REACH and Reliability

Transcription

1 REACH and Reliability DA Pinsky 12/10/08 Copyright 2008 Raytheon Company. All rights reserved. Customer Success Is Our Mission is a trademark of Raytheon Company.

2 Overview of REACH REACH (Registration, Evaluation, Authorization and Restriction of Chemicals) New European Union (EU) legislation regulating chemicals and products that contain them Law regulates substances (chemicals and metals): Estimated 30,000 substances manufactured in, or imported into the EU Estimated 1,500 chemicals may eventually be designated as Substances of Very High Concern (SVHCs) and subject to restrictions Scope of REACH: Affects all EU facilities using chemicals or importing them Affects all products that are sold to an EU customer (direct sales, Foreign Military Sales, and indirect sales) No blanket exemptions like RoHS Impacts all companies doing business in the EU 12/10/2008 Page 2

3 REACH applies to all E.U. States 27 Member States of the European Union are: Austria Belgium Bulgaria Cyprus Czech Republic Denmark Estonia Finland France Germany Greece Hungary Ireland Italy Latvia Lithuania Luxembourg Malta The Netherlands Poland Portugal Romania Slovakia Slovenia Spain Sweden United Kingdom Copyright of the maps is owned by the European Commission but reproduction is authorized. REACH also applies to: Norway, Iceland and Liechtenstein (the green shaded countries are EU candidate countries REACH doesn t apply, but may in the future) 12/10/2008 Page 3

4 REACH vs RoHS RoHS Applies to electronics Includes exemptions Excludes military applications Limited set of substances regulated Threshold concentration is based upon 0.1% by weight homogenous material REACH Applies to all products Substances subject to authorization will be approved for interim usage on an application by application basis only No exclusion for military applications All chemicals are subject to registration SVHC list covers 15 substances but is expected to grow substantially Threshold concentration for SVHC s is based upon 0.1% by weight of the entire article If you work in the commercial electronics industry both regulations will apply 12/10/2008 Page 4

5 REACH Requirements Registration: Requires any substances (chemicals/metals) manufactured or imported to the EU over 1 tonne/year to be registered. Substance manufacturers in EU will do most of the registrations Pre-registrations for potentially regulated substances were due by 11/30/08 Evaluation: The EU Chemicals Agency will evaluate each substance to determine if it is safe for human health and the environment Authorization: The Agency will ban the most toxic substances, unless an authorization for continued use is obtained Communication/Notification: Requires that you communicate to your customers and (sometimes) to the EU Agency if your products contain any Substances of Very High Concern (carcinogens, mutagens, etc) list is estimated to grow to 1,500 Requires significant coordination with suppliers First list of 15 was published October /10/2008 Page 5

6 REACH Requirements- Dates Regulation mandates many activities spread over 10 years! Figure Taken from Guidance on Requirements for Substances in Articles, ECHA /10/2008 Page 6

7 REACH Requirements Imported items are classified into one of three bins Articles Manufactured items shape, surface, design determines function All packaging materials are considered to be separate articles! Substances alone or in a preparation (mixture) Paints Adhesives The associated containers are classified as articles Articles with substances intended for release Articles that release a substance where the substance released is not critical to the function Scented erasers, for example The overwhelming majority of products from the electronics industry will be articles (w/o intended releases) Possible exception of repair and maintenance kits containing preparations 12/10/2008 Page 7

8 REACH Requirements Notification requirements only apply to substances in articles if they are Substances of Very High Concern (SVHC s) and a single legal entity imports greater than one metric ton per year The annual limit is aggregated across all articles imported annually Extremely unlikely for electronics manufacturers The only REACH requirement that non-eu electronics manufacturers will likely be subject to is the communications requirements of Article 33 Provide safe handling and use information if SVHC content of an article exceeds 0.1% by weight Substances in imported articles will not be subject to authorization, but may be subject to future restrictions under Article 67 12/10/2008 Page 8

