|Tim McGrady is chairman and a founding member of ASTM International Committee F40 on Declarable Substances in Materials. He has recently formed a new company, Serious Science, a consulting and materials testing company, which focuses on helping companies comply with substance restriction regulations. He can be reached at 607/753-9075.
Committee F40 to Meet in Shanghai
The fall 2006 meeting of Committee F40 on Declarable Substances in Materials will occur Oct. 10-12 in Shanghai, China. The meeting will be hosted by the Thermo Electron Corporation. For more information, contact Brynn Iwanowski, ASTM International (phone: +1 610/832-9640).
An Update on ASTM International Committee F40 on Declarable Substances in Materials
ASTM International Committee F40 organized on Jan. 13, 2005, to assist global industry regarding the regulation of substances in materials. Committee meetings have since been held at ASTM International Headquarters in West Conshohocken, Pa., in Dallas, Texas, and in Toronto, Canada. Recognizing that regulation of substances in materials is an international issue affecting the entire global manufacturing and supply infrastructure, Committee F40 voted to hold, at a minimum, every fourth meeting outside North America. The fall 2006 meeting of Committee F40, to be hosted by the Thermo Electron Corporation is planned for Oct. 10-12 in Shanghai, China.
Regulations Impacting Product Composition
The impetus behind the formation of Committee F40 was the February 2003 introduction of European Union Directive 2002/ 95/EC on the Restriction of the Use of Certain Hazardous Substances in Electrical and Electronic Equipment, commonly referred to as “RoHS” (pronunciations vary, but the most common are “rose,” “rohoss” and “ross”). While the scope of RoHS is wide and its impact is imminent due to the July 1, 2006, effective date, many other regulations affect the composition of materials used in the manufacture of finished goods. Examples include EU Directives 2000/53/EC on End of Life Vehicles, 94/62/EC on Packaging and Packaging Waste, 76/768/EEC relating to cosmetic products, 91/157/ EC on batteries and accumulators, and 76/769/EEC on the marketing and use of certain dangerous substances and preparations.
There are many existing and proposed regulations pertaining to substances in materials outside the EU as well, including:
• California’s SB 20 and SB 50 establishing the Electronic Waste Recycling Act of 2003 and California’s Proposition 65, which requires reporting of California’s listed carcinogens and reproductive toxins used within products);
• China’s Management Methods for Controlling Pollution Caused by Electronic Information Products Regulation, commonly referred to as “China RoHS,” due to go into effect in March 2007;
• Japan’s amendment to its government and METI ordinance under the Law for Promotion of Effective Utilization of Resources, reporting of RoHS substance information; and
• Korea’s Act for Resource Recycling of Electrical/Electronic Products and Automobiles, which contains regulations similar to the EU RoHS, WEEE and ELV directives combined.
The list of regulations pertaining to declarable substances in materials continues to grow, with even more laws pending or enacted in Australia, Canada and the United States. Subcommittee F40.03 on Monitoring of Legislation and Regulation has developed a database to help industry keep track of the plethora of regulations (see David Edenburn’s article).
One common theme in all these regulations is restricting substances within the materials used to produce finished goods. Some of the regulations require reporting of certain substances contained within materials and/or products, and others require that the concentrations of certain substances be limited to specified maximums. Each regulation differs in some way from the others and as these laws continue to propagate it will become increasingly difficult for industry to meet all the requirements. This situation is often referred to as a “moving target”: companies work toward compliance with one regulation and then have to adjust their strategies to meet the next, and so on.
The impact of these regulations is felt to a greater degree by smaller companies that do not have the resources to keep up with an ever-changing regulatory environment. This is one area where the efforts of Committee F40 should soon bear fruit as standards and databases become available to help those in need of information. As mentioned above, the Subcommittee F40.03 database of regulations should soon be available on the ASTM International Web site, and Subcommittee F40.04 on Existing Document Research/Liaison should follow up soon with a similar database linking to pertinent standards.
