Overview of Environmental Trends
and IBM Requirements
Focus On
Printed Circuit Boards and Assembly
World Wide Environmental Compliance
John H. Quick – Sr. Engineer
IBM Poughkeepsie, NY
November 19, 2009
—2—
IBM Product Stewardship Program
IBM's Product Stewardship program was established in 1991 to bring additional focus to
the corporate environmental affairs policy objectives on product environmental design
and performance.
The Product Stewardship program within IBM's worldwide EMS provides development
organizations with direction and goals, infrastructure, tools and expertise to apply
environmental life cycle considerations from product concept through product end-of-life
management.
The objectives of IBM's Product Stewardship program include:
• Develop products with consideration for their upgradeability to extend product life.
• Develop products with consideration for their reuse and recyclables at the end of
product life.
• Develop products that can safely be disposed of at the end of product life.
• Develop and manufacture products that use recycled materials where they are
technically and economically justifiable.
• Develop products that will provide improvements in energy efficiency and/or reduced
consumption of energy.
• Develop products that minimize resource use and environmental impacts through
selection of environmentally preferred materials and finishes.
• Environmental design requirements are communicated and verified with suppliers.
Let’s Build A Smarter Planet – Finding the Value In “Green”
System z: z10 BC
—3—
Power System w/ xSeries servers in a rack
System z: z10 EC
Various Power Systems
Storage: DS8000
System i: 570 stack
System x: 3455
Blade: BladeCenter H
System x: 3655
IBM Customers want value added “Greener” products
—4—
Environmental leadership
ƒ 1990-2007 Early Results
– IBM reduced or avoided CO2 emissions by an
amount equivalent to 45% of its 1990
emissions through the company's global energy
conservation program.
–
ƒ Earned Leadership Status
– 2009 #1 Green IT Vendor, Computerworld
– 2007 #1 Vendor “Green 500” Supercomputing
– 2008 CNET UK Business Technology “Green IT
Initiative of the Year”
– 2008 One of top 15 Green IT companies,
InfoWorld
– 2008, CERES ranked IBM #1 among 63
different companies across 11 different industry
sectors for corporate climate change
governance practices.
– 2008, Gartner and WWF-UK ranked IBM #1
among fourteen I/T companies for Basic
Environmental Management of Climate Change.
– 2008, Climate Counts ranked IBM #1 among
electronics companies for Climate Friendliness.
http://www.ibm.com/ibm/responsibility/
—5—
Environmentally Responsible disposal
ƒ About 1 billion computers will become potential
scrap between now and 2010
(IDC, Gartner and the National Safety Council)
ƒ 55% of US-based companies do not have an IT
disposal strategy (IDC)
“To optimize TCO benefits,
companies require a
corporate standard
disposition strategy”
Gartner Group
ƒ In 2006 IBM processed over 100 million pounds of
used equipment and sent less than 1% to the
landfill
—6—
Road to World Wide Environmental Compliance Is Wide
IBM systems are designed and specified to be compliant with
all countries' regulations
no matter where we ship them
—7—
World Wide Environmental Regulations
Examples
Europe
•
•
•
•
•
•
North America
• California Waste Electronics Recycling Act
- SB 20/50 (CA version of RoHS / WEEE)
• Product take-back regs in several states
• Individual State RoHS like legislation
adopted or proposed.
• USA-Environmental Design of Electrical
Equipment Act (H.R. 2420) introduced
• Canada Provincial legislation gaining focus
RoHs Directives 2002-95-EC
WEEE Directive 2002-96-EC
EuP Directive 2005-32-EC
REACH Regulation (EC) 1907/2006
Packaging Directive 2004-241-EC
Phthalates /PVC / Halogen free (future)
China
• RoHS / WEEE Regulation for administrative
Measure on the Control of Pollution Caused
by Electronic Information Products
• Catalog published
Brazil
• CONAMA Resolution 257/99)
• Solid waste Policy PL 203/91 (Draft)
South Korea
• South Korea: Basic Environmental Policy Act
• Industry agreements to limit certain
materials and for products to be recyclable
Japan
Other Drivers
• Non-Government Organizations (NGO’s)
- GreenPeace,
• J-MOSS / Basic The Law for the Promotion
of Effective Utilization of Resources
-3Rs - reduce, reuse, and recycling
… and Continually Growing
No harmonized WW Standard
Australia RoHS
—8—
Federal RoHS Bill Introduced in U.S. House of Representatives
On May 14, 2009, Rep. Michael Burgess (RTX) introduced H.R. 2420, which proposes to
amend the Toxic Substances Control Act
(“TSCA”) to prohibit the manufacture after
July 1, 2010 of “electroindustry products” that
contain lead, mercury, cadmium, hexavalent
chromium, polybrominated biphenyls
(“PBBs”), and polybrominated diphenyl ethers
(“PBDEs”) above the maximum concentration
levels specified in the European Union’s
Directive on the Restriction of the Use of
Certain Hazardous Substances in Electrical
and Electronic Equipment 2002/95/EC (“RoHS
Directive”). See H.R. 2420, § 4(a).
