The 30-year US space shuttle program is drawing to a close. The final shuttle launch is scheduled for June 28, when Atlantis is slated to embark on its last voyage.  The last launch is likely to attract more people than this one, estimates run one million and up. 

This blogger intends to watch. Respect, Salute, Cheers. Perhaps every engineer in my age group owes part of their passion to the inspiring space program of the late 60s.

Programs focusing on humans in space now belong to other countries.  But the aerospace industry still booms at home.

Regs in aerospace. From a regulatory standpoint, the aerospace industry is a unique beast.  In 2005, the FAA published “Aviation and Emissions, a primer,” which was largely about the flight and emissions.  More a logistics concern at the time, it’s worth reminding ourselves that this modern era of manufacturing considers waste and downstream emissions reporting in design, supply and build phases.

On February 3, the Office of Management and Budget approved the Section 114 Information Collection Request (ICR) for the aerospace manufacturing and rework industry.

For more on managing compliance with emissions standards, Actio technology can help, or try reviewing EPA documents such as Risk & Technology Review.  Hazardous Air Pollutants or HAPs are a key component of related emissions reports.

In term of pending deadlines, it’s worth noting that by May 4, Major and Synthetic Minor sources must supply all remaining data on the ICR (see Allowable Forms).

Electronic components as exemption. So what is the definition of electronic components for the purposes of completing the information collection request (ICR) for the aerospace source category?  The aerospace rule provided an exemption for electronic components but it did not provide a definition or guidance for “electronic component”.

EPA suggests using common sense on what constitutes an electronic component.  (We’d all like to believe this will work!)

“If you have a solid justification, that any reasonable person would accept, for the part or component being an electronic component then please do not report the activities associated with that part or component on the ICR,” says EPA.  “However, if you question whether or not it would be considered an electronic component then you should report the activities associated with that part or component.”

Docket, Federal Register and National Emissions Standards. There are three key rivers that merge in a delta to form a gulf of aersospace emissions standards.

The Docket: Air and Radiation Docket The Air and Radiation Docket and Information Center (The Docket) contains information on Air and Radiation rules and proposed rules. The Docket is composed of Federal Register Notices, the rules, and supporting documentation, and public comments.

The federal register states that the National Emission Standards for Hazardous Air Pollutants (NESHAP) for Aerospace Manufacturing and Rework Facilities were proposed on June 6, 1994, and promulgated on September 1, 1995.

National Emission Standards applies to owners and operators of new, reconstructed, and existing aerospace manufacturing and rework facilities where the total hazardous air pollutants (HAP) emitted are greater than or equal to 10 tons per year of any one HAP; or where the total HAP emitted are greater than or equal to 25 tons per year of any combination of HAP.

Operations covered include such activities as:

1. cleaning
2. primer and top coat application
3. depainting
4. chemical milling maskant application
5. handling and storage of waste.

The information is to be used by enforcement agencies to verify that sources subject to the standard are meeting the emission reductions mandated by the Clean Air Act.  Owners and operators of aerospace manufacturing and rework facilities are required to submit initial notification, performance tests, and periodic reports.

Aersopace manufacturing, being largely for military purposes, is often exempt from industry standards and regulations.  However, often companies have their own lists, because tracking chemicals is critical even if there really were “No Rules.”  Thus, many custom lists of chemicals apply in aerospace manufacturing and supplier compliance.  Boeing and Lockheed attend their own hazardous substance lists, for instance.  Then of course Canada, China and Europe have their own as well.  This litany of unique sets of parameters makes communications and disclosure practices for suppliers more complicated.

But that’s another subject for another day.  To find out more about streamlining supplier disclosure practices, examine the information at Material Disclosure.com.

Aerospace standards. Key standards organizations are SAE, RTCA, and EUROCAE.  Specifically, these originating organizations and ISO-recognized international aerospace standards include:

1. SAE
www.sae.org/SAE AS 755 C
Aircraft Propulsion System Performance Station Designation and Nomenclature

/SAE AS 4893
Generic Open Architecture (GOA) Framework

/SAE MA 4872
Paint tripping of Commercial Aircraft – Evaluation of Materials and Process

/SAE ARP 4150
Procedure for Inspection of Inservice Airborne Accumulators for Corrosion and Damage

2. RTCA
www.rtca.org/RTCA/DO-178B
Software Consideration in Airborne Systems and Equipment Certification

3. EUROCAE
www.eurocae.net/EUROCAE/ED-12B
Software Consideration in Airborne Systems and Equipment Certification (published in December 1992)

For more, see ISO.

