the challenges inherent in determining the presence of banned substances in RoHS-targeted product categories. His subcommittee played an important role in the development of a number of relevant ASTM standards, including F2617, Test Method for Identification and Quantification of Chromium, Bromine, Cadmium, Mercury and Lead in Polymeric Material Using Energy Dispersive X-Ray Spectrometry, and F2980, Test Method for Analysis of Heavy Metals in Glass by Field Portable X-Ray Fluorescence.
Taco van der Maten, chairman of Committee F40, is quite familiar with X-ray fluorescence spectrometry, or XRF. Van der Maten’s “day job” is product manager for XRF at PANalytical, Almelo, The Netherlands, a world leader in X-ray analysis systems.
“RoHS is a moving target, so to speak,” van der Maten asserts, “which is why ASTM Subcommittee F40.02 [on Management Practices and Guidelines] is very important, keeping track of what’s happening in the world with all these restricted substances.” The subcommittee is developing a guidance document for the identification of declarable substances in polymeric materials. It has also approved two guides — one for assessing materials and products for declarable substances (ASTM F2577) and another for supply chain information exchange for substances identified by the EU’s REACH regulation (Registration, Evaluation, Authorization and Restriction of Chemicals) (ASTM F2725). (See “Committee F40 on Declarable Substances in Materials: the Standards,” for complete titles.)
Following the Supply Chain
One of the most challenging aspects of the original RoHS (and the more recent RoHS2) is the provision on “homogenous materials.” So how is a homogenous material defined under RoHS?
To quote from 2011/65/EU, “‘homogeneous material’ means one material of uniform composition throughout or a material, consisting of a combination of materials, that cannot be disjointed or separated into different materials by mechanical actions such as unscrewing, cutting, crushing, grinding and abrasive processes.”1
In practical terms, this means that a manufacturer can’t simply provide test results showing that its electronic product, considered as a single object, meets the limit on lead, mercury, hexavalent chromium, PBB or PBDE (0.1 percent), or the stricter 0.01 percent limit for cadmium. It means that documentation is required for every nonhomogenous component within that product.
Take, for example, the circuit board — an integral element of many electronic devices. Circuit boards consist of a number of constituent parts: capacitors, resistors, switches, etc. The manufacturer of any device containing a circuit board must be able to prove that each homogenous material in that board’s array of parts also comes in under the RoHS limit.
Put another way, if the ceramic insulating material in a capacitor fails to meet the standard for any of the six restricted substances, the object containing the circuit board with said capacitor also fails.
This scenario illustrates how important it is for each company that goes to market with electronic devices to maintain a comprehensive database on the provenance of every part and material used in its products. “You must be able to prove that everybody in your supply chain is in compliance,” says John Sieber, a chemist with the National Institute of Standards and Technology, Gaithersburg, Maryland.
Toward this end, ASTM test methods have proven very useful to companies as diverse as Depuys Synthes, a global supplier of surgical instruments and implants, and Intel, the world’s largest manufacturer of semiconductors.
According to John Disegi, group manager for materials development in Depuy Synthes’s R&D division, West Chester, Pennsylvania (and a 35-year ASTM member who received the ASTM Award of Merit in 2003), “Many of our primary suppliers that issue certification of compliance to ASTM standards for implant and instrument alloys are also certifying RoHS statements of compliance. This practice is beneficial because one quality document covers ASTM and RoHS certification.”
The main effect of ASTM standards on Intel has been to educate people both within and outside the company. “Intel has found, especially in the early days (2000 – 2006), that many companies didn’t understand what was actually required to report or how to report, what collaterals they needed for compliance or even how to perform a risk assessment,” says Dick Casali, product ecology technical manager at Intel, Hillsboro, Oregon (and another very active ASTM member). “Companies were also doing too much testing or not enough of the correct tests. Intel became involved in ASTM to help standardize and teach companies, from the very small to the very large, how to comply with regulations and which tests to use for screening or quantitation, as well as to provide our input on new standards for test methods.”
Casali cites standard F2617, Test Method for Identification and Quantification of Chromium, Bromine, Cadmium, Mercury and Lead in Polymeric Material Using Energy Dispersive X-Ray Spectrometry, as having had a positive impact on Intel’s business.
