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Transcript of Creating Manufacturing Efficiency. Accelerating Your Profit. What they are and how they impact you...
Creating Manufacturing Efficiency. Accelerating Your Profit.
What they are and how they impact you
EnvironmentalInitiatives
Worldwide
Copyright 2007 by Brooks Automation, Inc.
Training TopicsTraining Topics
The Concern The Focus The Legislation The Primary Substances The Products Covered Legal Requirements vs. Customer Requirements Brooks Current Status Next Steps and the Roadmap to Compliance
Copyright 2007 by Brooks Automation, Inc.
The Concern - What is driving environmental change?The Concern - What is driving environmental change?
The number of disposable electrical and electronic equipment (EEE) is increasing very rapidly Cell phones, PDAs, laptops, desk tops, printers, other
office and mobility products Toasters, coffee makers, sandwich machines,
household appliances, televisions
End of life usually means the trash can and then the land fill
There is not enough voluntary recycling
Toxic waste material is getting into the waste stream and into natural resources – land, water, air
Copyright 2007 by Brooks Automation, Inc.
The Focus – What products are affected?The Focus – What products are affected?
Consumer products Products that are replaced often Products that are disposed of easily
Office products Office machines that are replaced due to obsolescence Machines that are no longer needed
Industrial products Production equipment, tools Anything from hand tools to very large machines
Virtually any electrical or electronic
product is covered by this legislation
Copyright 2007 by Brooks Automation, Inc.
The LawThe Law
All legislation is similar but there are key differences
Some are aimed at consumer products only Some allow exemptions based on equipment type Some allow exemptions based on equipment
function Some do not allow any exemptions
Worldwide Requirements are similar more than they differ.
Copyright 2007 by Brooks Automation, Inc.
The Primary RoHS SubstancesThe Primary RoHS Substances
The focus is on Heavy Metals There are 6 basic substances:
Lead Mercury Cadmium Hexavalent Chromium PBB (used in plastics as a flame retardant) PBDE (used in plastics as a flame retardant)
These are known health hazards
Copyright 2007 by Brooks Automation, Inc.
The Primary RoHS SubstancesThe Primary RoHS Substances
There is a Maximum Concentration Value (MCV) for each of the substances
MCV for all is .1%, except for Cadmium which is .01%
MCV is based on the lowest homogeneous part of the product Homogenous level has a uniform composition and no
further separation by mechanical action (such as unscrewing, cutting, brushing or grinding) can be accomplished. Chemical separation is not allowed
These limits are the same for all current requirements
Copyright 2007 by Brooks Automation, Inc.
Products CoveredProducts Covered
Varies by legislation EU RoHS has 10 categories of electrical and electronic products
based on EU WEEE Directive EU RoHS currently exempts:
Large Scale industrial Tools (as part of Category 6 products they are exempt from WEEE and therefore also RoHS)
Medical Products – Category 8 Control & Laboratory Products – Category 9
China has a list of EIP – Electronic Information Products – that covers most of the known electrical and electrical products today
This is for Phase 1; different list will be used for Phase 2 All others are a subset of one of the above
Basic requirement is that the product use electricity
Copyright 2007 by Brooks Automation, Inc.
RoHS Comparison ChartRoHS Comparison Chart
EU CHINA JAPAN KOREA USASTATES
OTHERS
Implementation Date
Currently in Effect Phase 1 in effect
Currently in Effect
January 1, 2008
CA – in effect
Work is in progress in Australia, Canada, New Zealand and 26 US cities and States.
US will most likely follow California.
Australia will probably follow EU RoHS.
Canada is monitoring the US and EU
Legally required action at this time
LSIT – noneCat 9 – noneCat 6 (other than LSIT) – currently in effect
Disclosure by EPUP label and information table
No Legal Requirement at this timeDisclosure and prohibited use per Tables
None (will be same as EU ? ? ?)
Disclosure, prohibited use and mandatory recycling
Products Covered
1 - Large household appliances2 - Small household appliances3 - IT and telecommunications equipment4 - Consumer equipment5 - Lighting equipment6 - Electrical and electronic tools (with the exception of LSIT)7 - Toys, leisure and sports equipment8 – Medical Products9 - Monitoring and control instruments10 – Automatic Dispensers
As Listed in the EIP(if it uses electricity assume it is covered)
Japan RoHS Consumer Products- - - - - - - - Japan’s Green Initiatives covers all products and uses JIG-101 as the restrictive document; covers any B2B product as requested by the customer; also requires ISO 14001 Certification
Same as EU (???)Electrical & Electronic Products including components
Vehicles including components
May only include high volume waste products – yet to be determined
CaliforniaCRT, LCD, Plasma Displays ≥ 4” diagonal display
“Not covered if they are part of industrial, commercial or medical equipment”
Copyright 2007 by Brooks Automation, Inc.
