THE CHALLENGE

For many electronics manufacturers, environmentally restricted substance (ERS) management is at the top of the list of environmental design objectives because of significant regulatory and marketing concerns. ERS requirements can be split into two basic categories: requirements applicable to product marketing and requirements related to disposition. This case study discusses the Environmental Product Design (EPD) Database, a software tool created to facilitate the collection, management, and application of product environmental data from suppliers and product engineers.

Requirements Applicable to Product Marketing

Numerous international laws and regulations govern how restricted substances can be used in products. One example of such a requirement is the German Prohibition of Chemicals Ordinance, which bans the sale of products in Germany if the ordinance�s limitations are not observed. The ordinance restriction on dioxins and furans has impacted electronics manufacturers worldwide, threatening lost market access that speaks directly to each company�s bottom line. Certain halogenated organic substances used as flame retardants in plastic resins such as integrated circuit molding compounds (which may contain trace amounts of dioxins and furans or may release these compounds when incinerated) have been targeted by the German ordinance as well as become the target of regulations and studies in several other European countries. This has resulted in a curtailing of the use of these materials, as international customers and suppliers modify product designs to meet and exceed statutory requirements.

Manufacturers wishing to use "environmental labeling" as a positive differentiator for their products are also subject to substance restrictions. One example is the German "Blue Angel" label for computers and printers, which includes concentration restrictions on substances such as heavy metals, flame retardants, and connector compounds. The high level of market recognition associated with this label among German consumers makes it very desirable for global manufacturers.

These examples illustrate practical differences in how international substance restrictions work. While the German restriction prescribes specific limitations on how certain substances may be used, the labeling scheme is different in each case, since labeling requirements are "voluntary" and ordinance restrictions are not (although labeling is becoming expected as a condition of doing business in certain markets). Regardless of these differences, each type of restriction must be considered early in sourcing discussions with suppliers, so as to minimize potential increases in cost and time to market that could result from last-minute changes.

Requirements Applicable to Product Disposition

Both state and federal hazardous waste regulations in the United States restrict disposal of waste electronic equipment if the equipment exhibits a hazardous characteristic such as toxicity (determined by leachate testing). U.S.-based manufacturers, which have been subject to state and federal hazardous waste regulations for many years, have significant experience in complying with these requirements but less experience in designing products to minimize regulated substance content and avoid hazardous waste generation altogether. The design challenge is increased when products are sold internationally and will be subject to the disposal restrictions of the jurisdiction in which they reach their end of life.

Once applicable disposal requirements are identified and understood, designing products so that they will not be characterized as hazardous wastes at the end of their life is still challenging. For example, the leachate tests used in U.S. hazardous waste classification do not directly correlate to concentration or weight of a restricted substance in the component. Consider the difference between a component with a lead coating and one that is an alloy of lead and another metal. The coated part is more likely to be classified as hazardous waste because it has more surface area in contact with the weak acid solution used in the leachate test, and the lead alloy is likely to be more chemically stable and resistant to leaching.

Mandatory product take-back schemes, such as those that will be enacted by European Union (EU) member states in compliance with the forthcoming EU Waste Electronics Directive (WEEE Directive), are expected to have a significant impact on how the electronics industry manages restricted material use in products. The WEEE Directive, currently in draft form, will require manufacturers to take back products from end users at the end of the product�s useful life and manage the product in an environmentally responsible manner. Furthermore, the directive is expected to require the phaseout of materials, such as lead and mercury, from electronic products. This directive is expected to have a significant bottom-line impact and will require close cooperation between manufacturers and suppliers to meet both take-back and substance phaseout requirements. Product take-back legislation is already effective in several EU member states concerned with increasing volumes of information technology and electronic equipment going to landfills.

These requirements and associated industry-based product stewardship efforts are shifting the focus of product disposition from proper disposal to designing products so they will be easily recyclable. Improper restricted substance use can hinder recyclability.

THE SOLUTION

Solutions involve development of a product environmental data base and a systematic approach to managing restricted substances.

Data Base Development

Quantum Corporation, Texas Instruments, and Lucent Technologies have joined, in association with Environmental and Occupational Risk Management (EORM), to create the Environmental Product Design Database (EPD Database� ) to manage product environmental data and associated international regulations. The goal of the EPD Database was to satisfy the need for "one-stop shopping" for regulatory data and storage of component ERS content information. The data base is designed to replace paper-based systems for managing component-level data collected from engineering departments and suppliers.

Collecting component-level product information in a single database allows users, such as product designers, to identify potential regulatory restrictions on substances contained in a product. Awareness of potential substance use or disposal restrictions is important in predicting regulatory compliance and/or market access that can be achieved by a given product.

Microsoft Access� was selected as the relational data base platform of choice for this application to allow rapid and low cost development. This platform is also flexible enough to accept data in a number of different data formats. Approximately forty representatives from the intended user community at Texas Instruments and Quantum were recruited to participate in the beta test, including procurement, engineering, account management, quality, and information systems.