Regulations can be difficult for industry to navigate because they often do not give direction on how to comply. Instead, regulations tend to focus on what industry must achieve, leaving how to comply with the regulations up to industry. Unfortunately, what always precedes how and there is most often a chaotic period for industry until how is sorted out. If regulations spell out what is demanded of industry, standards are one way to agree on how to comply. But good standards take time to develop, particularly when the regulations are as sweeping in scope as the current substance restrictions. In the meantime, companies who make up the supply chain are left to their own devices and often make their own interpretations of what is to be achieved and how to do it. This is the chaotic period a time when standards are not available to industry. This is the period in which industry now finds itself with regard to RoHS and similar regulations.
Standards in Industry
A general description of how industry uses standards is appropriate for those not familiar with the role standards play, and Figures 1 to 4 illustrate the process.
A simple contract between buyer and seller usually involves a purchase order (Figure 1). All the terms of the contract are spelled out in the purchase order. This type of contract works well as long as all aspects of the agreement are easily laid out in the document. More often than not, however, the contract involves a level of detail not easily reproduced on a purchase order, or it may be tedious to repeat such complex requirements on frequent orders. In such cases, other documents are commonly referenced by the purchase order. Those documents could be drawings and other specifications shared between buyer and seller. When a common material is involved, the other document referenced is often a standard material specification (Figure 2).
A standard material specification contains physical, chemical, structural and/or dimensional limits as well as other information necessary to characterize the specified material in detail. Such a document is of great value to both buyer and seller because both have access to the standard and all the requirements are given under a single designation. For example, an order for type 430 stainless steel sheet with a minimum tensile strength of 450 mega-pascals (MPa), minimum yield strength of 205 MPa, minimum 22 percent elongation, maximum Rockwell B hardness of 89, and a chemical composition of 0.12 percent maximum carbon, 1.00 percent maximum manganese, 0.75 percent maximum nickel, 0.040 percent maximum phosphorus, 0.030 percent maximum sulfur, 1.00 percent maximum silicon and 16.00 to 18.00 percent chromium is easier to order as type 430 stainless steel per ASTM A 240 than to lay out all the requirements in a purchase order.
Material specifications also reference test methods to measure specified properties. These are most often standard test methods (Figure 3). Standard test methods have been developed by experts and have been evaluated for precision and bias through interlaboratory studies. Such methods are available to both the buyer and seller and may be performed in house or at a third party independent laboratory. The availability and use of test methods serve as a check-and-balance system so that contracts may be evaluated before and even long after transfer of a material has taken place. For example, a buyer wants to purchase type 430 stainless steel sheet per ASTM A 240 from a scrap dealer. The scrap dealer might think they can fill the order, but to be sure the dealer sends a sample to an independent laboratory for testing according to the chemical and physical requirements of ASTM A 240 using standard test methods. If the lab report comes back stating that the material meets the requirements for a type 430 stainless steel per ASTM A 240, the seller can be sure he can properly satisfy the contract. If the buyer is not sure if the material is correct or if problems with it are encountered, he or she could also have the material tested at any point in the production process or even after the material has been incorporated into a product that later presents problems.
One further part of this system is the use of reference materials to ensure that test methods are producing or will produce accurate results (Figure 4). Reference materials can also provide traceability to the International System of Units (SI), often a requirement for standard test methods and accreditation of laboratories.
This infrastructure for buying and selling materials and parts is an integral part of doing business throughout supply chains. It allows both buyer and seller a means of communicating and verifying contractual requirements, aids in quality control, provides legal protection and serves as a mechanism for dispute settlement. This system is essential to manufacturing, particularly where many materials and parts are exchanged and supply chains are spread throughout the world. If this infrastructure breaks down or is not in place, there are bound to be problems throughout the supply chain. Because this infrastructure is almost nonexistent with regard to the recent regulation of substances in materials, it is no wonder that industry is struggling with regulatory compliance. This is another focus of Committee F40: to assist industry with the daunting task of developing new standards and modifying existing standards in order to create an infrastructure that will allow the buying and selling of compliant materials and parts.