9 What is an SVHC? Member states or the European Commission can propose candidates for inclusion on the list in any of the following categories Carcinogenic, mutagenic, or reproductive toxics (CMRs) Persistent bioaccumulative toxics (PBTs) Very persistent, very bioaccumulative (vpvb) New candidates will be proposed and added to the list periodically Initial list of 15 substances was published in October 2008 Additional substances will be added sometime during 2009 This list may eventually include thousands of substances Substances on the list will eventually become subject to authorization (banned) 12/10/2008 Page 9

10 Current SVHC list Substance name Anthracene 4,4'- Diaminodiphenylmethane (methylene dianiline) Dibutyl phthalate Cobalt dichloride Diarsenic pentaoxide Diarsenic trioxide Sodium dichromate 5-tert-butyl-2,4,6-trinitro-m-xylene (musk xylene) CAS number EC number Authority Germany Germany Austria France France France France Netherlands General Use Comments wood preservatives, insecticides, and coating materials, pyrotechnics, and dyes polyurethane precursor, curing agent for adhesives Used as a plasticizer in many polymeric material (cellulose fibers and resins, polyurethanes, rubbers, etc PVC). Drying agent, ammonia absorber, electroplating additive Dyes, wood preservatives, production of copper alloys Used as a starting point for the preparation of elemental arsenic, arsenic alloys and arsenide semiconductors. metal finishing- chrome plating, CRES passivation, chromate conversion coatings Fragrances Bis (2-ethyl(hexyl)phthalate) (DEHP) Sweden Plasticizer in PVC Hexabromocyclododecane (HBCDD) Sweden Flame retardant Alkanes, C10-13, chloro (Short Chain Chlorinated Paraffins) Bis(tributyltin)oxide United Kingdom Norway Broad range of applications antifouling agent in paints, industrial water systems and on inner surfaces of cardboard and cellophane containers for tomatoes, and as a wood preservative. Lead hydrogen arsenate Norway insecticide Triethyl arsenate Norway manufacture of GaAs Benzyl butyl phthalate Austria Used as a plasticizer in many polymeric material (cellulose fibers and resins, polyurethanes, rubbers, etc PVC). 12/10/2008 Page 10

11 The SVHC Decision Tree This is likely the only thing US electronics manufacturer will have to do Is it already registered? Likely yes for standard applications Is it intended to be released? NO for nearly all cases for electronics apps Is there more than a metric ton of SVHC? likely NO for all electronics apps Can exposure be excluded? likely YES for all electronics apps Figure Taken from Guidance on Requirements for Substances in Articles, ECHA /10/2008 Page 11

12 Communication Requirement Article 33 of the REACH regulation defines communications requirements for SVHC s in articles Information regarding the presence of SVHC s must be provided to the recipient of the article Consumers are not considered to be recipients The minimum information required to be provided is the names of the substances that are present in excess of 0.1% by weight in the product as produced in the EU or imported This information must be provided automatically Information regarding safe use must be provided to consumers upon request Must provide information within 45 days, free of charge No similar provision for requests from others that are not consumers 12/10/2008 Page 12

13 An Example of a Communication Figure Taken from Guidance on Requirements for Substances in Articles, ECHA /10/2008 Page 13

14 What is an Article Each physically separate item that performs its own function is an article A single product may include one or more articles Example from the guide: a man s three-piece suit consists of three articles ( jacket, trousers, and vest) although they may be sold as a single ensemble Buttons on the jacket are part of the jacket article A small plastic bag of spare buttons in the pocket consists of multiple articles: each button is an article, and the plastic bag is an article! An example of a computer system The monitor, keyboard, mouse with attached cable, each separable cable, and the desktop computer box would all be separate articles Each of the cardboard boxes, Styrofoam inserts, plastic bags, and separate pieces of packaging would also be individual articles 12/10/2008 Page 14

15 Example of SVHC Calculation This means it takes 1000Kg of the SVHC to get to the notification stage Figure Taken from Guidance on Requirements for Substances in Articles, ECHA /10/2008 Page 15

