What Manufacturers Need To Know About WEEE: The Waste Electrical and Electronic Equipment Directive
The Waste Electrical and Electronic Equipment (WEEE) Directive 2002/96/EC of the European Union aims at minimization of the impact of e-waste (discarded or end-of-life electrical or electronic equipment [EEE]), on the environment by increasing re-use and recycling and reducing the amount of WEEE going to landfills. It is closely linked to the Restriction of Hazardous Substances (RoHS) Directive 2002/95/EC which seeks to limit the presence of six hazardous materials in electrical and electronic equipment.
There are several categories of electronic waste or e-waste that fall under the WEEE Directive: large and small household appliances as well as consumer products are included. E-waste in this directive means electrical and electronic equipment (EEE) designed for use with voltage ratings of up to 1000V ac or 1500V dc. Hence manufacturers of most electronic consumer goods used in day to day life, fall under the purview of the directive. Since the consequences of non-compliance are serious (including possible ban on doing business in EU countries), manufacturers need to be conversant with the WEEE and the related RoHS directives.
The WEEE Directive seeks to minimize the environmental impact of e-waste by mandating its collection, treatment, recovery and/or recycling should be facilitated and financed by producers. It also proposes that consumers be able to return their waste equipment free of charge. Manufacturers, therefore, need to assess the impact of these requirements and initiate appropriate action for implementation.
This involves setting up collection centers for e-waste, arrangements for transportation to the recovery and/or recycling centers, facilities for recycling and determination of final disposal options. Recovery and recycling of electronic waste is specialized work and recycling plants must conform to certain minimum standards.
Operation of captive recycling facilities may be both uneconomical and beyond the core competence of equipment manufacturers. Hence suitable tie-ups with external recycling establishments may need to be entered into by manufacturers, either singly or through collective arrangements. The foregoing are post-sales activities.
It is very important for a manufacturer to also understand the importance of certain pre-sales actions which impinge upon compliance significantly. These are actions at the design and manufacturing stages.
First is the effort to design equipment which can be dismantled into the smallest possible parts and components. This will facilitate recovery of the parts for reuse; a more economical proposition than say, recycling.
Second, manufacturers must ensure labeling of products is in line with the requirements of the WEEE Directive including a “Do Not Landfill” note.
Third, reduction of hazardous material content in the product greatly reduces the need for expensive recovery efforts. It also contributes to overall environmental conservation. For this reason, the importance of RoHS compliance of products and processes cannot be over emphasized. The sooner manufacturers recognize this fact; the better their profits will be long term.
The WEEE 2002/96/EC Directive is not a law and individual EU member states are to incorporate its provisions into their own legislations. Since differences in the laws across the EU member states are inevitable, multi-national manufacturers may need to develop innovative compliance solutions.
Further, the WEEE Directive is based on Article 175 of the EC (European Community) Treaty – the Treaty establishing the European Union. This allows member states to include additional products as long as they countries adhere to European Community laws governing overall trade and commerce within and beyond the EU. Manufacturers must stay abreast of more environmentally sound practices and current WEEE changes. They also need to be aware of the implication of such changes on their businesses.
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OSHA Process Safety Management (PSM) of Highly Hazardous Chemicals
Industries using hazardous chemicals (“Dangerous Products” in European parlance) in their processes are especially vulnerable to accidents. These substances include the possibility of unforeseen and even catastrophic release of toxic or inflammable liquids and gases. Catastrophic release is defined as a major uncontrolled emission, fire, or explosion, involving one or more highly hazardous chemicals, that presents serious danger to employees in the workplace.
Recognizing these vulnerabilities, agencies such as the Occupational Safety and Health Administration (OSHA), and the Environmental Protection Agency (EPA), have developed enforceable regulatory frameworks for workplace safety and health, including penalties for non-compliance. This framework includes documenting information pertaining to the hazards of the highly hazardous chemicals used and/or produced and information pertaining to the technology and equipment used in the manufacturing process. A written plan of action detailing the safety measures being applied must also be provided.
