Category Archives: Green Thoughts

Environmental compliance expert Kal Kawar’s blog

Reducing the Environmental Impact of Electronics Manufacturing

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Manufacturers are increasingly evaluating the environmental effects of their practices as eco-consumerism becomes more widespread. Companies can increase their profits by making their product development more sustainable and supporting energy-efficient infrastructure development.

President Biden allocated trillions of dollars to the sustainability sector, promoting low emission production. Reaching carbon neutrality requires a restructuring of the electronic manufacturing sector. Before evaluating the impact of reduction methods, we must examine the degradation associated with commonly used devices.

Life Cycle Assessment

A significant portion of electronic development derives from material mining. Many devices contain lithium-ion batteries, linking manufacturing processes to ecological degradation. Inadequately maintained mining sites pollute local water supplies, like the Liqi River in Tibet. Here, a lithium mine generated a chemical leak, killing a significant quantity of marine life.

Mining also depletes local water sources in drought-ridden regions. Lithium derives from a saltwater brine, which workers extract. Over time, local farming operations suffer from low groundwater levels. The extraction process also pollutes the air, causing adverse health effects.

Inefficient manufacturing processes can also generate pollution by developing electronic waste. The U.S. produces the most e-waste in the world. Chemicals leach into the soil from electronic landfills, which degrades the environment and human health. These dumps contain lead, mercury, cadmium and more, polluting food sources and drinking water. They also contain persistent organic compounds from fire retardants. When consumed, the substances cause cognitive defects in children and behavior or motor skill challenges.

Another environmentally degrading factor of production derives from energy use. China manufactures the highest portion of electronics globally. Coal is China’s largest energy source, fueling many production facilities.

When products leave the center, they absorb a portion of the emissions generated. Fortunately, manufacturing facilities can increase the sustainability of their products by using renewable energy sources. Over time, their environmental impact will decrease.

Renewable Energy Sources

Large corporations recently adopted renewable energy systems in production, meeting eco-consumerism demands. Over the past year and a half, BMW used solar and wind power to decrease the emissions generated by its manufacturing facilities. It also increased the energy efficiency of their products, shrinking their carbon footprint throughout their life cycle.

If China’s electronic manufacturing facilities converted from coal-powered electricity toward renewable energy, they could significantly increase their practices’ sustainability. Reducing greenhouse gas emissions and adding energy-efficient appliances can decrease a company’s carbon footprint.

Some companies decrease their production facilities’ ecological impacts by swapping conventional lights with light-emitting diode (LED) bulbs. The bulbs absorb 75% less energy than incandescent lights and last 25 times longer.

Improve Product Longevity

The best way to target e-waste is through improving products’ longevity. Some companies utilize planned obsolescence to maintain a consistent revenue stream. The expiration date on electronics increases e-waste production and decreases their sustainability.

Some electronics companies source ceramic and glass for product development. The materials have a limited defense against electronic stressors and generate pollution over time. Replacing the materials with liquid silicone rubber can make a product last longer and eliminate the normalization of planned obsolescence.

Manufacturers can also sustain economic gains by increasing the price of long-lasting products. Customers are more likely to purchase sustainable goods over their less expensive counterparts. If we build products to last, it increases profitability while decreasing environmental impact.

Recycled Materials

Rather than mining lithium-ion battery elements each time we produce new electronics, we can utilize recycled materials. Environmental engineers and scientists are generating efficient lithium-ion recycling technology, extracting functional features from the devices. The Department of Energy (DOE) developed the first recycling center, increasing the industry’s profitability.

The DOE also developed a program influencing professionals to develop advanced lithium-ion recycling technology. It offered the winner a $5.5 million reward to expand the system’s efficiency. When using recycled materials, manufacturers can reduce their reliance on ecologically degrading mining practices.

Where to Start

Manufacturers can begin decreasing the environmental impact of their practices by leaving fossil fuel-derived electricity sources behind. Renewable energy is abundant and currently cost-effective, improving sustainability rates while reducing utility costs. It also helps companies immediately reduce greenhouse gas emissions, shrinking their carbon footprint and making them more appealing to a new generation of consumers.

Jane Marsh is the founder and editor-in-chief of Environment.co where she covers topics in green technology, energy and environmental sustainability.

What a Waste

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I like articles like this one from Forbes — even if they are out of date, because they cast attention on the intrinsic complexities of manufacturing.

But, while Forbes may think manufacturing inefficiencies cost the industry $8 trillion a year (no idea where that figure comes from, by the way), it points to the need for tools like the digital twin.