16 What Not To Worry About What Not To Worry About A coat of paint with phthalate on a cabinet will not trigger the 0.1% limit A container of touch up paint with phthalate in excess of the 0.1% limit will only require communication of its presence Packing materials totaling less than 100,000Kg per year Foam is one article Packing peanuts is one article Cardboard is one article Sheeting is one article What Would Cause Worry ~100,000Kg of desiccant with 1.0% cobalt dichloride in it ~ 500,000Kg of cushioning foam/peanuts with 0.2% fire retardant that is expected to be discarded upon arrival in the EU ~ 50,000Kg of 2% Di(2-ethylhexyl)phthalate containing PVC pallet wrap that is intended to be discarded upon arrival in the EU 12/10/2008 Page 16

17 Authorization Substances placed on the SVHC list will eventually be subject to authorization Authorization means a ban Substances that are subject to authorization will only be permitted to be used on an interim basis based upon an acceptable phase-out plan that includes a sunset date Sunset dates before 2011 are not anticipated Authorization does not apply to substances contained in imported articles Therefore as non-eu manufacturers authorization will not directly affect your products If you do manufacture in the EU this will affect you directly SVHCs contained in articles may be restricted from import or use in the future under Article 67 12/10/2008 Page 17

18 What will be the effects on the electronics industry? Initially the only effects will be an administrative burden to collect and aggregate data on SVHC content to support communications requirements Many of the standards organizations are creating or modifying existing materials declaration forms to streamline communication up and down the supply chain IPC, SAE, ANSI, etc. Many business software developers are marketing systems or modules designed to process substance data to verify compliance with REACH It is the stated intent that substances placed on the SVHC list will eventually be subject to authorization (banned) Which substances are placed on the SVHC list, and which of these become subject to authorization and when will be subject to internal EU politics Environmental groups have already pushed for a wider substitute it now or SIN list of 267 The political supporters of SIN really don t care about long-term reliability of electronics 12/10/2008 Page 18

19 Risks to the electronics industry Authorization or the risk of impending authorization may drive chemical suppliers worldwide to alter the composition of their formulations Flame retardants in plastic encapsulant material and in printed wiring board material Beryllia heat sink material Precursor materials for semiconductor manufacture Substances used during processing: cleaning, activating, masking, etc. Insecticides, fungicides, and preservatives in paper and cardboard packaging materials Any and all substances that environmental activists believe pose too great of a risk to consider using Material substitutions will occur deep in the supply chain, for reasons not associated with performance or cost Notifications of change may not always reach up as far as the level of an electronics integrator Assumptions and testing performed at the lowest level may or may not meet the ultimate OEM s needs 12/10/2008 Page 19

20 Cautionary tale from the recent past The red phosphorus debacle In 1996 Sumitomo replaced their brominated flame retardant with inorganic red phosphorus in three different molding compounds used to encapsulate microcircuits. The motivation for this change was environmental regulations. These compounds were used to encapsulate microcircuits by a number of major OCM s and contract packaging houses Significant long-term reliability issues ensued- followed by the inevitable multimillion dollar lawsuits Has the industry learned its lesson? Authorization will begin to come into effect a significant level after 2011, 15 years after the Sumitomo decision Do the key decision-makers in our industry have a sufficiently long memory to retain these lessons? I wouldn t count on it! 12/10/2008 Page 20

21 Detailed example of SVHC HBCDD is used as a flame retardant in polystyrene One of the listed applications is in electronic power supplies The dossier prepared by Sweden to support the listing as an SVHC includes information on alternatives Several of the listed alternative are on the SIN list The section on alternative approaches includes the following verbiage: Re-designing the products so that the voltage supply is separated from ignitable plastic will decrease the requirement for flame-retarding. The suggestion to reduce the need for flame retardants through good design practices may sound nice (shouldn t we already be doing this?), but it is in effect advocating eliminating one layer of safety 12/10/2008 Page 21

22 Recommendations If you purchase components and assemblies Ask your suppliers whether or not they are aware of and planning for the impacts of REACH If you receive unsatisfactory answers, immediately begin searching for alternative sources of supply Be alert for changes in flammability ratings, and qualification test results If you purchase processing chemicals Check your chemicals against the 15 published SVHCs and the SIN list If they are listed, immediately began assessing the potential impacts of unavailability If you export directly to the EU Be prepared to deliver SVHC communications If you sell to companies that export to the EU Be prepared to deliver materials declarations in standard format 12/10/2008 Page 22