by Mary F. McDonald
Your organization is planning to achieve environmental compliance and improve its “green” profile by demonstrating its environmental corporate citizenship. You’re also wondering if you should comply with the European Union directive on the restriction on hazardous substances (RoHS). What are your options?
A few years ago, your choice was easy. You could register to ISO 14001, the environmental management system ( EMS) standard, and self-declare compliance with RoHS. Now that there are multiple standards, an organization must look in at least two directions to decide where its needs and goals are best met: with ISO 14001, originally released in 1996 and updated in 2004; or a newer option, QC 080000, a technical specification released in 2005 related to EU Directive 2002/95/EC on RoHS, and Directive 2002/96/EC on waste electrical and electronic equipment (WEEE). After examining the similarities and differences, your organization must determine which certification system make sense for your industry and client base.
What industry segments does the EU RoHS directive affect? RoHS limits the use of six hazardous substances in electrical and electronic equipment. This covers many industries and, according to the EU directive, products affected by this ruling encompass semiconductor chips; large and small appliances; industrial equipment; lighting fixtures including luminaires; toys, leisure, and sports equipment; and automatic drink dispensers.
The QC 080000 specification provides a more specific alternative to demonstrating compliance with the RoHS directive than the broader ISO 14001 standard. So which one should you choose to meet market requirements?
In making your decision, it’s helpful to understand where they intersect and diverge. To the uninitiated, they appear to very similar, as seen in figure 1 below.
Can your organization pick either ISO 14001 or QC 080000, because they appear to have parallel requirements? Or are the differences more pronounced than the similarities? See figure 2 below for a closer look at these differences.
QC 080000 is promulgated by the International Electrotechnical Commission to govern RoHS by building on the ISO 9001 quality management system (QMS) standard. QC 080000 is essentially a “bolt-on” supplement to ISO 9001; the former’s scope statement even declares, “The requirements of this specification are in addition to those contained within ISO 9001.”
Why was ISO 9001 chosen rather than ISO 14001 as the management system for QC 080000? I spoke to Stanley Salot, coauthor of QC 080000, to learn the reason for this.
“ISO 9001 was a better fit from a supply-chain management standpoint,” Salot says. “It’s much more thorough and robust than ISO 14001 for managing the contents of a product, which is what RoHS requires. ISO 14001 doesn’t specifically address product materials but rather looks at aspects and impacts from a broader environmental management standpoint; since we were building a standard that would address the use of hazardous-
substance-free [HSF] products, we chose ISO 9001, which we felt was a much better foundation to build upon.
The rationale for building around the ISO 9001 standard may be better understood by reading QC 080000’s forward:
“This IECQ specification and its requirements are based on the belief that the achievement of HSF products and production processes cannot be realized without an effective integration of management disciplines. This specification is a supplement to and exists in concert with the ISO 9001 quality management system framework for the comprehensive, systematic, and transparent management and control of processes pursuant to HSF goals.”
This position was echoed by Chris
Morrell of the National Standards Authority of Ireland, one of the registrars that is a supervisory inspectorate and the sole issuer of QC 080000 certificates in North America to date. “ISO 9001 is a quality management system standard, and ISO 14001 is a technical management system standard, specific and exclusive to environmental requirements,” he says. “ISO 14001 includes a subset of the requirements of ISO 9001 but not all of the elements of a management system. This is why QC 080000 is based off of the family of quality management system standards that include ISO 9001, AS9100, and TL 9000 to ensure that a comprehensive management system is in place.”
QC 080000 was developed to address the perceived need for a standard that formalizes the use of hazardous substances. That sounds good so far, but QC 080000 isn’t meant to address U.S. government concerns (CAL/OSHA and the EPA do this already); it was written to address EU RoHS concerns. This becomes apparent when reviewing the QC 080000 definitions section:
“‘Hazardous substance’ refers to any material as listed in the WEEE or RoHS and any additional customer requirements as prohibited from usage, and is interchangeable with ‘restricted substances.’”