RoHS Comparison ChartRoHS Comparison Chart
EU CHINA JAPAN KOREA USA OTHERS
SubstancesCovered
LeadCadmiumMercuryChromium VIPBBPBDE
Same As EU Same as EU plus:
JIG = JIG A + JIG BJIG A = ( EU + 8)
JIG B = (+9)
Same As EU LeadCadmiumMercuryChromium VI
Pending
Future
legislation
MaximumAllowableLevel
Cadmium ≤ 0.01%All others at ≤ 0.1%
Same As EU Same as EU forRoHS + JIG 101values
Same As EU SameAsEU
ExemptionsAllowed
Based on applicationto and approval by EU; exemptions allowed forsubstances necessaryfor product function(lead in X-rays,mercury wetted relays,etc.
None None If elimination ofhazardoussubstance isextremelydifficult due toSpecialCharacteristicOf productsconcerned orthere is nosubstitute, andfor R&D andproducts forExport
Asallowedby the EU;
Also ifSubstanceuse isrequired toMeetsafetystandards
Pending
Future
legislation
Copyright 2007 by Brooks Automation, Inc.
RoHS Comparison ChartRoHS Comparison Chart
EU CHINA JAPAN KOREA US
Compliance Drivers
Legally required forcovered products
Competitive Position
LegallyRequired
Competitive Position
Customers who have adopted a “Green Procurement” program
Competitive Position
ISO14001
Will belegallyrequiredfor covered products
CompetitivePosition
Legallyrequired for CoveredProducts
Comments and Notes
Cat 8 and Cat 9 willprobably be included inRoHS by 2010-2012
LSIT may be the topicof a future EUconsultation report (~2012)
Phase 2 will require restriction onsubstance usebut in a smallerproduct listingCatalog will becreated forproduct list
Customer Driven as noted above
SupportLegislationnot yetreleased
Does notaffectBusiness tobusinessProducts
Copyright 2007 by Brooks Automation, Inc.
Environmental TimelineEnvironmental Timeline
ID Task Name Start2006 2007 2008 2009
Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4
1 8/15/2005EU WEEE
2 7/3/2006EU RoHS
3 3/1/2007China RoHS Phase 1
4 1/1/2009China RoHS Phase 2
6 1/1/2008Korea RoHS
1/2/2006Japan JIG-1015
anticipated date
Copyright 2007 by Brooks Automation, Inc.
StatusStatus
What Brooks is currently doing
and what we will be doing next to bring our
products into compliance with legal
requirements and customer expectations
Copyright 2007 by Brooks Automation, Inc.
How are we doing this?How are we doing this?
The Green Initiatives Steering Committee was formed to: Analyze and document the external threats and opportunities emerging
from environmental regulations Develop and champion strategies necessary to sustain business in
light of these emerging issues. Create internal programs intended to meet or exceed our customer’s
expectations for environmental compliance Use the opportunities resulting from these initiatives to distinguish
Brooks as an environmentally friendly company. Working Groups:
This committee established Working Groups to address specific environmental topics such as China RoHS.
There are representatives from each Division on the Steering Committee and Working Groups.
These Divisional representatives then work within their Working Groups to develop and implement plans, with review and approval by the EHS Steering Committee and Senior Management.
Copyright 2007 by Brooks Automation, Inc.
How are we doing this?How are we doing this?
Green Initiatives Working Groups: RoHS Marketing WG for all Divisions (TBD)
They will determine product status and roadmap, per the earlier slides
The Material Content WG through Global Sourcing interfaces with our suppliers to get the information we need in the form we need it.
Materials Declaration WG to work with IT to determine the tools needed to get the information from our suppliers into your ERPs
WEEE Registration WG is responsible for evaluating and implementing registration for certain products in EU member states.
ISO 14001 WG is responsible for planning and execution of ISO certification.
Copyright 2007 by Brooks Automation, Inc.
Brooks Automation Environmental PolicyBrooks Automation
Environmental Policy
Development of a Environmental Policy Statement:
“Brooks Automation recognizes that the protection of the earth's environment is one of the most important issues for all mankind.
We are committed to protecting the environment for our Customers, Partners, Employees, Friends and Neighbors in the workplace and the community.
We are committed to complying with environmental laws and regulations that affect our products worldwide.”
Copyright 2007 by Brooks Automation, Inc.
Current Compliance Status by Region – European UnionCurrent Compliance Status by Region – European Union
RoHS – Position papers has been issued for TAD, GCS and VPD Products. Most products are out of scope as “Large Scale
Industrial Tools” Continue to monitor EU activity for any changes
in current legal requirements.