OSHA has the primary function and the authority to develop and implement rules and regulations aimed at protecting workers in their workplaces. One of the most important such initiatives is the standard for Process Safety Management (PSM). The PSM is officially known as the 29 CFR 1910.119, Process Safety Management of Highly Hazardous Chemicals. It lays down detailed criteria which have to be followed for the prevention of any potential disaster due to catastrophic releases of toxic, reactive, flammable, or explosive chemicals and for the minimization of the consequences of such incidents.
While there are specific PSM Standards for the construction and general industries, the OSHA Standard essentially applies to the management of risks related to highly hazardous chemicals and is somewhat similar to the EPA Risk Management Program (RMP) regulations (Title 40 CFR Part 68). The PSM Standard of OSHA is not merely a set of specifications but strives to provide a comprehensive safety management program that can be implemented by industry and enforced by OSHA. These include concise documentation of toxicity information, permissible exposure limits, reactivity data, corrosivity data, as well as thermal and chemical stability data. Also addressed is an examination of the hazardous effects of inadvertently mixing different chemicals and the ramifications that could occur.
These powers of enforcement arise from The Occupational Safety and Health Act passed by Congress in 1970. The Act provided a legal and constitutional framework for the development and enforcement of workplace safety and Health related rules and regulations, including provisions for penalties for non-compliance. Through the enactment Congress also created OSHA as a division of the U.S. Department of Labor, to oversee the administration of the Act and enforce its standards throughout the United States.
The National Institute for Occupational Safety and Health (NIOSH) was similarly created as a federal agency responsible for conducting research and making recommendations for the prevention of work-related injury and illness. Bearing in mind the need for balance, Congress also created the Occupational Safety and Health Review Commission (OSHRC), through the same act. OSHRC is an independent agency for mediation of workplace safety and health disputes between the Department of Labor and employers. It is not part of any other Federal department.
The enforcement powers enjoyed by OSHA include the power to carry- out investigations and to inspect/audit organizations, to asses the level of compliance to mandated health and safety standards. In cases of violations, OSHA is empowered to issue citations to the erring entities and also propose penalties.
The effective implementation of health and safety standards, which requires multi-faceted inter-disciplinary efforts, is never easy in any industry. However, the OSHA initiatives, including the PSM, (together with similar efforts of other agencies in the field of industrial health and safety), have succeeded in reducing work-related fatalities by 50 percent. OSHA initiatives have also helped reduce on-the-job injuries and illnesses by over 40 percent since 1970. The development and subsequent actions of OSHA in America can legitimately be considered a major success story and a powerful inspiration for similar agencies seeking to insure health and safety in the workplace.
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RoHS Complaint Industrial Control Switches
The RoHs directive restricts the use of lead (Pb), mercury (Hg), hexavalent chromium (Hex-Cr), poly-brominated biphenyls (PBB) and polybrominated diphenyl ethers (PBDE) to maximum 1000 parts per million and cadmium to 100 ppm. The restrictions are on a homogeneous material basis, which means that they apply to any single substance that could (theoretically) be separated mechanically.
The restricted substances have traditionally found extensive usage in Industrial control switches because they impart strength, reliability and durability. These are crucial properties as the switches often operate in harsh conditions such as in boilers, etc. They are expected to have a long life and operate accurately and reliably. These restrictions have therefore been challenging to the switch industry.
While the industry has taken commendable initiatives for RoHS compliance, the efforts have neither been easy nor entirely successful thus far. This is not to detract from the sincere efforts that have been attempted. The main problem has been the availability of RoHS compliant components and parts. The majority of electronic parts available today contain at least one of the restricted substances: Pigments contain cadmium, mercury is present in infrared detectors, PBBs and PBDEs in plastics used as flame retardants, lead in solder joints and inhibited paints contain Hex-Cr. (chromium is passivated by oxygen, forming a thin protective oxide surface layer which prevents oxidation of the underlying metal. Common oxidation states are +6 i.e hexavalent chromium and +3 (i.e trivalent chromium).
A number of products have been developed to replace the banned substances. However, long term reliability, an important parameter for the switch industry, is yet to be established. Examples of such alternates are Hex-Cr, replacements such as trivalent chromium, molybdates etc. These are, however, substrate specific; in other words they require a particular type of under-coating to be applied for proper adhesion and protection, which Hex-Cr does not need. This leads to extra costs, in addition to being less flexible operationally. Similarly, lead-free solders based on tin-copper-silver alloys have been developed to replace the traditional tin-copper solder. However, concerns related to durability and reliability still remain. Lead free solders also require a higher reflow temperature. This often entails expensive process changes and retooling.
