| by Dennis Bradley and Gwen K. Wade
The dawn of the electronic age has been a great benefit to the consumer. Cell phones, laptops and other modern devices have changed the face of communications, commerce and even personal relationships. However, there's a downside to all this technology. The lead, mercury, cadmium and other metals that make up these devices are a threat to the health of people and the environment. Establishing a process to manage the risks of hazardous substances throughout the entire product life cycle is now mandated by various governmental bodies, and manufacturers must comply with new standards, specifications and directives.
Hazardous substance process management (HSPM) is a technical approach to implementing and maintaining hazardous-substance-free (HSF) products and production processes. It was developed to enable suppliers to demonstrate, through third-party assessment, their compliance to customer requirements for HSF electrical and electronic components and assemblies that meet specific local, national and international requirements.
HSPM certification through the International Electrotechnical Commission Quality Assessment System for Electronic Components (IECQ) provides companies with an international certification process by which they may demonstrate their ability to control and manage design activities, their supply chain, materials management, and manufacturing processes specific to their customer requirements for IECQ HSPM and HSF components and assemblies. Through this internationally agreed-upon technical specification for certification, accredited third-party assessors examine a company's processes to manage, minimize and/or eliminate hazardous substances to meet the highest standards.
Organizations are already overwhelmed with costly and redundant component testing to demonstrate Restriction of Hazardous Substances (RoHS) compliance and are struggling to meet their customers' various but similar Green Process management system requirements. EIA/ECCB-954, Electrical and Electronic Components and Products Hazardous-
Substance-Free Standard and Requirements was developed with this in mind, and it was released as the U.S. national standard in March 2005.
In April 2005 the IECQ Management Committee agreed at its annual meeting in the United Kingdom to allow the United States National Authorized Institute to begin an international IECQ HSPM pilot program using the EIA/ECCB-954 standard.
In October 2005, following the IEC Conformity Assessment Board meetings in South Africa, it was agreed that the IECQ would release EIA/ECCB-954 as an international specification, given the international document title QC 080000 IECQ HSPM.
With this specification, IECQ provides a common-sense process and system assessment approach. The IECQ HSPM specification incorporates applicable parts of the RoHS directive, the European Commission directive regarding Waste Electrical and Electronic Equipment (WEEE), California state bill 50 (SB-50), the Electronic Waste Recycling Act of 2003, Green Process management system requirements and Japan's Green Procurement Survey Standardization Initiative (JGPSSI) guidelines. This approach is far more cost-effective than the post-production, product-focused testing method that had been used previously.
The specification provides a framework for process management and control to ensure that finished products meet regulatory and customer requirements. It's designed to work with changing standards and the regulations that emerge from them. This includes Green Process management systems which take a much more comprehensive approach to the elimination of hazardous substances than RoHS or SB-50. IECQ HSPM is based on the belief that the achievement of HSF products and production processes cannot be realized without effective integration of management disciplines, and that the solution must be process-based and designed to prevent the problem. In other words, you can't "test in" compliance.
Numerous departments in an organization must work together to meet the new requirements. If you want to achieve HSF results in products and processes, change must be comprehensive and coordinated. Because compliance can't be "tested in," a process management approach is needed. Statistical process control is important, but the best use of SPC in this regard is to monitor process stability while integrating function and discipline input.
IECQ HSPM is comprehensive in scope and incorporates management of all hazardous substances in addition to those specified in RoHS. Not all organizations can meet all requirements, but with the specification in place, hazardous substances can be managed in an HSF environment until each of these substances can be eliminated.
Once certified as having satisfied IECQ HSPM requirements, a company is presumed to satisfy disparate customer and governmental HSF regulatory requirements. Currently, RoHS outlines concentration limits, but not how to meet them through testing. If you put IECQ HSPM in place, you can manage and update your processes as changes are made.
The specification is a supplement to the ISO 9001 framework for the comprehensive and systematic management and control of processes pursuant to HSF goals. ISO 9001 provides a blueprint for optimization of business and quality management systems. IECQ HSPM was written to fit into that blueprint and strengthens adherence to the principles and practices prescribed by the International Organization for Standardization and directs their application to the management of hazardous substances.