WEEE – Working Group has been formed to complete the Registration for some VPD products (GP & CTI) in selected EU states. GP products contain the EU WEEE symbol,
indicated “not to be disposed of as trash”
Copyright 2007 by Brooks Automation, Inc.
Current Compliance Status by Region - ChinaCurrent Compliance Status by Region - China
Phase 1 Brooks products shipping directly to China are compliant
with Phase 1 requirements: EPUP label, MCV Table and Spares Identification.
We continue to monitor status in China for problems or scope change
We will do a review in July to see if we need to change anything in our current process
Working with various industry groups (SEMI Asia RoHS WG, ASTM F40 (Materials Declaration and Testing)
Position Paper Issued (www.brooks.com)
Phase 2 Monitor progress in China
Copyright 2007 by Brooks Automation, Inc.
Current Compliance Status by Region - ChinaCurrent Compliance Status by Region - China
EPUP label: All EIP products to be used in China require a label indicating the ”Environmentally Protected Use Period”. This is a period in years during which the product will not degrade, causing pollution. For products containing no RoHS materials above the Maximum
Concentration Values (MCV):
For products containing one or more RoHS materials above the MCV:
These labels are applied on the product and on the packaging. Draft Guidance Document is out for review
Copyright 2007 by Brooks Automation, Inc.
Current Compliance Status by Region - ChinaCurrent Compliance Status by Region - China
The Divisions make their own business based decisions for product labeling: They can label all products they ship, or If they know which ones go to China then can only label those
If a Brooks product is being shipped to a customer not in China it may not be labeled (depends on above decision)
If the customer then ships it to China it is now a component of their system They have to label their end product We will provide content information to them upon request.
Copyright 2007 by Brooks Automation, Inc.
Current Compliance Status by Region - ChinaCurrent Compliance Status by Region - China
Spare parts, replacement parts, or parts for upgrade are out of scope of China RoHS based on the MII’s China RoHS FAQ
Stamps or labels may be added to the shipping documentation to indicate that the shipment contains Spares, Replacements or Upgrade parts:
这些是零配件 , 维修用零件 , 更换用零件THESE ARE SPARE PARTS, REPAIR
PARTS OR REPLACEMENT PARTS
•这些零件用于设备升级THESE PARTS ARE TO UPGRADE
AN EXISTING INSTALLATION
Copyright 2007 by Brooks Automation, Inc.
Current Compliance Status by Region - ChinaCurrent Compliance Status by Region - China
A table (in Mandarin) is added to the User Documentation. Brooks declares presence of all 6 RoHS substances,
unless we have sufficient evidence that these substances are not present.
The table includes the top level product and one level below.
铅(Pb) 汞(Hg) 镉(Cd)六价铬
(Cr(VI ))多溴联苯
(PBB)多溴二苯醚
(PBDE)
真空机器手包括: MagnaTran® 7 vacuum robot i ncl udes: X X X X X X
机器手驱动本体 Robot dri ve body X X X X X X
机器手臂组合 Arm assembl y X X X X X X
机器手终端受动器组合 End eff ector assembl y X X X X X X
操作包 Operati ng package X X X X X X
O:表示该有毒有害物质在该部件所有均匀材料中的含量均在SJ / T11363-2006规定的限量要求以下X:表示该有毒有害物质至少在该部件的某一均匀材料中的含量超出SJ / T11363-2006规定的限量要求。
部件名称有毒有害物质或元素
表1 有毒有害物质或元素名称及含量标识格式
Copyright 2007 by Brooks Automation, Inc.
Current Compliance Status by Region - Japan Current Compliance Status by Region - Japan
We remain “legally” out of scope with current Japanese legislation
Customer driven Green Initiatives programs are requesting: RoHS/JIG-101 product compliance or roadmap A plan to achieve ISO 14001 certification Demonstration of corporate social responsibility.
Copyright 2007 by Brooks Automation, Inc.
Current Compliance Status by Region - KoreaCurrent Compliance Status by Region - Korea
Act for Resource Recycling of Electrical and Electronic Equipment and Vehicles Legislation released in early April, 2007 Translation available at
http://www.kece.eu/data/Korea_RoHS_ELV_April_2007_EcoFrontier.pdf *
Supporting legislation has not been released yet Korea RoHS begins on January 1, 2008 Scope covers:
Electrical and Electronic Equipment - equipment or device (including components and parts thereto) operated by electric currents or electromagnetic fields.
Vehicle - means an vehicle (including components and parts thereto) as provided in Article 2, Section 1 of the Automobile Management Act.