Achieving RoHS compliance is, to say the least, an arduous task for any company. This is equally true for the switch industry. The difficulties are essentially due to the requirement to meet the maximum allowable limits of the restricted substances on a homogeneous material basis. This requires the entire material flow, starting from raw material and component vendors, to the end product stage be tracked. Also included in compliance standards are consumables like labels, glue, paint etc which can sometimes introduce the undesirable substances into the end product.
An added complication for many control switch manufacturers is that clients include the military and /or aerospace sector. There is no RoHS in aerospace and products with applications that can be considered exclusively “aerospace” need not be RoHS compliant. However this poses more problems in maintaining inventory control of RoHS compliant and non-compliant products for the switch supplier.
While achieving full RoHS compliance is the ultimate goal of the industrial control switch manufacturing industry, managing the transition is the biggest current challenge.
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Preparing For and Surviving an OSHA Inspection
The primary responsibility of the Occupational Safety and Health Administration (OSHA) is to develop and enforce health and safety standards that protect workers in the workplace. It has mandatory power to audit organizations for compliance of health and safety standards. OSHA conducts workplace inspections to make certain that employers are complying with the standards and providing a safe and healthful workplace.
OSHA inspectors, called compliance and safety officers, carry out these inspections/audits. These may be carried out due to accidents, fatalities, situations of imminent danger, complaints and referrals or as a follow-up investigation. An OSHA audit can be a tedious and stressful experience for employers since the agency is empowered to impose penalties on those who are in violation of the standards. This is particularly true for small businesses that may not have the wherewithal to be in full OSHA compliance.
Generally, an employer who takes proactive action (and the associated pains) to try and adhere to mandated requirements will fare much better during such OSHA inspections. A little known fact for many employers is that compliance officers normally research the history of a worksite before an inspection. Therefore it pays to work with the inspectors and answer questions fully and honestly, rather than adopt stalling tactics. Actions like insisting on an inspection warrant, to buy time, can turn out to be counterproductive in the end.
Every workplace is unique; no universal formula can be prescribed for negotiating an OSHA audit unscathed. However, attention to some basic details can help immensely:
First, having an effective safety and health program which lays down the policies, procedures and practices for protection against occupational safety and health hazards helps to develop the proper mindset. Depending upon the type industry and the complexity of operations, these programs may even include a Processes Safety Management (PSM) program mandated by the 29 CFR 1910.119 OSHA Standards. A written program should be communicated to all employees.
Second, coaching employees on health and safety, including OSHA compliant training, should be routine. Proper training is necessary to insure that workers understand potential hazards as well as practice safe working methods.
Third, it is important for companies to stress employee participation in safe practices. Active employee involvement can greatly enhance compliance to OSHA standards.
Fourth, it is imperative that businesses have a written hazard communication program. This is particularly important in industries handling hazardous chemicals. The complexity of the program will obviously depend upon the specific needs of the worksite. It may range from a simple collation of information from Material Safety Data Sheets (MSDS), to a comprehensive OSHA mandated program in line with the 29 CFR 1910.1200 Standard.
Fifth, periodic self inspections and compliance audits will help to identify violations and allow corrective action to be taken. Earlier cases of accidents or injuries, if any, can also be analyzed for possible preventive measures. This will minimize the likelihood of being cited for violations during OSHA audits.
Record keeping is one of the most important tools for providing proof of a company’s efforts to comply with an OSHA inspector. The scope of documentation is wide and the more accurately records are maintained; the better it is for audits. Examples of relevant documentation would be accident reports, injury and illness reports, exposure records (hazmat exposure, noise exposure, etc where applicable), past inspections and action-taken reports, as well as employee training records.
All these steps will lessen the stress of an OSHA inspection and reduce the odds of receiving citations and penalties. As an OSHA fact sheet states, “OSHA’s primary goal is correcting hazards and maintaining compliance, rather than issuing citations or collecting penalties.”
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