The superstructure for effective quality and business management already exists, so why reinvent the wheel? IECQ HSPM assumes you already have a quality management system (QMS). Thus, IECQ HSPM addresses the technical aspects of compliance, from how you train specific employees to how you control lead and other potentially hazardous substances. Accordingly, there's nothing about customer satisfaction in the specification because it should already be covered in the QMS.
Fortune 500 companies that understand IECQ HSPM find it to be a common-sense way to deal with Green Process management system requirements, including compliance with RoHS and WEEE.
There are many benefits to IECQ HSPM registration, including:
• Accreditation can demonstrate to regulators that a manufacturer's processes are free of hazardous materials or that the hazardous substances used are properly controlled and communicated to users of the products.
• Companies that can manufacture according to IECQ HSPM receive an internationally recognized certificate of conformity to the specification.
• Registration tells the global marketplace that you have the capability to properly manage your processes to get your products on the path to HSF compliance.
• Compliance grants access to global markets and creates competitive advantage.
• Registration demonstrates compliance with regulations, statutory requirements and the highest industry standards.
• Compliance to IECQ HSPM saves money by reducing costs.
The effects of California's SB-50 are widespread. For example, you cannot import bronze statues into California due to their lead content. Some pots and pans have similar problems. Similarly, in California you can get a cell phone for free, but you'll pay $7 or $8 to get rid of it, and there are fines if you are caught disposing of electronic items irresponsibly.
Maine has a tough bill from 2003 that phases out all brominated fire retardants, lead, mercury, cadmium, hexavalent chromium and polyvinyl chloride (PVC) in electronics equipment by 2006.
Massachusetts and Minnesota have banned e-waste, including cathode-ray tubes, from landfills. Other states are starting to follow suit. Approximately 38 states have some sort of e-waste program in place, and many are looking to prohibit or restrict the disposal of mercury and flame retardants.
What's important to understand is that these initiatives are occurring at the state level. Each state may have different requirements a manufacturer has to meet.
The problems of electronic waste that IECQ HSPM addresses aren't just facts and figures--these issues have a real effect on the quality of life in the United States and throughout the world. For example:
• Four million tons of e-waste lands in U.S. landfills annually. (Source: Environmental Protection Agency)
• Included in this total were 130 million cell phones during 2005. (Source: Environmental Protection Agency)
• There are six million tons of e-waste annually in the European Union.
• Of this total, 90 percent is incinerated or winds up in a landfill.
• This total amounts to 13 kg/person in the European Union.
• Current projections estimate that there will be 12 million tons of annual e-waste in the European Union by 2015.
These are the realities driving international directives to minimize and reduce electronic waste and hazardous substances.
Industry is responding to these demands, and the largest of the Fortune 500 companies are rapidly embracing Green Process management systems. Many companies are now producing HSF products, but some are also still producing hazardous products. A chip made in the United States may be RoHS-compliant, but the same chip made in another country may not be compliant because of the plastic it contains. However, the part number may be the same on both. How does an organization know which is which and track the parts accordingly?
A company might advertise itself as RoHS-compliant yet only produce one HSF product. You must ensure that you're getting HSF products or components if that's what you need. Furthermore, how does one manage a mix of hazardous and HSF parts? Perhaps your company has one silk screen that is used with both leaded and lead-free solder paste. Do you get another screen, or do you implement a cleaning process? Is there new material for plastic molders that is RoHS-
compliant? Perhaps your company has leftover noncompliant material it wishes to use as regrind. How do you manage the process of using regrind and maintaining RoHS-compliant products?
In April 2005, a pilot program began which assessed three IECQ HSPM systems. Eight training classes and numerous presentation/review meetings were held worldwide. IECQ HSPM system assessments were conducted in the United States, Taiwan, France and China. The companies assessed were SigmaTel Inc. in the United States, Solnet Technology Inc. in Taiwan, Deltron Electronics Plc. in France, and Fook Tin in China and Hong Kong.
The first assessment was completed by NSAI Inc. at SigmaTel, a fabless integrated circuit (IC) and software-tools design company with more than 600 employees worldwide. ECCB's certification committee reviewed and approved NSAI's recommendation for registration.
The second IECQ HSPM registration was conducted by DNV Certification at Solnet Technology. The company manufactures a variety of lead-free and Green Process management system solder products. The ECCB certification committee reviewed and approved the recommendation for registration.