Curiously, although it states, “… as listed in the WEEE or RoHS...,” QC 080000 doesn’t address waste streams at all. Why, then, is there a reference to WEEE? Also, it’s unclear what “RoHS” refers to, because the EU directives aren’t specifically referenced in the standard. So does “ROHS” also pertain to the Chinese version of RoHS? The Korean version? When QC 080000 was issued, neither of these directives existed, so although it seems likely that it refers to the EU version of RoHS, it isn’t made entirely clear.
Can QC 080000 be used to demonstrate conformance in China or Korea? Each of these countrywide directives has different requirements. For example, many of the product types included in the Chinese RoHS aren’t included in the EU RoHS. Knowing which RoHS you’re requested to comply with, and which you’re registering to, is important.
The EU directive for RoHS requires an organization to limit its hazardous-substance use. According to the directive, RoHS was promulgated because the waste stream from these hazardous substances was so great that implementing WEEE alone wouldn’t address the volume of the waste stream --only its segregation.
A company may declare that it’s HSF and then demonstrate this through testing and analysis. Several laboratories specialize in determining the levels of the hazardous substances, and can provide reports detailing detectable limits of any substances requested, including those listed in RoHS.
ISO 14001 is an international standard promulgated by the International Organization for Standardization. It’s part of the ISO 14000 family of standards, meaning that the standard family has several documents that relate to environmental concerns, all numbered ISO 140XX. The only standard that can lead to registration is ISO 14001--”Environmental Management Systems--Requirements with Guidance for Use,” and it’s therefore the most widely recognized standard. However, the ISO 14000 family also includes more than 20 other guidelines, technical reports, and assessments, including: ISO 14004--”General Guidelines on Principles, Systems, and Support Techniques”; ISO 14015--”Environmental Assessment of Sites and Organizations”; ISO 14051--”Vocabulary”; ISO/TR 14062--”Integrating Environmental Aspects into Product Design and Delivery”; and ISO 14063--”Environmental Communications--Guidelines and Examples.”
Moreover, ISO 14001 isn’t a performance standard. This means that organizations don’t need to meet a specific environmental target spelled out in the standard to become registered; they need only to demonstrate that they’ve identified their significant environmental aspects --which may include RoHS --and have a plan in place to meet continuous-improvement goals that they themselves have set. They must also demonstrate that they’re working to achieve those goals. Because this is a management standard, organizations don’t have to be environmental “overachievers” prior to certifying to ISO 14001.
The decision to position ISO 14001 as a management rather than a performance standard was a deliberate one on the United States’ part. Prior to ISO 14001’s original release, the U.S. technical advisory group (TAG) to ISO/TC 207, the ISO technical committee responsible for ISO 14001, took the position that the United States didn’t want to implement a performance standard that would be a lower environmental standard than current U.S. standards. It was felt that the threshold for the performance level would have to be set low enough that it would be attainable by most member countries, many of which have much lower environmental thresholds. Because these thresholds would fall significantly below those established by the U.S. Environmental Protection Agency and state agencies, the U.S. TAG took the position that a performance standard wouldn’t be in the United States’ best interests. A management standard, by contrast, ensures that organizations throughout the world are able to register to the standard from a wide variety of progress and maturity levels.
The QC 080000 specification used ISO 9001 as its framework. Some of the companies that have implemented QC 080000 report that they’re under pressure from customers to conform to ISO 14001 and QC 080000 -- some customers want one standard certification and some want the other. These companies believe that a better solution would have been a standard that built on ISO 14001 -- such as ISO 14001 with a RoHS or WEEE addition to which a company could certify. A model for this would be similar to what the American Chemical Council implemented when rolling out RC14001, which is essentially ISO 14001 with chemical-industry add-ons. This “ISO 14001-plus” standard would have allowed organizations to demonstrate compliance to ISO 14001, and RoHS or WEEE, with a single registration.
“RoHS fits well into our ISO 14001 framework,” one notes. “We can discuss RoHS in terms of environmental aspects and effects, and manage RoHS via environmental objectives and targets. But we can’t reverse it and implement an ISO 14001 system into a RoHS-registered system because QC 080000 doesn’t require us to detail our organization’s aspects that affect the environment.