*Courtesy of Eco-Frontier
Copyright 2007 by Brooks Automation, Inc.
Current Compliance Status by Region - KoreaCurrent Compliance Status by Region - Korea
Definitions: Electrical and Electronic Equipment -
equipment or device (including components and parts thereto) operated by electric currents or electromagnetic fields.
Vehicle - means an vehicle (including components and parts thereto)
Copyright 2007 by Brooks Automation, Inc.
Current Compliance Status by Region - KoreaCurrent Compliance Status by Region - Korea
Article 9 (Restriction on the Use of Hazardous Substances and Concentration Limits) Among electrical and electronic equipment or vehicles which
generates high volume of waste after use, any person who manufactures or imports electrical and electronic equipment prescribed by the Presidential Decree (hereinafter, producers or importers of electrical and electronic equipment) and who manufactures or imports vehicles prescribed by the Presidential Decree (hereinafter, manufacturers or importers of vehicles) shall comply with the concentration limits of such hazardous substances as heavy metals and flame retardants, which are stipulated by the Presidential Decree and have high potential of environmental pollution, so as to promote recycling of electrical and electronic equipment and vehicles. Provided that this shall not be applicable in cases that the elimination of hazardous substance is extremely difficult due to special characteristic of products concerned or there is no substitute, as prescribed by the Presidential Decree, and in cases of research and development or export of products.
Copyright 2007 by Brooks Automation, Inc.
Current Compliance Status by Region – United StatesCurrent Compliance Status by Region – United States
State legislation is aimed at the consumer market, not at business to business – for now
Primary focus is on lead and mercury Some states limit use of certain
substances, but most US State legislation is concerned with recycling
One information source for US State legislation is the Northwest Product Stewardship Council (www.productstewardship.net)
Copyright 2007 by Brooks Automation, Inc.
US Legislation by State – Enacted and/or PendingUS Legislation by State – Enacted and/or Pending
California Connecticut Hawaii Illinois Iowa Louisiana Maine Maryland Massachusetts Minnesota Nebraska
New Hampshire New Jersey New York State New York City North Carolina Pennsylvania South Carolina Rhode Island Utah Vermont Washington
Copyright 2007 by Brooks Automation, Inc.
Next StepsNext Steps
Let’s talk about what needs to be done
to achieve legal compliance
and customer satisfaction
Copyright 2007 by Brooks Automation, Inc.
Legacy ProductsLegacy Products
Marketing must determine the future status of legacy products Will or are they being sold in Japan, China, etc.? Will they be become EOL in a reasonable time? Is there a product to replace them?
Question to ask before determining material content For specific products or for specific customers? Do you charge a NRE?
Need to provide the customer with a plan and milestones We will or will not get the information for the specific product Do you only report it or do you bring the product into compliance? Who will pay for it?
Copyright 2007 by Brooks Automation, Inc.
New Product DevelopmentNew Product Development
RoHS compliance must be in the product specification for all new products
Redesigned products should fall into this category as well
Do you include JIG-101 information as part of the requirements?
Copyright 2007 by Brooks Automation, Inc.
What do you need to know and when do you need to know it?What do you need to know and when do you need to know it?
Material Content & Declarations For JIG-101, China Phase 2, possibly EU RoHS, and other
pending legislation you will need to determine the material content in your products
Expect to get only one chance with your suppliers You need to determine what information you need and what format
you want it in. i.e Only RoHS substances? Should you include JIG-101 Table A and Table B? Some other combination? IPC format or other Time line for this information
Copyright 2007 by Brooks Automation, Inc.
Everyone has a roleEveryone has a role
Operations need to evaluate RoHS compliant tools (solder, coatings, etc.) and processes
Sourcing will be asked to find RoHS compliant alternate components Engineering will evaluate the alternate components and test the
form, fit, function Quality will assure the reliability, safety, and product performance are
maintained and verify processes. Documentation Control needs to decide how to identify compliant
components. Marketing, when confronted with the cost of bringing legacy products
into compliance, has to consider end of life vs. redesign options.
Copyright 2007 by Brooks Automation, Inc.
And then…And then…
If you do your homework and implement correctly you will be ready for new environmental legislation.
It will take planning and a few years to get it all done.
Create, Implement and Maintain processes and prepare for the next environmental opportunities.
Copyright 2007 by Brooks Automation, Inc.
SummarySummary
RoHS is NOT going away
RoHS will impact all more and more products
We all have a role in obtaining and maintaining
RoHS Compliance.
Copyright 2007 by Brooks Automation, Inc.
And now it’s your turnAnd now it’s your turn
Questions?
Thanks for your attention.