Bill really focused on electronic waste (e-waste)
What about a federal
take back bill ?
—9—
State Legislation and World Wide WEEE Regulations
Generally, the scope of products covered is getting broader
Source: Electronics TakeBack Coalition (June, 2009)
— 10 —
Environmental Compliance Process & Challenges
DfE
Design for
Environment
Manufacture
Compliant
Processes
Supply Chain
Identify
Categorize
Take-Back, Disposal,
& compliance
Treatment
Reporting/
Analysis
Site
Inspection
Material
Compliance
for RoHS
Lead Free
Compliant
Identify Parts
& Assemblies
Substance
data
Waste
Stream
Disposal
Confirmation
Audit
Design
For RoHS
RoHS
Compliant
Substance
management
Material
Declaration
(PCD)
WEEE
ELV
(Vehicles)
NonConformance
Design
For EuP
REACH
Compliant
Birth
Certificate
(DoM)
Ship to
Restrictions
Recovery
Material
Manifest
Design
For IPP
Proof Of
Compliance
Country
Specific
Legislation
Treatment
Destruction
Certificate
Disposal
Operations
Corrective
Action
Process
— 11 —
DfE
Design for Environment
Think about material types:
• Use
• Use
• Use
• Use
less harmful materials
materials from sustainable sources
materials from recycled sources
materials which can be recycled
— 12 —
Who Is Responsible for Regulation Compliance ?
Everybody
Amended RoHS Directive removes the term
‘producer’ and replaces ‘manufacturer’,
‘distributor’, ‘importer’ or ‘authorised
representative’ – to be collectively known as
‘economic operators’. Unlike ‘old’ RoHS, where
generally only one of these operators would be
defined as the ‘producer’, under the change,
each of these operators will have obligations
under the Directive. Just because IBM doesn’t
physically make equipment (OEM, ODM, black
box) doesn’t remove IBM’s obligations to ensure
whatever we import or distribute complies fully
with the requirements of the legislation and is
suitably documented and labeled.
IBMs Environmental “Due Diligence” approach
Focus on Records
“Product Content Declaration (PCD) Document
Manufacture
— 13 —
New use for “CE” Conformity Mark
Member states shall presume electrical and electronic equipment
bearing the CE marking as conforming to this (RoHS ) Directive”
The CE Mark is a mandatory conformity symbol required for products sold in the European
Economic Area. The CE mark indicates conformity to the legal requirements of the European
Union (EU) Directive with respect to safety, health, environment, and consumer protection.
By affixing the CE marking, the manufacturer, its authorized representatives, or any entity
placing the product on the market asserts that the item meets all of the essential
requirements of all the applicable EU Directives and that the applicable conformity assessment
procedures have been applied correctly. All products offered for sale anywhere within
the EU must have the mark or they cannot be sold. Each EU country inspects equipment
and documentation to make sure that products conform as required. Any deviations from
complete conformity will lead to sanctions such as warnings, sales bans, fines or even
imprisonment.
Source: Present EU recast draft - this recast is simply a proposal and is not yet in force.
it is highly likely that the “CE” mark for RoHS compliance will be adopted early 2010
— 14 —
IBM Environmental Requirements
• IBM Engineering Specification (ES 46G3772) establishes baseline
environmental requirements for all Deliverables where this
specification is referenced in a Statement of Work, print, contract or
other procurement document's.
• ES 46G3772 implements IBM's environmental policy objectives and
contains some, but not all, environmental legal requirements for
deliverables.
• Supplier shall ensure the Deliverables comply with all
“Environmental Laws” and are ready for import, export, sale or
other distribution of the Deliverable in all jurisdictions worldwide,
regardless of where they are sold to IBM.
• IBM Global Procurement: Information for suppliers
http://www03.ibm.com/procurement/proweb.nsf/contentdocsbytitle/united+sta
tes~information+for+suppliers
Baseline Environmental Requirements for Supplier Deliverables to IBM
— 15 —
IBM Environmental Requirements
• “Environmental Laws” include laws, rules and regulations at local,
state, provincial, national or international level that relate to
environmental matters, including without limitation material
restrictions, material bans, labeling, availability of product
environmental information, energy efficiency, end-of-life take back,
battery requirements and other similar requirements.
