|William F. Hoffman III is a principal staff engineer at Motorola Labs where he develops product information systems and decision tools, environmentally preferred material systems, and implements life cycle thinking in product design. Bill is also the technical activities vice chair of the Environmental Health and Safety Technical Committee of the Computer Society within the Institute of Electrical and Electronic Engineers and is chair of ASTM Subcommittee F40.02 on Declarable Substances in Materials.
Materials Reporting and Test Methods at Motorola Labs
Motorola Labs has explored the environmental aspects of product design for over 10 years. It became clear early in the effort that to improve the environmental performance of any product, the material content was an important point of consideration. It also became clear early in the effort that we had very little information on what materials were being used to build our products. Initially, knowing that we used polycarbonate, aluminum, steel, or a printed wiring board that contained copper, gold, silver and platinum was considered enough for a basic understanding of the environmental performance of a product.
Design direction, therefore, was initially set from this basic line of thinking. Lately, much greater detail has come to be required, since recent regulations are often based not on the existence of a material but on the substances that make up that material. More detailed understanding of a product’s component materials also aids in estimating the value of a product at end-of-life. The amount of gold, copper, silver and other metals often is the key source of value from a printed wiring board.
Engineers rarely think of a product design in terms of the substances composing those products. Substances such as gold, silver, aluminum, iron, poly(vinyl chloride), and bisphenol A polycarbonate are rarely useful alone. Substances are usually combined with other substances to make materials such as aluminum 308, Lexan®, or ASTM A 512 steel. The process of combining substances to make materials adds considerable value and tailors the properties to fit the application requirements. However, it also hides the substances that were used and many times a trade name will disguise even further the chemical composition of the material being used. Detailed information about the substances used within a product are required for even the most basic of environmental performance assessment.
How Products Are Assessed for Environmental Performance
The environmental performance of a product is a multi-variable issue that includes such factors as material hazard, amount of material used, recyclability, material availability, recycled content, material diversity, energy used, and the impact that those factors have on individuals and the environment. Each environmental factor has a unique relationship between the measured value and the actual impact. Some factors are more important than others. Because of these issues, systems must be developed to evaluate the relative performance of each material within a product.
One such method developed at Motorola uses multi-attribute value analysis. (1,2) Regardless of the stated arguments for or against a particular material or material system, value judgments are a part of the discussion. The perceived level of risk balanced against the value of that material within a product is often an unstated but important part of deciding whether or not to use a substance. Multi-attribute value analysis brings that discussion to the forefront by including both the impact of a single substance (or an aggregated product hazard score in the case of substance hazard) and the relative value of other measures of environmental performance to create a final product score.
The scope of an environmental assessment can also impact information requirements. One popular way of looking at environmental issues is life cycle assessment, or LCA. In this method, the environmental performance of a product is measured using an input-output analysis for each process in the supply chain, the handling of the product at the end of its life, recycling of materials and reuse of the components of the product.
Figure 1 is a good illustration of the general life stages examined in LCA. On close examination it becomes clear that LCA is really the measurement of the flow of materials through the supply chain. From raw material acquisition to end-of-life, the materials used and wasted are measured. A summary of the materials used is compiled and each material is evaluated using one of many potential assessment methods developed for LCA. Knowing the substances used in the manufacture and structure of a product is basic to assessing the environmental performance of that product.
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Today, there are several standards for the exchange of product substance information, each produced by an organization within a specific industry. With representation from a cross-section of industries, ASTM International’s new Committee F40 on Declarable Substances in Materials is well-positioned to produce an information exchange standard that would be acceptable to the whole supply chain from mining to final product.
Voluntary Reductions and Regulation of Substances
For many years the electronics industry has participated in voluntary efforts to reduce the use of certain substances. Programs from the U.S. Environmental Protection Agency, such as the 33/50 Program and others, have restricted the use of some materials. The 33/50 Program was considered very successful by the EPA. An EPA publication states, “The 33/50 Program met its ultimate goal a 50% reduction in releases and transfers of the 17 targeted chemicals in 1994, one year early. The most recent data show a 1988 baseline total for the 17 chemicals of 1.496 billion pounds of on-site releases and transfers off-site to treatment and disposal and a 1994 total of 748 million pounds. In 1995, releases and transfers of the 33/50 chemicals totaled 672 million pounds, and by 1996, releases and transfers had dropped nearly 60% from the 1988 baseline, to 601 million pounds.” (3) The focus of the 33/50 program was to reduce the movement of the target materials, not the use of these materials in products. To the extent that some companies were also voluntarily reducing the use of these substances in products, this EPA initiative also impacted product design and could effectively be a substance ban for certain companies.
Substance Bans Force Companies to Consider the Substances Used in Products
In Europe, the electronics industry has monitored the implementation of regulations that would ban the use of certain substances, including lead, mercury, cadmium, hexavalent chromium, polybrominated biphenyls and polybrominated diphenyl ethers. In anticipation of these regulations, some companies began to determine where these materials are used within electronics. Many applications were obvious, lead in solder for example, and planning was begun to eliminate these materials from products. In the United States there have been several proposals for material bans similar to those in Europe. Some existing regulations, California’s Proposition 65 for instance, were newly applied to electronics. To better illustrate the issues of regulation, the implications of one regulation in particular will be explored.
