Did your company make it? We're about a week past the July 1, 2006 deadline for compliance with the European Union's Restrictions on Hazardous Substances (RoHS) directive. Yet some companies still are working to ensure their products are lead-free. Getting the lead out under the EU's demanding new environmental rules hasn't been easy, especially for OEMs, who have ultimate responsibility for RoHS compliance.
"This is a big challenge for them because they're concerned about the usability and the serviceability of the components they're about to receive," says David Haataja, vice president and general manager of Underwriters Laboratories' Restricted Substances Compliance Solutions. "Many are still in the planning stage. That's tough because the deadline is coming up fast and putting a product on the market is your declaration of conformance. So, there's still some scrambling going on."
Clearly demonstrating due diligence is critical, says Haataja. At a minimum, this means keeping careful data records, monitoring and auditing suppliers, responding to customers' questionnaires and surveys, and obtaining Certificates of Certification. Haataja also suggests making product testing data available to customers.
In Hewlett-Packard's case, what's new is old in environ-mental terms. HP began investigating alternative soldering techniques in the early 1990s, essentially as part of developing a broader environmental perspective. "We were trying to understand the implications of eliminating lead from our products," says John Frey, HP's manager of Corporate Environmental Strategies.
But many companies are only now getting with the program. To help its 2300 member companies in the interconnection sector of the industry, IPC-Association Connecting Electronics Industries has launched its Certification for RoHS Lead Free Electronics Assembly Process Capability Program in North America and Europe.
"The IPC certification audit program has a long name but a simple goal, and that is to audit an electronics assembly facility—whether it's an OEM or EMS [electronic manufacturing service] company—to determine if the company's facility is capable of producing product to meet the lead-free requirements of the RoHS directive," says John Kania, IPC director of assembly industry programs. "The audit is not designed to, and cannot ensure, a facility will produce RoHS lead-free compliant products."
Kania says the certification audit program is a rigorous series of steps culminating in a two-day audit of the site's assembly operations. "The program allows both large or small companies to benchmark their processes and to judge their capabilities to meet RoHS lead-free assembly requirements," he says.
The program consists of 15 technical categories covering assembly-related issues such as equipment capability and compatibility, employee training, material compatibility, component handling, materials declaration, and documentation procedures. The audit itself will consist of more than 300 questions along with an on-site review by an IPC-trained auditor. By passing both the written and on-site audits, companies will confirm their lead-free process capability.
"Companies will not receive a rubber stamp certification," notes Kania. "This is an in-depth program that requires an exhaustive and thorough audit of one's processes."
The certification audit program took seven months to develop. So far, two EMS facilities in the U.S. have been certified following beta testing of the program. Solectron's facility in Charlotte, N.C., was the first beta test and the first Tier 1 EMS facility to receive certification. Raven Industries of Sioux Falls, S.D., successfully completed the second beta test on May 1.
OEMs and industry suppliers then evaluated and approved the structure and content of the program. Additional information on lead-free certification is available by downloading the program brochure and a sample audit checklist at www.ipc.org/LFCert.
WE'LL BE BACK
Like many large OEMs, HP has been auditing its vendors for years. "Start with the fact that HP is a very big customer with lots of vendors. That in itself generates a certain level of interest," says Frey.
"But you get a different level of interest when you say to a vendor that you're going to visit their operation and see how they're doing against our set of criteria," he adds. "And when you tell them you're going to be back next year, or if we find issues and say we'll be back in six months to see what kind of progress they're making in areas of concern—especially if it's something that might jeopardize our relationship—you get a whole different level of interest." Frey also says that HP usually is willing to work with its vendors to correct technical or other issues.
"Even companies that have explored lead-free know that research isn't enough," says John Perry, IPC technical project manager and conference director.
UL also has developed two new programs designed for organizations seeking to demonstrate due diligence in compliance with RoHS. Under the RoHS Product Certification Program, UL tests representative samples of a product at the homogeneous level for all six substances restricted by RoHS.
UL's Restricted Substances Management Systems Registration assesses an organization's compliance with the standards established by the International Electrotechnical Commission Quality Assessment System for Electronic Components (IECQ QC 080000 HSPM), which deal mainly with process management issues and generally require that organizations have implemented processes to identify and control the hazardous substance content in their products.
"UL created these services in response to the need in the industry for additional confidence when self-declaring their products are in compliance with the RoHS directive," says Haataja.
By most accounts, the industry still has plenty of work to do at the design level. Jasbir Bath, a manufacturing engineer with Solectron, says industry companies are still trying to understand how lead-free processes impact their product designs.
"Many companies are asking how design standards will change to address lead-free soldering relative to tin-lead soldering," Bath says. But he doesn't believe design standards are changing, at least not from current production information for lead-free consumer products, including cell phones and laptops. He also says Solectron is documenting these and related issues in a design guide.
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