• Full compliance requirements with the European Union (EU)
Directive 2002/95/EC on the Restriction on the use of Certain
Hazardous Substances in Electrical and Electronic Equipment
(RoHS) are not part of ES 46G3772, but are rather applied through
the combination of ES 46G3772, other applicable contract
provisions and IBM engineering specifications, such as 53P6233 or
97P3864. In circumstances where multiple documents contain
restrictions on the same chemical or substance in the same
application, the most restrictive requirements apply.
Baseline Environmental Requirements for Supplier Deliverables to IBM
— 16 —
REACH
• The overriding aim is to ensure that the most dangerous substances are
replaced with safer alternatives. In effect, businesses must prove that
substances that they produce or use are safe – a change from the
previous way chemicals were regulated which put the burden of proof on
the authorities.
• All companies that produce or use chemicals are being given obligations
under REACH. Manufacturers and importers must gather information on
the properties of all substances that they produce or import in quantities
greater than one tonne and register them in a central database. Users of
chemicals must apply risk management measures for certain substances
and provide information on how they use substances to their suppliers.
• Registration is to be staggered so chemicals are phased into the REACH
system by 2018. The European Chemicals Agency, based in Helsinki, is the
central authority dealing with the REACH system.
• Provisions are made for companies that produce or use the same
chemicals to work together in consortium at national and EU levels, in
order to reduce to the minimum the administrative and financial burdens
on companies, particularly for SMEs.
Source: EU’s regulation on the Registration, Evaluation, Authorisation and Restriction of chemicals (REACH) website
— 17 —
Design for Environment (DfE) requirements & NGO’s
Toxic material restrictions
also driven by NGO’s
Electronics manufacturers, standards bodies, and
legislators have begun to take notice of the human
health and environmental concerns associated with
the use of brominated and chlorinated compounds in
electronic products. An array of conflicting definitions
and policies have emerged to address these
concerns at various levels
Environmental Working Group
Published: September 2009
NGO's asking for clear timelines when industry will have halogen free equipment
Source: NGO - Clean Production Action, an ETBC partner organization
— 18 —
Human health and Environmental Concerns
Forms Dioxins When Incinerated (most potent cancer causing agents)
PBB
REACH
Switzerland
Norway
Canada
PBDEs
PVC & DEHP/
BPP / DBP
SCCP / MCCP
Washington
State
Introduction
Of
Restrictions
Annex 1V
Ban + limits
Prohibited
above 0.1 %
by weight
Previously Used - Banned
Prohibited in IBM Deliverables
*TBBPA
EU Approved
For Use In
PCB’s
In use Today
Restricted Limits in IBM Deliverables
IBM – Voluntarily prohibited PBBs and PBDEs
from use in products in 1993
HBCDD
New Halogenated
Substances
Introduction
Of
Restrictions
Annex 1V
Ban + limits
?
Potential
New Material
Currently Regulatory Practice
Every organo-halogen compound used in electronics can produce dioxins and furans, particularly during the end-of-life treatment of obsolete
equipment. This chart shows just a few of the bromine- and chlorine-containing compounds used in electronics products manufactured over the past
few decades. In addition to well-known BFRs (HBCDD, PBB, PBDEs, and TBBPA), the chart mentions some phthalates used with PVC plastic (BBP and
DBP), as well as other persistent and bioaccumulative substances used in electronics production, such as chlorinated paraffins (SCCP and MCCP).
PBT is the acronym for persistent bioaccumulative and toxic substances.
•The European Union has approved without restriction its use in circuit boards and plastics with no significant health concerns.
*Largest BFR in terms of production. 70% used as a reacted flame retardant in electrical and electronic equipment and 20% used as an additive to plastics
Based on ref. source: Clean Production Action, an ETBC partner organization
— 19 —
EU Recast Draft
• (3d) Regulation (EC) No 850/2004 of the European Parliament and
of the Council of 29 April 2004 on persistent organic pollutants1
recalls that the objective of protecting the environment and human
health from persistent organic pollutants cannot be sufficiently
achieved by the Member States, owing to the transboundary
effects of those pollutants, and can therefore be better achieved at
Community level. Pursuant to that Regulation, releases of
persistent organic pollutants, such as dioxins and furans, which
are unintentional by-products of industrial processes, should be
identified and reduced as soon as possible with the ultimate aim of
elimination, where feasible. Thermal treatment or uncontrolled
disposal of waste electrical and electronic equipment containing
halogenated flame retardants or PVC can contribute significantly
to the formation of dioxins and furans.