New ‘Extended’ Safety Data Sheet in REACH

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Many companies use safety data sheet software for updating, searching and viewing SDSs. What surprises people is that under the REACH regulation in Europe, companies must produce something called an extended-Safety-Data-Sheet, or e-SDS.

REACH regulation is the Registration, Evaluation, Authorization of Chemicals — Europe’s famous regulatory behemoth for managing hazardous substances in the marketplace. If you use hazardous substances registered under REACH, your suppliers now have to provide you with a new, extended safety data sheet that includes exposure scenarios.

What’s an exposure scenario?

Exposure scenarios are the new, key element in safety documentation. They include safe use conditions, the operational conditions and necessary risk management measures.

In other words, exposure scenarios say, “We tested this spray paint for spraying paint, and we assume your use will be similar.” But if you want to use the spray can to blow up a balloon, that’s a different story, and for that you will need to get a new exposure scenario from the supplier. Get more detail about exposure scenarios.

What’s in the extended-SDS?

Ideally, the extended safety data sheet should cover all uses in the life cycle of the substance, from manufacture through to waste, including:

  1. Uses within your own company
  2. Uses by your customers in their processes or products, i.e. mixtures or articles
  3. Uses by companies supplied with chemicals by your customers
  4. Thus, the extended safety data sheet provided by your supplier should include:
  5. The main technical function of the substance (e.g. flame retardant, pigment, stabilizer) and the uses covered in the exposure scenarios
  6. Threshold values of the exposure levels for human health and the environment that should not be exceeded, according to the assessment made by your supplier
  7. Physicochemical data needed to carry out exposure assessments (e.g. water solubility, vapor pressure, biodegradability)
  8. One or more exposure scenarios containing practical advice on the conditions of safe use, including risk management measures and waste management measures

Conflict Minerals, Meet US Sanctions

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Here comes another layer of “conflict minerals” restrictions.

President Obama last week set the stage for expanded sanctions against the Democratic Republic of the Congo and vicinity’s militia-ravaged region. A new Executive Order specifies that sanctions are called for against “individuals and groups tied to militias involved in the illicit trade of natural resources from the region” of the Democratic Republic of the Congo or DRC. If that criteria doesn’t include conflict minerals, what does?

Penalties to companies and individuals that fail to adhere to the expanding sanctions can include:

  1. Fines of at least $250,000
  2. Fines twice the amount of the underlying transaction
  3. Criminal penalties of up to $1,000,000
  4. Imprisonment for up to 20 years

Other conduct that will trigger future US sanctions:

  1. Actions or policies that threaten the peace, security, or stability of the DRC
  2. Actions or policies that undermine democratic processes or institutions in the region (DRC)
  3. The targeting of women and children with acts of violence (including killing, maiming, torture, and rape or other sexual violence), abduction, forced displacement, or attacks on schools, hospitals, religious sites, or locations where civilians are seeking refuge, or through conduct that would constitute a serious abuse or violation of human rights or a violation of international humanitarian law
  4. The use or recruitment of children by armed groups or armed forces
  5. Obstructing the distribution of, or access to, humanitarian assistance
  6. Attacks against United Nations missions, international security presences, or other peacekeeping operations.

Earlier this month, ahead of the Executive Order, US and United Nations Security Council added a Ugandan rebel group, the Allied Democratic Forces, to the sanction lists for “targeting children in situations of armed conflict through rape, killing, abduction and forced displacement.”

As far as conflict minerals go, this is yet another reason to know thy product ingredients and to continue tracking conflict minerals for compliance.

Thanks to many sources for these updates, for this one in particular thanks to Christopher T. McClure, Crowe Horwath LLP.

How Far Should Sustainability ‘Standardization’ Go?

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My longtime friend and industry colleague Pam Gordon blogged today about the role trade associations should play in driving the industry toward sustainability practices. In it, she writes

Associations will not necessarily push members to the next level of sustainability practices. But members can raise the baseline through their involvement and commitment — emphasizing that the industry’s continued profitability and continuity rests in good part on meeting customers’ increasing efficiency requirements, avoiding dependence on dwindling materials, and reducing costs through design-for-environment principles.

I agree with all that. But Gordon also mentions a colleague’s discussion of the possibility of trade groups offering certification in supply-chain sustainability, suggesting that those that do not are behind the curve. There, I’m very reluctant to concur.

I am a huge fan of standards, but I also recognize their limits. I view sustainability as an extension of innovation. And innovation is not something that can be standardized. Those companies that consistently adapt fastest to market demands are always the winners in the long run. I think the same will be true with design for recycling and reuse and other such initiatives. Companies will either pursue that course or not, but to add a layer of bureaucracy in the form of yet another pursuit of paper isn’t the way to go.