Solnet Technology is a lead manufacturer. Ironically, lead-free manufacturers often require lead parts. For example, military and avionics end users cannot accept lead-free parts because of tin whiskers. Many companies that use lead are considering embracing IECQ HSPM because it addresses process management, and they want a way to safely and legally distribute and obtain lead parts.
The third IECQ HSPM assessment was conducted by LCIE on Deltron Electronics. The company is a division of the Deltron Electrical and Electronic Components Group, which is a European component distributor. The results of the assessment were reviewed by the LCIE certification officer and approved in accordance with LCIE procedures for registration and the ECCB certification committee.
The fourth and fifth registrations were conducted by SGS Hong Kong on Fook Tin Technologies Ltd. in Hong Kong and its wholly owned manufacturing company Cha's Electronic Industries (Shenzhen) Co. Ltd. in Bu Ji, Shenzhen, Guangdong, China. The company designs and manufactures electronic mechanical weighing scales, including body-fat scales; load cells for weighing devices; health care and medical devices; electrical and electronic devices; and household appliances. The ECCB certification committee reviewed and approved the recommendation for registration.
As the IECQ HSPM pilot program continues, other major international companies are preparing for registration. Original equipment manufacturers worldwide are considering the use of third-party certification as a means of reducing their supply chain management cost while helping a supplier reduce its own internal cost of compliance. Companies that have undergone the registration assessment have commented that the specification and the assessment process is a sensible way of demonstrating compliance.
IECQ HSPM training classes have been held in the United States, Taiwan, China and France, and a peer assessment was conducted on the class given in France. As part of the training accreditation process, a peer assessment was performed on the training material and trainers. Philippe Guillon from LCIE was the lead assessor conducting the assessment as part of the June 2005 training sponsored by and presented at LCIE in Paris.
IECQ HSPM overview presentations have been given in Chinese Taipei, the United States, Singapore, Malaysia, China, Japan, Thailand and South Africa. Future presentations are planned for Thailand, China, Taiwan, South Korea, Japan, France, Germany, Ireland, the Philippines, Indonesia, the United States and Australia.
In general, the IECQ HSPM specification is being well received by industry throughout Asia, the United States and in some parts of the European Union. Current industry debate continues between product testing analysis vs. the process management approach, with a growing trend favoring management of the process as a more cost-effective means. Similarly, discussions continue concerning the role of a supplier's declaration and third-party certification. It's clear that suppliers, required to demonstrate compliance to a full Green Process management system by their customers, are finding value in the IECQ HSPM approach.
Because the specification is based on Green Process management systems approval requirements, it addresses the minimum acceptable hazardous substance and HSF requirements of customers worldwide. This includes the acceptance of third-party assessments as a way to demonstrate compliance to customer-specified Green Process management systems. The growing trend for supplier-certified management systems is demonstrated by the continued interest in IECQ HSPM from large and small companies around the world.
Registrars NSAI, DNV, LCIE and SGS are actively working with companies that are preparing for IECQ HSPM certification in 2006. Based on feedback from the representatives of the four companies listed above, more than 300 companies will seek certification in 2006. China's Supervising Inspectorate, CEPREI, has also requested approval to operate under the U.S.-led IECQ HSPM pilot program, thus enabling them to provide training and certification services in support of manufacturers in China.
The requirements of HSF are here to stay. This is evident based on the following observations:
• You must ensure your products are HSF.
• You must know your suppliers are HSF.
• You must ensure you meet a myriad of global HSF requirements.
• You must keep up with the changing HSF environment.
• You must have processes in place for dealing with HSF.
Dennis Bradley is the founder and vice president of business development for the Salot Bradley Group International (SBGi). Bradley co-authored EIA/ECCB-954. For 25 years he has combined organizational change consulting with teaching and guiding continuous process-improvement practices that have enabled clients to achieve best-in-class performance levels.
Gwen K. Wade is the senior technologist for the Salot Bradley Group International (SBGi). Wade co-authored EIA/ECCB-954, has more than 25 years of experience as a quality professional, is an IECQ HSPM and ECMP lead assessor and trainer for IEQC, an RAB-certified QMS auditor, ASQ senior member and past chairman of the Silicon Valley Section of the ASQ.
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