• The RoHS recast needs to be put into the context of the EU’s international
obligations to reduce total releases of dioxins and furans, with the goal of
their continuing minimization and, where feasible, ultimate elimination.
Emissions of dioxins and furans can only be addressed via
material choices at design stage.
Phasing out brominated and chlorinated flame retardants
as well as PVC and its hazardous additives.
— 20 —
Status of IEC 62321 Test Standards: RoHS Testing
• New standard structure has been approved. The next version of IEC 62321 will
split into separate horizontal standards by Substances for ease of standard
development, maintenance, and adding new substances. Draw back: need to buy
separate standards
• New name of standard: Determination of Certain Substances in
Electrontechnical Products
• Goals are to turn PBBs/PBDEs and Cr(VI) (surface coating & polymer) from
informative methods to a full test standard by 2012
• New Work Item Proposals had been finalized and will be submitted for voting in Nov.
International Round Robin Study 2H2010
• Cr(VI) testing of surface coating:
– Harmonize the detection limit of Cr(VI) with EN15205, at 0.1 mg/cm^2 – no
objections thus far
– Pressure to provide guidance/risk assessment due to the uncertainty of
coating weight determination – proceeding with caution due to the potential
implication
• Cr(VI) testing in Polymer:
– Progress on Extraction Efficiency by China and Korea
– Still working to understand how to overcome Matrix Interference issues
Source: IEC TC111 WG3 - IEC 62321 Standard Meeting Report
— 21 —
News headlines
Mac Pros accused of emitting toxic gas,
placing blame on someone else
Greenpeace slams HP, Lenovo,
and Dell in latest report
California Proposition 65
Greenpeace takes a break from issuing
Reports to vandalize HP corporate HQ
— 22 —
IBM Volatile Organic Compound (VOC) Testing
California Proposition 65,
OSHA, ACGIH
IPC Standard IPC-6012B –
Qualification and Performance Specification for Rigid Printed Boards
Section 3.10.1
Outgassing: The degree of outgassing shall have a Total Mass Loss (TML) of less
than one percent (1%) and Collectible Volatile Condensable Material (CVCM) of
less than one tenth of one percent (0.1%). Mass loss shall be determined on test
coupons or production boards of representative substrates when tested in accordance
with IPCTM-650, Method 2.6.4.
Example: Found in recent testing – Epichlorohydrin
Used in epoxy resins – to offer corrosion resistance, solvent and
chemical resistance, hardness and adhesion
Recognized CA Prop 65 Carcinogen and Reproductive Toxicant
— 23 —
Source: iNemi 2009 Technology Plan Board Assembly TIG – April 03, 2009
— 24 —
— 25 —
New “Green” PCB Materials ?
• Elimination of Halogenated Flame Retardants
– Flame Retardants in PCB Material (are required)
– Characteristics of Halogen-Free Laminates
– Processing Challenges of Halogen-Free Laminates
– Activities to develop Halogen-Free Laminate
• Reduction of Toxic Solvents
• Renewable Resin for PCBs
— 26 —
Renewable resins for PCBs
• Use of biopolymers to replace the oil-based epoxy resins – Lignin.
• What is Lignin?
– The glue like substance found that ties the cellulose together
in plants and trees
– Produced in large volume as a by-product of paper
manufacturing
– Its molecular structure provides the thermal stability and
chemical resistance necessary for PCBs.
• Experiments with epoxy resins with 50-percent lignin are proving
to provide a PCB with equivalent or better thermal and electrical
performance than current high-volume PCB's
— 27 —
Expect expanded and new legislative requirements
The Nanotechnology Discussion
“Risk management”
“Because nanotechnology would have such wide
applications and so little was known about its
potential effects, its risks could fall under a wide
variety of existing lines, including environmental,
product and professional liability, as well as
workers' compensation, medical malpractice and
directors' and officers' insurance, Dr. Blaunstein
said.”
Source: The Royal Gazette on-line edition May 21, 2008
— 28 —
Summary
• It is inevitable that the transition to environmental
compliance will have a significant impact on IBM
“Mission Critical” Information Technology product
Printed Circuit Boards and assembly as more BFR’s
and other SVHC materials are restricted.
• Capability & timeliness to comply with RoHS,
WEEE, REACH and China and other worldwide
environmental regulations now become key
competitive differentiators in the industry.
— 29 —
Questions ?
Thank You