Directive Decoder

The first national seminar on hazardous materials management was held at the Bangalore Institute of Technology on February 4th and 5th.

The seminar was organised by the Academy of Certified Hazardous Materials Managers (ACHMM) – India Chapter and the Karnataka State Pollution Control Board.

The ACHMM is a professional organisation of hazardous material managers in the US, and the ACHMM-India Chapter was initiated in 2006.

The objective of ACHMM is to bring together the regulatory agencies, academia and industry to discuss problems related to hazardous materials management, foster fellowship, offer networking opportunities as well as training and educational programmes.

New information from the Ministry of Environment of Korea (so called Korean RoHS).

Amended clauses in an additional rule of enforcement include:

1.Revised date of enforcement is now 1/7/08 for new products manufactured after 1/7/08

2.Products manufactured prior to 1/7/08 will be subject to a duty from 1/1/11

Directive Decoder

The dismantling time for products can vary enormously depending on whether or not they are designed for easy recycling. The overall cost of recycling will depend on many factors including dismantling time and therefore designers should consider what happens to their products at end-of-life.

For example:

• Design components / assemblies that can be easily dismantled into their equipment (PCBs, enclosures, etc.) and those that can be recycled separately and economically

• Removing screws is time consuming whereas plastic clips can be undone more quickly. Use as few screws as possible.

REACH regulations cover some 849 pages of legislation with 2000 pages of guidance notes.
Farnell has produced a five page Step-by-Step Guide to the regulations, providing a high level overview.
The Guide looks at the background to the regulations and adopts a question and answer theme to address the key points.
This free, best-in-class guide has been adopted by the major trade organisations. AFDEC in the UK, FBDi in Germany and NEDA in North America are all putting the document to good use.
For your copy:
http://uk.farnell.com/images/en_UK/rohs/pdf/reach_step_by_step_pdf_v3.pdf

Directive Decoder

REACH regulations continue to pose questions. Here I look at substances of very high concern (SVHCs).

Notification of SVHC when present in articles:

Article 7 of REACH details the criteria under which an SVHC would need to be notified to the European Chemicals Agency (ECHA) if it is present in an article. Notification would be required if:

(a) The substance is present in those articles in quantities totalling over 1 tonne per producer or importer per year, and;

(b) The substance is present in those articles above a concentration of 0.1 % weight by weight of the article (not homogeneous material as with RoHS).

Notification is not required, however, if the producer or importer can exclude exposure to humans or the environment during normal or reasonably foreseeable conditions of use including disposal. (In such cases, the producer or importer shall supply appropriate instructions to the recipient of the article.) or, if the substance has already been registered for that use.

So finally the German courts decided that a high-tech sports shoe does not fall within scope of the WEEE (Waste Electrical and Electronic Equipment) Directive.

Last year the German National Register (Elektro-Altgerate Register – EAR) was challenged by a Producer on the sports shoe, and the matter subsequently went before the courts.

The case in question was whether or not a high-tech sports shoe with an implanted chip was considered to be electronic equipment under WEEE legislation. The chip measures weight distribution when running and makes adjustments in the shoe that, according to the manufacturer, can improve running performance.

A revised Battery Directive was adopted by the European Union (EU), and came into effect, on 6/9/2006.

Member States have two years to implement the new Battery Directive and, on the same date of 26/9/2008, the former Battery Directive will be repealed.

The former directive only applied to certain batteries containing mercury, cadmium and lead over certain permitted values. However, the new legislation applies to all batteries regardless of their weight, shape, composition or use, although limited exemptions will apply.

I have received one or two queries regarding PFOS recently.

Most Perfluorooctane Sulfonate (PFOS) was originally produced in the USA by 3M. It was a key ingredient in Scotchgard, a fabric protector made by 3M, and numerous stain repellents. When 3M discovered how toxic it was they stopped making it with the result that it is now only used, via other sources, in applications where it is difficult to replace.