Of particular interest in the United States are regulations related to mercury. On June 8, 1998, the Conference of the New England Governors and Eastern Canadian Premiers adopted the Mercury Action Plan, which had as a goal “the virtual elimination of the discharge of anthropogenic mercury into the environment.” As the result of the establishment of this goal, a task force was created to develop the Mercury Action Plan. The intention was to reduce emissions from incinerators and industrial sources, and to encourage the safe waste management of mercury. (4) As a result, several states initiated regulation that controlled the amount of mercury in products. Figure 2 (below) shows an excerpt from the Rhode Island statute that implements the goals of the action plan by restricting the use of mercury in products. (See also the sidebar.)
|Figure 2 Excerpts from the Rhode Island Statutes focused on mercury restrictions
|§ 23-24.9-7 Phase-out and exemptions. (a) No mercury-added product shall be offered for final sale or use or distributed for promotional purposes in Rhode Island if the mercury content of the product exceeds: (1) One gram (1000 milligrams) for mercury-added fabricated products or two hundred fifty (250) parts per million (ppm) for mercury-added formulated products, effective July 1, 2005.
Why Testing Is Important
Mercury in polyurethane is just a single example of the sometimes obscure uses for substances of interest (or at least these uses are obscure from the perspective of the original equipment manufacturer). In some cases the substance may be there as a contaminant that is within the limits allowed. In other cases the substance of concern is added purposely, often in small quantities, to achieve a particular material property. Manufacturers are responsible for the substance content in the products they manufacture and sell. The primary method of data collection is through the supply chain, and OEMs have been working with suppliers for at least four years to determine the substance content of the parts they sell. That is not always enough, however, and an analytical test to determine the concentration of substances in a product provides manufacturers with a check and balance on the substance content in their products.
Motorola began methods development in 2000 so that the substance content of new products could be determined with some accuracy before entry into the market. Motorola understood that not all suppliers knew in detail what was being used in the components they manufactured and, as can be seen in the case of mercury, some of these banned substances could be found in unexpected places.
Motorola initiated a systematic testing program and decided to qualify several labs around the world. Samples were submitted to determine the labs’ capability of measuring individual elements, mixtures of elements, and mechanically homogenized electronics. As a preliminary test of laboratory-to-laboratory differences, samples from a homogenized phone were sent to two laboratories. Both labs used recognized standard methods for digestion and elemental analysis of the samples, although the methods used were not specified beforehand. Each lab received several samples including blind duplicates from a split sample derived from the homogenized phone. Neither lab should have been aware that these samples were the same before analysis. The two labs generally returned results that were comparable, but there were significant differences. In addition, the results from one of the labs were generally very precise while the other labs’ results were less so. They believed that the sample size used in the digestion was the culprit. At the same time the methods of digestion and analysis used in the material assay were significantly different at the two laboratories. Based on these results a new set of tests were performed using methods specified by Motorola.
The next set of samples returned results that were identical within analysis error. Clearly, standard methods for elemental assay will be needed in order to assure that all test labs report the same results for the same sample. Beyond elemental assay there are also several organic molecules that are of interest. One or more standard methods specific to those substances will also need to be developed.
The analysis of substances used in products is an important part of product environmental evaluation and assurance of compliance. Suppliers are the first and best source of information when they are aware of the substances used in their products. However, suppliers have not always known in sufficient detail the substances used in the products they sell. Today, a program of data-gathering by OEMs from their suppliers can supply enough substance information to assure compliance and help to perform an environmental analysis of products.
At the same time, OEMs are responsible for the substance content of the products that they put on the market and may feel a need to analyze the products for substances of concern before a product design is released for sale. The quality of both the data that suppliers provide to OEMs and the quality of the data that testing labs provide is crucial to understanding the complex uses for substances within products. Poor quality or incorrect information from either source can lead to substantial work for the supplier and OEM. If the substance of concern has a regulated limit for use in a product, incorrect testing could lead to considerable cost to manufacturers who must remove products from the market or, even worse, to prosecution. The first and primary method for the compilation of product substance information should be through the supply chain, beginning with raw material suppliers. Standards, both test methods and information exchange procedures, are an integral part of a system of checks and balances to assure both suppliers and OEMs that the product being sold complies with regulation and the environmental goals of the manufacturer.
I would like to acknowledge Steve Scheifers and Michael Riess for their contribution to the work on test methods and many useful discussions about this paper. //
(1) W.F. Hoffman III, “Recent Advances in Design for Environment at Motorola,” JIE, Vol. 1, Issue 1, 1997, pp. 131-140.
(2) Thurston, D.L. and W. Hoffman, “Integrating Customer Preferences into Green Design and Manufacturing,” Proc. 1999 IEEE International Symposium on Electronics and the Environment.
(3) “33/50 Program - The Final Record,” United States Environmental Protection Agency, Office of Pollution Prevention and Toxics, EPA-745-R-99-004, March 1999.
(4) “Draft PBT National Action Plan for Mercury,” The US EPA Persistent, Bioaccumulative, and Toxic Pollutants (PBT) Program, 1998, www. epa.gov/pbt/hgaction.htm.