Make Sure Clean Means Green

The REACH and SED directives come into play this year, and companies as well as users must comply sooner rather than later.

Over the years, electronics designers become familiar with using the same types of cleaning products. So, not surprisingly, they tend to give this area little thought. Yet with legislative changes on the horizon, that's all set to change. Indeed, companies caught using banned substances could be leaving themselves wide open to legal action that could result in fines and prosecution.

Hot on the heels of Restriction of Hazardous Substances (RoHS) last year, this year sees the introduction of REACH and the European Solvents Emissions Directive. Suddenly, choosing the right cleaning products has become a critical decision, not least because users are concerned about having to trade cleaning performance and efficiency so that they comply with green legislation. So what do electronics designers need to know and what options are available to them?

READY FOR REACH?

Let take a look at REACH (Registration, Evaluation, Authorisation and Restriction of Chemicals), which became mandatory on 1 June 2007. REACH requires all companies manufacturing or importing substantial amounts of chemicals to register them on one central database. In essence, REACH gives the chemicals industry greater responsibility for managing the risk to humans and the environment, and to provide safety information across the supply chain. The regulation also calls for a switch from some of the most dangerous chemicals to safer alternatives where they exist.

As far as users are concerned, it makes sense to check the REACH status of their current suppliers. In my opinion, it could prove harder for smaller chemicals suppliers to achieve REACH than for larger organisations with more resources. It's important to ask any of your chemicals providers how sure they are of meeting REACH.

COMPANIES NOT READY FOR SED

The second landmark event for this year is the deadline to comply with the European Solvents Emission Directive (SED) on 31 October 2007. It has major implications for cleaning fluids, since many of these are solventbased. Furthermore, unlike REACH, where the pressure and responsibility falls on suppliers, the SED places the responsibility on users. What is worrisome is that many users have yet to put plans in place to comply with SED requirements.

What exactly does SED demand? The new directive places severe restrictions on the use of solvents that are classified as having "CMR" potential. CMR stands for "carcinogenic, mutagenic or toxic to reproduction." In practical terms, solvents affected include "Trike" (trichloroethylene) and nPB (n- Propyl Bromide), both of which are commonly used as cleaning products today. In fact, Trike has a long history as an industrial de-greasant. It was used extensively in Ford Motor Company plants in the U.K. during the 1960s. Therefore, any company using these products needs to review the impact of SED and, if necessary, may have to seek alternatives.

It is the word may that could cause confusion, because there's no outright ban on these substances. SED identifies what are known as "Risk Phrases," i.e., the degree of risk estimated to be involved when using certain substances. The Directive allows up to one tonne per year of CMR-classed solvents. While this may sound generous, for many users this will probably not be enough. Where a product has a Risk Phrase of R20 or less, two tonnes can be used.

Potentially, there's a lot of room for confusion, particularly because it may prove hard to predict exactly how much cleaning solvent will be needed over the coming year. Of course, another route to follow is to choose solvents that aren't classified as CMR at all and, therefore, are more readily able to comply with SED.

Apart from obvious solutions such as water, many companies are now looking at HFEs (hydrofluoro ethers) as alternatives to CMR-classified solvents. Available from a number of suppliers, HFEs are rated as being "non-ozone-depleting" and have comparatively low toxicity. Nor do alternatives such as HFEs necessarily have to be more expensive than traditional cleaning solvents, though it's important to ask manufacturers and suppliers to provide a clear business case and, where possible, examples of users reporting a return on investment.

NEXT STEPS

With so little time left, it's dangerous to leave the transition to alternatives until the autumn, or even later this summer. The reality is that while alternatives such as HFEs are being produced in large volumes, companies that wait until the last minute may find that demand has outstripped supply. Users also need to leave themselves enough time to look at the bigger picture of cost-of-ownership before making any changes.

Even using water has implications, due to the costs associated with disposal of contaminated water. At the other end of the scale, use of CMR solvents may require some kind of abatement system. Consequently, that may involve additional equipment.

If making the switch to HFEs, it's important to look at the benefits of buying new cleaning equipment at the same time. In addition, use of flammable liquids may have an impact on company insurance premiums. All of these factors need to be considered and could take months to organise. This holds particularly true since most purchasers would be advised to carry out a trial of new products before making a commitment.

This is where suppliers and manufacturers can play a role, providing advice to users. Certainly, reputable suppliers should be able to deliver business models based on a company's expected consumption, as well as offer solutions that match existing processes, without any compromise on cleaning performance.

LOOKING AHEAD

Another key consideration is ensuring that the chosen manufacturer of solvents is already looking ahead. In my view, SED is unlikely to be the last piece of legislation affecting cleaning solvents. For instance, in parts of Europe, authorities are already looking at the lifetime of a chemical in the atmosphere. If SED means investing in new cleaning equipment, then it makes sense to be confident that it will still be usable in a few years time. Ask manufacturers, or their suppliers, about their R&D plans for more environmentally friendly chemicals. Choose suppliers who are committed to the long term.

So, looking at the worst-case scenario, what if a company fails to meet the SED deadline? The exact nature of the penalties isn't yet clear, but the Health & Safety Executive will have the power to close down businesses that aren't SED-compliant after 31 October 2007. It's hard to predict whether the Executive will take that, but it's surely a risk that no company should take.

The SED is the prompt we all need. Cleaning products are an important part of the electronics industry, and it's in everyone's interests that we take a "cleaner and greener" approach to design and manufacture.

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