Welcome to the June 2008 Design Chain Associates E-mail Newsletter!

• DCA's New Website!
• Special Report: Dissecting the Counterfeit Electronic Component Problem - part 3 of our series
• ANSI - Keeping up on Chemical Regulation Issues
• REACH Updates
• IEC Product Safety Standards and Fire Retardant Chemicals
• Events to Attend
• Contact and Feedback

DCA's website has not gotten overhauled in several years; this has been long overdue! We needed a clear way to help you, our clients and prospects and other interested people, understand what we do and quickly obtain the information you need. So now we invite you to visit our website, review our three primary focus areas of Environment, Product Lifecycle, and Supply Chain, and learn more about how DCA can help you address and solve the most pressing issues to the electronics and manufacturing communities today!

In December, to kick-off the series we discussed the scope of the problem with counterfeit electronic components, the geographic and financial drivers, and the contributing factors that make our industry vulnerable to unscrupulous operators and purveyors of bogus parts.

In the second part of the series in February, we examined the origins of these components, classified them, and defined the risks associated with these counterfeit component classes.

In this installment, we will talk about prevention and actions you can take to lessen the chances of becoming a victim.

ANSI describes itself like this: "As the voice of the U.S. standards and conformity assessment system, the American National Standards Institute (ANSI) empowers its members and constituents to strengthen the U.S. marketplace position in the global economy while helping to assure the safety and health of consumers and the protection of the environment."

DCA participates in several ANSI activities, including the ANSI Manufacturers Network. The purpose of the network is twofold:

• To bring together disparate stakeholders who are impacted by chemical and other environmental regulation.
• To provide a forum for cross-industry, and cross-sector, communication and discussion on chemical and environmental issues.

1. It's free. You don't even have to be an ANSI member.
2. There are hundreds of members, up from about eight a year and a half ago when we started, representing many manufacturing industries across the spectrum of the supply chain, academia, governments, and standards bodies.
3. We have free monthly conference calls to raise awareness of new issues, create links between companies, stakeholders, and industries where there were none before, and enable them to more efficiently address the challenges of environmental compliance.
4. The Chemical Regulation Events Calendar
5. This is where cross-industry strategic approaches are seeded and developed.
6. We would like to see more participation from the electronics industry. There are silos within companies, within industries (yes, even the electronics industry), and between industries, as well as between the different stakeholders. Unless we all start communicating, the solutions we apply to global challenges such as product-targeted environmental regulations will continue to be inefficient, costly, and less effective than desired.
7. Did we say it's free? We'll say it again: it's free.

There are a few updates to the ongoing EU REACH saga:

• The pre-registration period has started and continues until December 1, 2008.
• The list of recommended candidate Substances of Very High Concern (candidate SVHCs) will be available for stakeholder comment after June 23. We expect a rather short list (~20?). Once the European Chemicals Agency approves the final candidate list in mid-October you will then have to address it with your supply chain and customers, and anyone that asks, per article 33 of the REACH regulation. The actual authorization process will start after that with a final list of substances submitted for authorization next June.
• The guidance for Article manufacturers is finally available. Six EU member states disagreed with the conclusion of the Commission Legal Service that the threshold for disclosure of candidate SVHCs for article 33 should be 0.1% of total article mass; they would like to see it at a lower level, like the component part level (in electronics). Does this matter? We don't know yet; enforcement is at the Member State level and the guidance is not legally binding. Expect either court challenges or revision proposal.
• ASTM's F40 working group WK15430 has now published version 1.0 of the Standard Guide for European Union’s Registration, Evaluation, and Authorization of Chemicals (REACH) Supply Chain Information Exchange, or F2725-08. DCA participated in the development of this guide and, while this was produced very quickly (for an international standard - we started working on last August), it has the potential to be very useful. There will no doubt be a version 2.0 but in order for that to happen, people and companies need to use it and identify strengths and weaknesses. So buy it today - only $49 - and please start using it.

In developing a new hazard-based standard for product safety under the auspices of the International Electrotechnical Commission, the members of technical committee 108 (TC108) have been dealing with a demand from the National Association of State Fire Marshals (NASFM, a member of the US National Committee for TC108) to make enclosures for most electronics that could be found in the home (audio/video, and much information technology equipment) flame retardant. The rationale used has been the danger of external ignition from candles. The evidence and rationale presented by NASFM for this has, however, been unclear, inapplicable, and/or inappropriately extrapolated fire data taken from the EU and the US.

The group of mostly electronics manufacturers has spent many years fighting this, but ended up developing a technical standard (IEC/TS 62441) that describes the actual test requirements and reluctantly approving the inclusion of a candle flame ignition requirement in drafts of IEC 62368 (a future hazard-based product safety standard), and upcoming revisions of 60065 and 60950 (Audio/Video and IT product safety standards respectively). Some scientists and researchers found out about this - they are also fighting NASFM attempts to fire-retard other types of products - and were extremely concerned that this would dramatically increase the use of bromine-based or phosphorus-based fire retardants that have either inadequate or no toxicity assessment information available, or are known to be hazardous. They engaged DCA, an ANSI member company, to get on the US National Committee for TC108 to find out more, see why this had progressed so far, and help them determine the best course of action.

Long story short - NASFM operates out of a Washington DC lobbyist's office. While they are a seemingly credible organization, they appear to be tied to the fire retardant chemical industry in many ways, primarily through this lobbyist (Peter Sparber & Associates, which also represents at least one major flame retardant chemical company and is associated with a number of flame retardant chemical associations and entities) and, in this case, are clearly resolved to promote the FR chemical industry's agenda, despite the fact that there are now fire-safe candle standards, a continued lack of fire data showing a problem with candles and electrical/electronic equipment of any significance whatsoever, and a clear and growing body of evidence of toxicity or lack of data of many of the candidate substances that could possibly be used in plastic enclosures. So with the help of a growing coalition of scientists and researchers a detailed technical paper was produced that describes why this is a Bad Idea. And with the assistance of an international and growing coalition of environmental NGOs, we made sure this paper got in to the hands of nearly every National Committee around the world that was voting on this standard, and we prevailed. Only months ago we were told that passage of this was "inevitable" unless we "had a silver bullet". Turns out we did - the facts.

Next up is the revision of the audio/video standard, IEC 60065, which includes a candle flame ignition resistance requirement for televisions. Click here to read why candle flame resistance for TVs is also a Bad Idea.

We will have more of this story as it continues to evolve. Nevertheless, the point of it is this:

July 16, 2008: It's Not Easy Being Green Cambridge, MA

Mike Kirschner discusses REACH and the actions required to comply at this IPC conference on electronics and the environment.

September 18, 2008: Global Environmental Regulations: Updates on RoHS and WEEE, and an Intro to REACH Santa Clara, CA

Mike Kirschner delivers a workshop that will give you an update on RoHS and WEEE, and then spend the bulk of the time on REACH. We will describe what it is, how it affects electrical and electronic products and supply chains, and what companies need to do to comply as well as identify and mitigate risk. We'll glimpse in to the future, as well, at upcoming issues and challenges to our industry and others.