Pam writes that some associations help members raise their own sustainability goals above the level of current regulations by giving them workable frameworks, such as the codes of conduct from the Electronics Industry Citizenship Coalition. I have long felt the EICC’s code of conduct is a sham. Under Labor, for instance, the first rule is, “Participants are committed to uphold the human rights of workers, and to treat them with dignity and respect as understood by the international community.” Yet EICC members include Foxconn and Pegatron, which are routinely cited by watchdog groups for worker abuse. It may be a code, but its toothless.

Pam is tuned in to the industry and always makes her readers think. Her note that the industry lacks roadmaps for best practices in sustainability is dead on. A roadmap isn’t a certification, however, and that’s where I call on trade associations to draw the line.

SEC Upholds Conflict Minerals Reporting Deadline

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US Securities and Exchange (SEC) Commission Chair Mary Jo White on April 29 said that the agency will continue to implement the conflict minerals rule upheld by the US Court of Appeals.

The SEC has also issued guidance on meeting the May 31 reporting deadline. The gist is that companies must meet the deadline as expected, but may omit aspectsstruck down recently by the US Court of Appeals.

SEC Division of Corporation Finance Director Keith Higgins said companies should comply with parts of the rule that the court upheld and file initial reports by June 2 (reports will be due on June 2, 2014 as the May 31 deadline falls on a Saturday). Thing is, most parts of the rule were upheld, so there is very little change to requirements on the whole.

Higgins said no company will be required to describe products as “not been found to be ‘DRC conflict free'” but companies will still have to disclose the origins of the products.

Legal outlook.Insiders at IPC say that yesterday the industry petitioners, led by the National Association of Manufacturers, filed a Motion for a Stay with the SEC in the conflict minerals case. If the SEC denies the stay, the petitioners will consider filing a stay request with the DC Circuit.

On April 14, U.S. Court of Appeals for the District of Columbia Circuit ruled that the requirement that firms report whether their products have “not been found to be ‘DRC conflict free,’ included in the SEC conflict minerals regulation, violates the First Amendment.

If there is no stay requested or granted, and the case is remanded to the district court, that court may simply remand to the SEC to implement the DC Circuit’s decision in the first instance.

Do I have to file? So it’s business as usual for conflict mineral compliance. And the deadline at the end of May approacheth.

There are two categories of companies who must report.

  1. The first is standard: a company that uses minerals including tantalum, tin, gold or tungsten if that company a)files reports with the SEC under the Exchange Act, b) the minerals are “necessary to the functionality or production” of a product manufactured or contracted to be manufactured by the company. For more on this, visit this helpful FAQ.
  2. The second category of company that must report is a softer definition, for these are companies whose downstream customers demand information on raw materials so that the downstream company can then file with the SEC. So, even though your company may not have to file with the SEC, if you’re a supplier to a company that does, then you’ll have to report to them on your conflict mineral uses. Yes, it will be challenging. But it’s not impossible.

RoHS July 2014 Deadline: Medical Devices and Control Instruments

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In 2011, the European Union issued a new directive that updates and supersedes RoHS; it has come to be known as the RoHS Recast or RoHS 2. Under the updated directive, as of July 22, 2014, RoHS restrictions will apply to Category 8, medical devices, and Category 9, monitoring and control instruments. Before we look at what those categories include specifically, here’s an overview of deadlines yet to come under the RoHS Directive.

So, what’s in Category 9, Monitoring and Control Instruments? The types of equipment that are in category 9 of the RoHS directive have a main function of monitoring or control, says Dr. Paul Goodman in Electronics Weekly, quoted here because it stands out as one of the better summaries of what to expect from Category 9. Monitoring, Goodman says, would include measurement – ergo thermometers, analytical spectrometers and digital voltmeters are all in category 9 because they monitor temperature, concentration, voltage, etc.

Monitoring and control functions are features of thermostats that monitor and control temperature and industrial process controllers that monitor and control a variety of process parameters. Other category 9 products include smoke detectors, fire alarms, traffic signals (control of traffic), X-ray imaging of luggage or electrical equipment (but not medical X-ray which is category 8), spectrum analyzers, etc. It is incorrect however, to assume that all laboratory equipment is in category 9 as these products must monitor or control as their main function. – Dr. Paul Goodman, EW

So, what’s in Category 8, Medical Devices? Medical devices were exempt in the original directive, which meant they could contain unlimited amounts of toxic metals and plastics and still be marketed as RoHS compliant. Not anymore. Medical devices are still a broad category, and note that RoHS is not targeting “in vitro diagnostic medical devices” yet in 2014.