The Regulations and Related Work of Committee F40
The number and type of standards required depend on the scope of the regulations. In the case of substance restriction regulations such as RoHS, the scope includes nearly every material and product imaginable. This is a counter-intuitive statement for those not familiar with the regulations because it would seem at first that RoHS concerns only electrical and electronic equipment to be put on the EU market. However, the EU Commission has made it clear that each “homogeneous material” within the covered products must comply with RoHS requirements. Per the commission’s frequently asked questions guidance document on the WEEE and RoHS directives, a homogeneous material is “a material that can not be mechanically disjointed into different materials.” Examples of homogeneous materials are “individual types of: plastics, ceramics, glass, metals, alloys, paper, board, resins, coatings.” The commission further states that the limit values of the directive apply to each homogeneous material within a covered product. Those limit values are 0.1 percent by weight maximum for the substances lead, mercury, hexavalent chromium, polybrominated biphenyls and polybrominated diphenyl ethers, and 0.01 percent by weight maximum for cadmium. Other restrictions such as those listed in 76/769/EEC on dangerous substances also apply to the materials used to construct products, and the list of restricted substances will continue to grow with time.
The implications of these regulations are far-reaching because materials used to construct electrical and electronic products are also used to construct other products not covered by the RoHS directive. Also important is that material producers cannot control where their products end up or into what product they are incorporated, so they tend to make wholesale changes to their products to meet the most restrictive requirements. Those implications have the effect of broadening the impact of the regulations to products outside their scope and market. The overall impact of substance restriction legislation is that hundreds of substances are restricted and thousands of materials must be compliant with myriad regulations. In other words, practically the entire global manufacturing infrastructure is affected in some way.
Compounding the difficulty for industry is that lists of declarable substances are compiled without regard to material type. Those lists are often found in the original manufacturer’s materials declarations and are passed through the supply chain. A problem inherent in this approach is that the substance restriction requirements are applied indiscriminately to every material even though it is not likely or not even possible for certain substances to be present in certain materials. A simple example of this issue is a machine screw made of wrought stainless steel. There is no reason to test the screw for organic substances such as polybrominated biphenyl (PBB) or polybrominated diphenyl ether (PBDE) or to test it for mercury or hexavalent chromium. Most material declarations are, however, indiscriminate with regard to which substances may be present in which materials, so buyers often ask for empirical data to prove that every material does not contain any of the listed declarable substances. This proposition is expensive and requires a vast amount of superfluous testing to be undertaken.
Subcommittee F40.02 on Management Practices and Guides has begun to address substance restriction and testing issues by introducing the work item WK9115, currently titled Guide for Risk Assessment when Assessing Conformance or Compliance with Requirements (this work item has been balloted and many changes will be made to the draft, including a change of title). WK9115 establishes guidelines to help the supply chain minimize the amount of empirical data required for materials declarations and to eliminate much of the perceived need for superfluous testing and information. One of the major contributions made by WK9115 is the introduction of the concepts of a priori and a posteriori knowledge as a means of assessing materials.
A priori knowledge is based upon logical deduction and scientific principles while a posteriori knowledge is based on empirical data obtained through observation or experiment. Getting back to the wrought stainless steel screw, a great deal of a priori knowledge may be applied when assessing the material for compliance to substance restriction requirements. A producer of stainless steel or a materials scientist knows the ingredients and process used to manufacture wrought stainless steel. First of all, the ingredients do not include organic substances, and second, any organic contaminant somehow making its way into the mix will be decomposed and evolved as gas at the high temperatures (greater than 1400ºC) used to manufacture stainless steel. Mercury is not added as an ingredient to stainless steel, and due to its volatility any mercury contaminating the stainless steel will be volatilized as mercury vapor and not remain in the finished material. The chromium within stainless steel is in the zero valence or ground state and as such is elemental chromium and not hexavalent chromium (note that there may be a concern that hexavalent chromium is formed while welding stainless steel). Thus, there is no need to test wrought stainless steel for any organic substances (including PBB and PBDE), mercury or hexavalent chromium. Indeed, even if someone wanted to test stainless steel for those substances it would not be possible to develop a standard test method because it would be impossible to manufacture reference materials for use in development of calibration curves or validation of results.