“ISO 14001 requires an organization to take a look at its general environmental effect,” the company adds. “QC 080000 is specific only to the control of six restricted substances. Controlling those six substances can, and probably should, be an organizational response toward good environmental stewardship, and therefore should be monitored through a management system required by ISO 14001. The scope of QC 080000 doesn’t include general environmental effects of the organization.”
Implementers of the standards complained that differing customer requirements mean that they must be certified to both standards, which involves two slightly different takes -- at double the cost for registration, implementation, and resources -- on what they describe as similar environmental concerns. Others grumbled that QC 080000’s language is, in the words of one, “awkward, confusing, and redundant, looping back on the same issue or topic again and again,” making it difficult to interpret and implement. Recall that QC 080000’s definition section defines hazardous substances and restricted substances as interchangeable. Yet OSHA defines hazardous and toxic substances as those chemicals present in the workplace that are capable of causing harm. Engineers might argue that restricted substances are those on a list (of restrictions), while hazardous substances are harmful to the environment or health -- and they’re not intrinsically interchangeable.
I also interviewed company representatives who were considering implementing one or both standards. Many companies are deciding to implement one standard over the other based on market or customer pressures; other organizations are still analyzing their options to determine which standard will better meet market needs. Some have decided to implement ISO 14001 to proactively demonstrate their commitment to be a “green neighbor”; others are implementing QC 080000 to proactively demonstrate their commitment to being a “green supplier.”
One organization I talked with is already registered to ISO 14001 (and has been for four years) and was in the process of researching QC 080000. The company is an electronics manufacturer and is repeatedly asked by its customers if it has a RoHS plan in place. Although it has received requests for information on its RoHS compliance from a wide range of customers -- including LG Electronics, Sony, Matsushita Electric Industrial Co. Ltd., Flextronics International, and Panasonic -- none of these has asked if the organization had a QC 080000 certificate. A review of these customers’ requirements shows that many of them ask questions regarding EMS and RoHS without inquiring about certification. There’s consistency in many of the questions from survey to survey:
• Does the organization have an environmental policy?
• Does the organization identify and document legal and other requirements?
• Is there an identified management representative for environmental concerns?
• How are nonconformances handled?
• How is nonconforming material segregated?
• What chemicals, materials, and restricted substances does the organization use in its manufacturing processes?
A few of these customers have asked if the organization is registered to ISO 14001; none of the surveys I reviewed mentioned QC 080000. In all cases, however, customers still want the 10-page surveys filled out. They won’t accept an ISO 14001 or QC 080000 certificate in lieu of a completed survey.
Your choice for compliance may come down to one key factor: whether implementing the standard will satisfy your customer’s requirements. If your customer requires its suppliers to register to one of the environmental standards as a prelude to placing an order, you’ll be implementing the standard as a prerequisite of doing business with them. These organizations are the lucky ones because the decision is already made. Less fortunate companies are those with multiple customers--some requiring ISO 14001 and others requiring QC 080000--that compel these organizations to implement two systems. This leads to replication of effort and actions, and greater expense.
Whichever standard you choose to implement, it will be a win-win situation for the environment. Your organization will realize improvements from implementing a green system; hazardous environmental consequences will be minimized or eliminated; and you’ll be able to show external, independent validation that your company is environmentally friendly. That validation will ultimately produce the kind of green that lines your pocket.
Mary F. McDonald is a 25-year environmental professional and the CEO/CTO of The McDonald Consulting Group, a process implementation and improvement firm in Austin, Texas. McDonald has been a member of the U.S. TAG for 12 years, and as lead auditor conducted the world’s first registration to QC 080000. She’s also an RABQSA-certified auditor for ISO 14001 and ISO 9001, and an OHSAS lead auditor. She is currently working with ABS Quality Evaluations as their environmental, health, and safety program manager. McDonald would like to thank her “D” team of advisors for their help with this article.
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