So what is targeted? For example:  radiotherapy equipment, cardiology, dialysis, pulmonary ventilators, nuclear medicine, laboratory equipment; other appliances for detecting, preventing, monitoring, treating or alleviating illness, injury or disability; but specifically excludes all implanted and infected products.

How are companies handling RoHS compliance? Industry’s leading companies are managing their compliance at various stages. There are challenges.

Certainly one challenge with RoHS is the many different formats suppliers use to submit their information. We asked a group of manufacturing risk assessment professionals on LinkedIn, “What form of documentation do you typically get from suppliers?” Here are the myriad answers.

Note: a good software should eliminate that challenge, for instance, by loading all information into a uniform data repository, so the resulting standardized data parameters are searchable, rational and reportable.

 

BPA – The Data Game

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Over in Europe, the Member State Committee (MSC) has agreed that the European Chemicals Agency (ECHA) should request further information on six substances. This is the first batch of substance evaluations agreed on by the MSC.

Of particular note is the now infamous BPA. BPA is a carbon-based synthetic compound. It belongs to the group of diphenylmethane derivatives and bisphenols. BPA is used to make certain plastics and epoxy resins. The MSC has determined that more information is needed in order to properly assess the world’s most notorious plastic ingredient. In the US, the FDA has reached similar conclusions.

So why did the MSC agree that ECHA should request more information on six substances? This is essentially because the currently available information is insufficient to enable adequate health and environmental risk assessments. These particular six substances listed in the Community Rolling Action Plan (CoRAP) were evaluated by Germany, France, Denmark, the United Kingdom, Belgium and Spain.

Further information on Bisphenol-A (BPA) will be requested to clarify a number of concerns. First, the MSC agreed to request a new in vitro skin absorption study to assess the risk to consumers from, for example, toys and PVC articles. Second, information on the emissions and environmental exposure of BPA will be requested in order to assess the impact on the environment. The information will help to finalize the risk assessment. It will also help to determine whether further risk management measures are needed. There are on-going studies on BPA in the US which the German authority will also take into account in the next step of the assessment on endocrine disrupting properties for humans. See also BPA and California thresholds.

Other chemicals on the list

The MSC also agreed to request further information on the reproductive toxicity of carbon tetrachloride in an extended one generation reproductive toxicity study (EOGRTS, OECD 443). (More information on worker exposure to carbon tetrachloride will also be necessary).

The MSC agreed to request further information on oligomerisation and alkylation reaction products of 2-phenylpropane and phenol (previously registered as Phenol, methylstyrenated). The information requested is a bioaccumulation study in fish to clarify the concern for potential persistent, bioaccumulative and toxic properties. A combined repeated dose toxicity (90 day) and reproductive toxicity study is also requested (EOGRTS, OECD 443) to investigate endocrine disrupting effects.

The MSC agreed to ask for further information on worker exposure to imidazole and on its reproductive toxicity effects. Information will also be requested on short-term toxicity in the environment and on mutagenicity through an in vitro study.

The MSC agreed to request further information on N,N’-bis(1,4-dimethylpentyl)-p-phenylenediamine to clarify the concerns relating to persistent, bioaccumulative and toxic properties of the substance. A soil simulation test will be requested to look at aerobic and anaerobic transformation in soil.

Finally, information will be requested on a mixture of cis- and trans- tetrahydro-2-isobutyl-4-methylpyran-4-ol to clarify concerns relating to the environment. The requested study will be a short-term growth inhibition study, followed if necessary, by a long-term toxicity study in the aquatic environment.

Mineral Uses

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If a mine is controlled by armed groups who use mineral profits to purchase weapons — or other supplies or luxuries — the minerals from the mine are sometimes called conflict minerals. Tantalum, tin, tungsten and gold are useful minerals mined in many parts of the world. But sometimes those minerals come from a very conflicted area in Africa, most notably but not exclusively from the Democratic Republic of Congo (DRC).

Four so-called conflict minerals and their uses are highlighted below.

Tantalum / coltan

  1. Tantalum capacitors enable energy storage in electronic products
  2. Tantalum capacitors are used in every laptop, smartphone, camera and video game console you’ve heard of – as well as in aircraft engines and military equipment
  3. Highly conductive and corrosive-resistant, tantalum is considered virtually “irreplaceable”
  4. Some alternatives include aluminum, ceramic and passivated nichrome – but none have the industry devotion of tantalum
  5. Armed groups in regions of the DRC who control mines earn an estimated $8 million per year from sales of coltan (the raw ore where tantalum comes from)
  6. 12% of all tantalum was mined in the DRC in 2011 (USGS data)
  7. Tantalum is predominantly mined in areas such as Australia, Brazil, and Canada but the amount mined in the DRC is not insignificant. A spike in tantalum export from the DRC since the tech boom of 2000 is apparent in the chart at bottom of page

The so-called “Africa’s World War” has been ravaging the eastern parts of the DRC for over a decade (map below).

