Semi SMC 2010 - Botsford Presentation

Death, Taxes, and Eco‐Compliance:
things you can count on

Dates: 13‐15 January 2010
Location: SEMI 2010, Half Moon Bay, CA, USA
Presenter: Krista Botsford, Botsford EcoTech Partners

© Botsford EcoTech Partners LLC 2010

Agenda
• Eco‐Compliance Legislative updates impacting
Electronics Industry and its supply chain
• Goals and Responsibilities for Compliance
• Lessons Learned & Best practices from Industry


Eco‐Legislation impacting Electronics Industry

• Europe ‐ EU • USA Federal
– RoHS – 2003, ‘06 – Taking a back seat to health
– WEEE – 2003, ‘05 care legislation.
– REACH – 2007, ‘08, ‘09 – CA most likely to enact
– EuP – 2007 legislation ahead of federal
– RoHS/WEEE Recast 2008‐09
• Asia • South America
– China RoHS – 2006, ‘07, ’09 – Argentina, Brazil, Chile,
Columbia, Venezuela
– S. Korea RoHS/ELV/WEEE 2007
– Several regions and
– Japan JGPSSI countries with take‐back
– Japan – JAMP legislation
– Taiwan RoHS – 2006 • Using EU as guidance; but
not verbatim


REACH Update

• EU REACH
Registration, Evaluation, Authorization of Chemicals
– Impacts all products
• Mainly focused on chemicals, mixtures, articles
– Substances of Very High Concern (SVHCs)
– Handful of SVHCs used within electronics
– Additional substances to be added annually (~15)

Useful websites:
http://echa.europa.eu
http://www.hse.gov.uk/reach/index.htm


REACH SVHCs in Electronics Industry
Substance Name CAS number EC number Potential EMS Use?

Anthracene 120-12-7 204-371-1 no

4,4'- Diaminodiphenylmethane 101-77-9 202-974-4 Yes (Hardener for
Solder Mask)

Dibutyl phthalate 84-74-2 201-557-4 7 products – mostly
enamels

Cyclododecane 294-62-2 206-33-9 No

Cobalt dichloride 7546-79-9 231-589-4 Yes – Desiccant
Indicator

Diarsenic pentaoxide 1303-28-2 215-116-9 No

Diarsenic trioxide 1327-53-3 215-481-4 No

REACH SVHC’s in electronics – presented at IPC 2-18 committee meeting APEX 2009
by Kelly White, Jabil


REACH SVHCs in Electronics Industry
Substance Name CAS number EC number Potential EMS Use?

Sodium dichromate, dihydrate 7789-12-0 No

5-tert-butyl-2,4,6-trinitro-m- 81-15-2 201-329-4 No
xylene (musk xylene)
Bis (2-ethyl(hexyl)phthalate) 117-81-7 204-211-0 Yes (Lacquer
(DEHP) Thinner)
Hexabromocyclododecane 25637-99-4 247-148-4 No
(HBCDD)
Alkanes, C10-13, chloro (Short 85535-84-8 287-476-5 No
Chain Chlorinated Paraffins)
Bis(tributyltin)oxide 56-35-9 200-268-0 Yes (Cooling
Towers)
Lead hydrogen arsenate 7784-40-9 232-064-2 No

Triethyl arsenate 15606-95-8 427-700-2 No

Benzyl butyl phthalate 85-68-7 201-622-7 Yes (2 products
for rust
prevention)

REACH SVHC’s in electronics – presented at IPC 2-18 committee meeting APEX 2009
by Kelly White, Jabil

Trends in Product “Eco”‐Legislation
• Green Chemistry legislation
– REACH; CA Green Chemistry Initiative
– Latest “hot item” within Eco‐compliance legislation.
• Eco‐compliance legislation
– continues to expand and change
– continues to place demands on manufacturers and
suppliers.
– substance‐level legislation will streamline compliance
• E.g. supply chain complying with REACH requests


Eco‐Compliance Goals & Responsibilities
• What are your corporate product compliance goals?
– Corporate risk management and compliance
– Satisfying legislative demands
– Satisfying customer demands

• Understand your responsibilities
– Legal definition of compliance
– Restrictions and exemptions
– Waste management
– Packaging/Marking
– Required reporting
– Product defense


Sustaining Compliance


Total Compliance

•Regional •Part material breakdown
•National •Life cycle information
•International Data & •Testing results
Legislative Information
Changes

Policies
News &
and
Updates
Procedures •Data procedure
•Conferences •Educational
•Industry Events Modules
•Listservs/Blogs Roadmaps
•Group digests
•Product
•Company
•Legislative


Lessons Learned & Best Practices

• Lesson 1: Process approach
– With the constant possibility of changes to any product
eco-compliance legislation, a process needs to be
implemented; not simply a project for each type of
legislation.
• Best Practices:
– Ability to track products by compliance to multiple
requirements and legislative requirements
• EU vs China, RoHS vs. REACH, USA by state
– Implementation of the next three lessons learned and best
practices.



• Lesson 2: Be ready for an audit
– No longer just government audits
– more customers or suppliers are performing audits
• Best Practices:
– 24 hour turn around time to deliver information
– Remote access to data & information
• Technical compliance files should include: component data,
corporate policies and procedures, classification/justification
documents, roadmap(s) of activities
– Information by substance, component, product
• Information should be searchable by component, part number,
supplier status, substance, exemption/variation


Compliance Failures

• Almost 50% of companies audited fail
• 80% of audits are competitive in nature
• Were are the obstacles?
– Definition of Due‐Diligence
– Misuse of exemptions
– Program sustainability
– Responsiveness



• Lesson 3: Gather full materials declarations
– More and more countries are creating requirements for
materials reporting requirements or materials restrictions.
– Countries with existing requirements are look at adding
additional substances.
• Best Practices:
– Full materials declarations by weight
– Listed in database by CAS number
– Ability to search database for specific substance



• Lesson 4: Stay current
– With changes happening for existing legislation and new
legislation being created, one needs a good service for
keeping informed.
• Best Practices:
– Industry involvement
– Targeted reports – not general knowledge databases or
“tech rags”
• Several services provide news; few provide only the info you need
or assist with interpretation and action on changes
• Be wary of tech rags and make sure the information you’re using
comes from a reputable source.


It’s not easy going green…

• It’s a Conscious Corporate Decision
– Changing critical thinking
• Go beyond substance restrictions and waste management
– Compliance not chaos
• Risk elimination
• Business based solution
– Crisp presentation of corporate environmental
stewardship

… but the rewards are tremendous.


www.BotsfordEcoTech.com

Krista Botsford
President, Chief Compliance Officer
Mobile office: 781.552.9585
E-mail: kbots@BotsfordEco.com
Skype: kbotsford


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