It is a tenet of Committee F40 that it will work with industry and other ASTM groups to develop the necessary infrastructure rather than attempt to prescribe standards. This approach is really born of common sense because it is best to go to the source with the most knowledge to create or modify standards concerning materials. Those committees must decide which elements to test (or not to test) in which materials because they have access to both a priori and a posteriori knowledge of their materials. To this end, Subcommittee F40.04 on Existing Document Research/Liaison is maintaining a list of liaisons with ASTM committees and other organizations outside ASTM International. Those liaisons give reports in every F40.04 subcommittee meeting and also in meetings of the committee having a liaison with F40.
Several test methods are currently under development by Subcommittee F40.01 on Test Methods, but it seems that modified material specifications are needed before many of the requisite test methods are developed. Those committees with jurisdiction over material types need to decide which, if any, substances need to be declared in order to comply with the various requirements. If a test method is not available for that substance in that material, F40 can aid in the development of a method. Test method modifications should be done by the committee with jurisdiction, but F40 stands ready to help in any way it can.
One last area of F40 activity concerns an issue surrounding the use of hexavalent chromium in chromate conversion coatings. Industry is currently split on whether they can continue to use hexavalent chromium or whether they must replace such coatings. The crux of the matter is the regulatory limit of 0.1 percent by weight maximum hexavalent chromium in chromate conversion coatings, with the coating considered by itself a “homogeneous material” as stated in EU Commission guidance. The fact is that industry has never measured hexavalent chromium in units of weight percent, preferring instead to measure hexavalent chromium in mass per area units (µg/cm2) as stipulated in ISO 3613, Chromate conversion coatings on zinc, cadmium, aluminium-zinc alloys and zinc-aluminium alloys test methods. The reason industry does not measure hexavalent chromium in relation to total mass of chromate conversion coating is that it cannot be done on real-world samples. Hexavalent chromium coatings are too thin to allow practical measurements of total coating mass (chromate coating thicknesses range from a few nanometers to a few hundred nanometers). Consider a zinc-plated set screw that has been coated with a hexavalent chromium coating. The chromate coating cannot be “mechanically disjointed” cleanly from the zinc layer, leaving chromate coating as a single homogeneous sample. The coating mass cannot be accurately measured by the common weigh-strip-weigh method because common analytical balances do not have the sensitivity required to measure such small mass differences. Essentially, no one knows how to measure hexavalent chromium in mass percent in relation to the total chromate coating mass. Committee F40 has drafted a white paper on this issue and will soon be sharing it with other ASTM committees for comment. Once the document is finalized, it will be submitted to as wide an audience as possible to try and help resolve the issue.
In conclusion, ASTM International Committee F40 has begun the long, hard process of helping industry with declarable substance regulations. The committee will provide up-to-date information in the form of databases; develop terminology and guides to help industry cope with confusing requirements; form liaisons to keep other committees informed; and assist in the development of material and test standards. There is a lot of work ahead and F40 hopes that industry will come to the conclusion that declarable substance regulations are best satisfied by cooperative standards development. In consensus standard development each company works in its own best interests but also in the best interests of all affected parties. This is the only way to address such sweeping regulation; otherwise, industry will continue to dole out billions of dollars in unnecessary compliance costs and these chaotic periods will continue to increase in number and duration. //