Even companies outside the immediate realm of EEE are affected. Take Caterpillar, the Peoria, Illinois-based manufacturer of heavy equipment and power systems. Yong Li, engineering project team leader for chemical management in the Product Compliance and Support division, notes that Caterpillar has thousands of unique suppliers — and many engine products that include electronic components that fall under RoHS.
“These regulations have actually served as an extra driver to get data from suppliers and make our entire manufacturing process more efficient,” Li says. “Our engineering and research teams are working on alternate technologies to address the RoHS requirements.”
A Story about Solder
The humble material known as solder is an illustrative example to any discussion of the search for alternatives to RoHS-designated hazardous substances. Because common versions of this fusible metal alloy, used to join metal workpieces, were traditionally made with lead, they came under the purview of RoHS. Any company that wanted to sell its electronic products in Europe had to prove that the solder in those products was lead-free.
Sieber notes that NIST, one of a number of organizations participating in the ASTM process to develop standards for declarable substances, “did not have a Standard Reference Material related to lead-free solder at the time of the initial RoHS. Now there are three.” These SRMs are used to validate the testing used to confirm the absence of lead.
Testing is, of course, at the heart of any regulatory scheme, as well as efforts to establish meaningful product component databases. “Some countries and manufacturers are requiring proof that the companies testing materials are competent,” Sieber says. “Customers want proof that none of the restricted substances are present.”
This can be a challenge in cases such as hexavalent chromium coatings, which are used to prevent corrosion. “You might be talking about a coating on a heat sink that is somewhere between 100 and 400 nanometers thick. Very thin layers like this are difficult to analyze,” Sieber says. “Test method standards are still in development.”
Despite the challenges, RoHS has already had a significant impact. According to its March 2008 final report of the “Study of the RoHS and WEEE Directives,”2 consulting firm Arcadis/Ecolas noted that lead, cadmium and mercury in EU waste streams were at that time reduced by 20, 63 and 56 percent, respectively (percentages are approximate and the time frame for the lead reduction figure was not specified).
The Role of ASTM
The increasingly international scope of ASTM standards development activities is particularly valuable in view of the proliferation of RoHS-type regulations around the world. “The EU system is very much based on harmonized standards to demonstrate product compliance with respective EU legislations,” says Joachim Wilke, director of regulatory affairs and policy in Europe, Cologne, Germany, for Medtronic, a global medical device manufacturer. “ASTM support on the development of high-quality, market-relevant, international standards — for instance on RoHS compliance testing — is very much appreciated.”
It’s important to note that ASTM is not the only organization working in the RoHS arena. The International Electrotechnical Commission, or IEC, is another key player, through Technical Committee 111, Environmental Standardization for Electrical and Electronic Products and Systems. UL’s Scott MacLeod and John Sieber of NIST are both members of the U.S. Technical Advisory Group (TAG) to Technical Committee 111 as well as technical expert members of TC 111 itself.
Though there’s always the possibility of turf battles in such a crowded standards development landscape, ASTM stands ready to work with other organizations in seeking the broadest possible consensus. In the words of Committee F40 chairman van der Maten, “ASTM is very open to international collaboration.”
For its part, the 130 international members of Committee F40 are working with stakeholders around the world to maintain existing and develop new standards that allow manufacturers and testing laboratories to identify and quantify restricted substances in materials and products. (See below for a list of F40’s existing and proposed standards.)
In March of this year, the committee held its standards development meetings in Shanghai, China, and invited local stakeholders, including government officials, to a workshop on rare earth materials. Committee members and ASTM staff also attended and presented at a workshop on new chemical substances and a roundtable event on RoHS.
This type of cooperation will be essential in the coming years. Van der Maten’s allusion to RoHS as a “moving target” takes on added significance in view of the fact that RoHS2 also sets the stage for further expansion of the list of declarable substances; phthalates (softening agents used in certain plastics) and hexabromocyclododecane (another flame retardant additive) are specifically mentioned. In addition, a host of other countries, including Canada, China, Japan and South Korea, have followed in the footsteps of the EU and developed their own RoHS-style regulations.