Tin / casserite / coltan

  1. Tin is found in food packaging, in steel coatings on automobile parts, and in some plastics. Many industries use tin in the form of tin solder, for example, as solder on circuit boards
  2. Tin is predominantly mined in China, Indonesia, Peru, and Bolivia, as well as in the DRC
  3. About 3% of the global tin supply of the global gold supply, was mined in the DRC in 2010
  4. Tin earns armed groups in the DRC an estimated $85 million per year

By conservative estimates, the war and its effects has killed over 5 million people, making it the deadliest conflict since World War II.

Tungsten

  1. Tungsten is used in automobile manufacturing, drill bits and cutting tools, and other industrial manufacturing tools. It is also the primary component of filaments in light bulbs
  2. From 2006 through 2011, 77% to 87% of tungsten was mined in China
  3. Less than 1% of all tungsten was mined in the DRC in 2011 (USGS data)
  4. Yet, tungsten brings armed groups in the DRC about $2 million a year

The idea behind conflict mineral restrictions is no funds = no weapons = less violence and less war.

Gold

  1. Gold is used as currency, by the automotive industry in catalytic convertors, in electronics, medicine, coatings, nanotech, high tech; used in jewelry, fashion, fuel cells, jet engines, space exploration, and almost anywhere you can think of
  2. Gold is mined in many different countries, including the DRC
  3. Industry uses about 440 tons of gold per year globally
  4. Less than 1% of the global gold supply was mined in the DRC in 2010
  5. Only 23 kilograms of gold were “officially” exported from eastern Congo in the first half of 2012
  6. It’s estimated that 2 tons to 4 tons of gold was exported through illegal routes in the first half of 2012
  7. Roughly $30,000 worth of gold can fit in a pocket, and around $700,000 in a briefcase (source: The Enough Project)
Resources:

Chart: How much tantalum is mined each year?

Useful reference:

Download a complimentary white paper here.

Information on software for minerals management – and SEC compliance – click here.

Map of Conflict Mineral region (note how green it is, with ample fresh water lakes):

Afterword: Some say it’s not the international community’s place to monitor human rights issues in a distant country. Yet — such a huge event as this WWII-scale reality demands international attention. And don’t be duped into thinking conflict mineral legislation is strictly a humanitarian gesture.

Economic interests are involved. Consider: many say Africa is the new Asia in terms of potential for production, industry and an economic boom. But regional warring drains resources and restrains the region’s growth. This in turn badly affects western nations and corporations who would prefer to invest there rather than Asia – if the political landscape is stable enough to do so.

If the regional warring could simmer down, look out world. In ten years we’ll be talking about Africa before India, Brazil and possibly China.

EU Conflict Mineral Rule — Requires Attention

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Reminder: time is slimming for public feedback on an EU conflict minerals initiative.

Here’s the European Commission info page. Insider comments and notes follow below.

Insider comments and notes. The Commission says it will use results to help decide whether – and how in a reasonable and effective manner – to complement and/or continue on-going due diligence initiatives and support for good governance in mineral mining, especially in developing countries affected by conflict.

The consultation is open until June 26, 2013.

The contributions received, together with the identity of the contributor, will be published on the Internet, unless the contributor objects to publication of the personal data by checking the appropriate box in the questionnaire (see question 1.1. in the EC’s questionnaire, scroll down).

IPC’s PoV. The North American electronics association IPC believes that it may be impractical to encourage the EU to take no action and that “the best strategy is to encourage a voluntary regimen based on the OECD process,” according to a recent comment from IPC’s frontperson, Fern Abrams.

OECD process. The OECD process was developed by a multi-national group with NGO and industry participation. Although the OECD process is far from perfect, IPC and others believe it’s more flexible than Dodd-Frank and other regulatory schemes. Therefore the OECD process may be the best option in terms of not having a new/competing regulatory regimen. If interested, IPC has drafted suggestions for industry in responding to the EU’s questioning.

In the US. The US conflict mineral rule was put into place in summer of 2012. Companies are required to collect data in 2013. The first deadline for reporting is in spring of 2014.

Companies who do not yet have a compliance initiative are encouraged to contact Actio or preferred vendor. Quickly. And weigh in on the EU’s possible initiative — especially if you agree that the OECD process is preferable to the Dodd-Frank compliance requirements. Take action tout de suite. Schnell. Vlug. Rapidamente.

Cheers.