This is the first of a series of articles intended to share with Quality Digest’s readers key aspects of the global movement toward hazardous substance–free (HSF) products and processes and how they affect organizations. SBGi helps producers of electronic and electrical products prepare for certification to international standards and specifications that demonstrate their ability to meet customer and regulatory requirements anywhere in the world. SBGi is an expert on IECQ HSPM QC 080000 for hazardous-substance process management, which was issued by the International Electrotechnical Commission Quality Assessment System of Electronic Components.
RoHS and WEEE elevate the HSF movement
The electronics and electrical industries have scrambled for the last few years in response to two European Union directives. The first concerns reduction of hazardous substances (RoHS), which restricts the allowable content of six substances—lead, mercury, cadmium, hexavalent chromium, poly-brominated biphenyls (PBB) and poly-brominated diphenyl ethers (PBDE)—in a wide range of products. The second directive deals with waste electrical and electronics equipment (WEEE), which addresses provisions for proper disposal of those hazardous substances. Those guilty of noncompliance risk losing access to the EU market, damage to their reputation, and the imposition of significant legal and financial consequences.
Billions of dollars have been spent around the globe on product testing, staff time dedicated to compliance-related activities, development and completion of supplier questionnaires, and legal advice to comply with these new requirements. With the first set of RoHS requirements having gone into effect on July 1, one might think that many companies are now over the hump on this issue, but in reality this far-reaching and costly disruption to the industry and commerce is just beginning.
All industries should be concerned now
The nascent movement to make products and production processes hazardous substance–free is arguably the most ambitious and important endeavor in human history and will affect generations to come. The HSF movement seems destined to affect nearly every product of every business in every industry in the global economy.
The proliferation of RoHS-like trade regulations should give every business cause for launching a serious HSF effort. While RoHS currently includes certain product exemptions, these should be thought of only as temporary delays. The reasoning behind many of those exemptions is being questioned and, at the end of the day, the public will not long tolerate exemptions that seemingly threaten their health and safety. Also, the EU RoHS directive currently addresses only six hazardous substances. The Montreal Protocol now identifies hundreds of substances that pose a threat to humans. How long should a company bet their livelihood on the list of regulated substances remaining at six?
Today, the notion is that the electronics industry, including companies that make computers, televisions, music players, flat screen displays, etc., is really the only one affected by the regulations. That notion is wrong and many businesses that should be working feverishly on RoHS compliance have yet to get started. Any product sold that has an electrical current running through it is subject to hazardous substance restrictions, unless specifically exempted. That teddy bear that talks to you when you squeeze it needs to be RoHS-compliant. Those running shoes with the blinking lights, too. So does that kitchen appliance. Electronic components have found their way into many products that aren’t considered electronics.
Humanity responds
The origins of the HSF movement are found in people’s increased understanding of the consequences we suffer as the result of our production habits. Improved science and technology have enabled us to see previously hidden consequences—such as child development—being irreversibly impaired by exposure to lead, and the carcinogenic effect on all of us from exposure to various toxic substances. There’s a growing and justifiable concern that products we use and consume every day and substances in our environment could be a danger to our health.
Similarly, public demand grows for action to stem the consequences of air and water pollution from industrial processes and casual disposal of products containing hazardous substances that then pollute water tables, leading to poisoning of our food and drink.
The bottom line is that men and women around the globe have awakened to the previously hidden consequences of our technologies and production processes, and recognize the need for change. Our collective instinct for survival is finding a voice. The HSF movement is gaining momentum and consumers are beginning to favor so-called “green” products and intolerance of the dangers inherent in products and production processes is quickly increasing. What once was labeled a concern of a wacky fringe element is emerging as a concern of the masses.
Industry is often adept at responding to changes in consumer preferences, certainly with time, but other forces for change are often more challenging.
Politicians and bureaucrats respond
For good reason, and in some cases pure self-interest, politicians, government agencies and special-interest groups are clamoring to address hazardous substance issues. Public fear is fertile ground for ambitious politicians and bureaucrats. These efforts have produced a complex, convoluted and chaotic patchwork of regulations that exceeds the electronics industry’s capacity to comprehend, much less respond to appropriately.
For example, there is the well-known RoHS of the EU, now followed by similar but different regulations commonly referred to as California RoHS or China RoHS. Every nation, or every state of the United States for that matter, has the capacity to set a different set of regulations, each with a distinctive twist. When these new laws and regulations emerge, there is often a regulatory agency that then begins the arduous process of documenting how compliance is to be determined. Added together, these varied and numerous regulations, coupled with the ever-evolving guidance for proving compliance, become an immense challenge for global businesses and a significant source of legal and financial liability and risk.
It has been a rough ride for the electronics industry over the last few years and it seems destined to get even more challenging. The HSF movement represents a challenge and an opportunity.
Coming “SBGi on HSF” columns
As quality professionals, many Quality Digest readers find themselves with added responsibility for regulatory compliance. Categorizing environmental regulations as just one more customer requirement is an important and logical step, but that approach alone has some shortcomings. Over the next few columns we hope to lead you to a new and better understanding of the global business situation, so that you have what’s needed to lead a more effective HSF effort in your company.
Future articles will address the chaos and shortcomings of current industry efforts to address RoHS and WEEE regulations. We’ll identify and explore emerging solutions to industry’s global challenges and how these are shaping business practices in various parts of the world today.
Let SBGi hear from you
Because “SBGi on HSF” is a continuing series of articles, we have the unique opportunity of gathering your feedback and interests to help shape future content. What is your response to this article? What aspects of HSF would you like us to address? What questions do you have?
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