Sacramento Protocol. The Sacramento Protocol is worth mentioning.  “Sacramento Protocol” Final Report of November 24, 1997 provides results of an effort by the California Air Resources Board (CARB or State), the EPA, and the South Coast Air Quality Management District (SCAQMD or District).  The joint effort sought to determine whether identified State and District air pollution control requirements in California are technically equivalent to the requirements found in five MACT standards, including the Aerospace NESHAP, and has bearing on emissions standards.  To download a copy, see EPA link here: http://www.epa.gov/ttn/atw/sacrorpt.html

On March 11, IPC responded to a US Environmental Protection Agency (EPA) request for public comment. EPA’s request for comment was regarding its embryonic National Framework for Electronics Stewardship.

IPC responded by first saying that it appreciated the opportunity to comment on EPA’s Solicitation of Input from Stakeholders to Inform the National Framework for Electronics Stewardship (Docket ID # EPA-HQ-RCRA-2011-0185).  Then:

IPC believes that EPA’s goal of encouraging the design, manufacture, procurement, and use of greener electronics should begin with a definition of a green electronic product.

This is in fact an excellent point.  At a recent high-level symposium for “Green Chemistry,” roughly 500 managers and executives gathered to share ideas on the subject of green chemistry.  In my working group, 250 well-educated individuals sat in a large conference room to discuss the business implications of Green Chemistry.  Very quickly it came to light that almost no one present agreed on what Green Chemistry meant.

Definition of green in manufacturing. Some, myself included, thought “green chemistry” would be a topic as defined by Paul Anastas and J.C. Warner, and a discussion of green product manufacture would be about materials and finished goods screened against the original 12 principles of Green Chemistry.  A few folks thought we would discuss law in terms of state-level green chemistry legislation, risk and litigation.

The slight majority in the room had never heard of the 12 principles of Green Chemistry; these folks thought Green Chemistry was synonymous with Sustainability, itself an undefined term.

Truly:  no definition is correct until we define these terms once and for all, and then continue to define our terms consistently as we go along.  Upshot:  the conference collateral and agenda should have defined Green Chemistry on every page.  In fact, every Sustainability conference or paper ought to do the same until we all know the definitions without thinking.

With that said, we can only applaud IPC for its sensible call for definitions of “green electronic product,” as the term will be used in the new national framework for electronics stewardship.

IPC’s letter to EPA on electronics stewardship. The IPC letter articulated that before developing a framework for electronics stewardship, the EPA ought to establish a definition for a green electronic product. Defining a green electronic product, it said, ensures that all impacted stakeholders will be working from a common starting point. Yes!

There is no need to recreate the entire document here, but there is a second particularly relevant point:  the need to consider the fact that some attributes may be less damaging to the environment in one way, say sourcing or end of life, but be more damaging in another way such as in processing emissions and waste. In IPC’s words:

For example, as shown in EPA’s lead-free solder study, the substitution of tin-lead solder for lead-free solder resulted in increased energy use associated with the higher operating temperatures required for manufacturing electronics with lead-free solder.  This increase in energy use was projected to cause higher air pollution, acid rain, stream eutrophication and global warming impacts.

That study serves as an important reminder that there are environmental trade-offs when substituting one substance for another. The EPA must lead the way in determining what attributes are of most importance in defining a “green electronic product.”

IPCs letter is signed by Stephanie Castorina, manager, Environmental Programs for IPC.  The entire document may be viewed here.

Green manufacturing index. Perhaps a hierarchal, ranked, feature set matrix would be a good start.  If the major electronics associations, industry consortia, EPA, and the new Task Force for Electronic Stewardship could agree on a ranking system to establish a green index in manufacturing, that index could be used to determine and define “green electronic products,” also to ensure that one evil wasn’t swapped for another.

With a Green Manufacturing Index we could move forward with a unified theory of electronics recycling, which would simplify a lot of things. Stay tuned.