Systematic Approach to Restricted Substance Management

Quantum Corporation and other companies are successfully implementing the restricted material management system approach represented in the figure below. Note that this process is integrated with and runs concurrently during each product development cycle. The EPD Database is a key component of the overall management system.

Step One: Determine Substances of Concern			Restricted Substance Management System
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The first step is to generate a combined restricted material list for the product or proposed product with input from stakeholders, including product engineering and marketing representatives. The goal of this step should be to make the restricted material list as short as possible while meeting all applicable restricted material requirements. The following substeps can be employed to achieve this goal: Determine the target markets for the product. This knowledge will help the environmental engineer select only those requirements expected to apply to the product. For example, if the product is targeted for sale only in the United States, it may not be appropriate to design the product with a non-U.S. ecolabel in mind. It is prudent to adopt a conservative approach in requirement selection to prevent potential market-access limitations. Create a combined list from the applicable requirements. Review the list and eliminate substances that, based on product knowledge, are known not to be contained in product subcomponents. For example, substances such as asbestos may be eliminated from the lists of many electronics manufacturers.

Limiting the length of the list to only those requirements that apply to a product and substances that may reasonably be expected to be contained in a product is important. For a typical electronic product, the list may be reviewed by several teams of engineers and hundreds of suppliers, each of whom must certify compliance with the requirements (see step two). Although the first step may appear to be relatively straightforward, obtaining and reviewing all applicable international requirements can be a daunting task.

Step Two: Obtain Supplier Component Certifications

Once the restricted material list is created, suppliers of product subcomponents are queried to identify which if any of the listed substances are proposed for use. To encourage a timely and accurate response, the query should be administered by the procurement group and tied to the component qualification process. In other words, qualification is contingent on supplier data submittal. This also achieves integration of restricted material data collection with existing processes to minimize potential impact to product development.

The presence of a restricted material in a product component does not in itself dictate component unsuitability. Because the applicability of substance restrictions cannot always be determined with a "yes or no" analysis, an individual familiar with the regulations and restricted material uses previously approved by the company should be involved in this process. To facilitate review of supplier data and retain institutional knowledge, a data base of approved restricted material uses should be created and maintained.

Step Three: Perform Risk Assessment

In cases in which restricted material use is proposed and not preapproved, a business risk assessment should be performed. The risk assessment should be performed by an experienced environmental professional who has information on strategic business issues associated with the product, such as target markets and production volumes. Issues that may be included in a risk assessment for proposed restricted material use include:

• What is the total quantity of the proposed restricted material use in relation to how the substance is currently being used in other applications within the industry? Will the new use result in a significant increase in the total usage quantity of that substance?

• What is the relevant risk/receptor analysis; that is, will the restricted material be evaluated by weight or concentration, or is a leachate test more appropriate?

• What is the leachability/bioavailability of the restricted material in the proposed application? Is the substance homogenous throughout the component, or is it a surface coating that would be more readily leachable in a landfill environment?

• How will the product typically be managed at the end of its useful life? Will the product be reclaimed, as in a product take-back program, or is it likely that the product will be disposed of in a landfill? Can the product or components be recycled and/or reused in a future product?

A systematic approach to the risk assessment, based on a company�s business drivers, should be employed to create consistent, supportable recommendations. One example of a relevant business driver is market share. Market share may be affected if customers choose not to purchase the product because it contains a certain restricted material. Other drivers for the technology industry include competitive "time to market," market access, and cost, which would be affected, for example, if special regulatory permission were required to market the product containing the restricted material.

One approach that has been used successfully is based on Graedel and Allenby�s Abridged Life-Cycle Assessment methodology. In the case of restricted material assessment, this methodology is based on evaluating relevant impacts (e.g., market access) during different life-cycle stages associated with the material�s use (e.g., manufacturing and product distribution). Although the approach does not provide absolute measures of cost or risk, it can be a powerful tool for identifying relevant issues and determining the order of magnitude or relative risk in the short time periods available for product-related decisionmaking.

Step Four: Modify Design

The risk assessment results are reviewed with key decisionmakers for the product, including engineering and marketing representatives. These results must be considered as part of the overall business decision.

Once a decision has been made on whether a restricted material is approved for a specified use, the decision should be recorded in a readily retrievable fashion so that the institutional knowledge gained in the exercise will be preserved. This supports consistency in decisionmaking and prevents duplication of effort.

ERS Management Challenges

The risks of not adopting a systematic approach to ERS management are compelling. Without a coordinated effort, electronic component manufacturers will develop separate and disparate data collection and transfer mechanisms and suppliers will be forced to deal with multiple manual and electronic tracking systems. Time and money are currently being diverted from what should be the goal of supplier environmental efforts, that is, improving product environmental attributes to support market and regulatory needs. Tremendous efficiency may be garnered from suppliers and customers within an industry using the same system, such as the EPD Database.

Organized ERS data sharing between customers and suppliers through a mechanism such as a centralized data warehouse reduces the time and resources currently required for ERS management. Suppliers participating in such an effort provide data on commodities basic to the industry, such as standard electronic components and/or plastic resins. Direct access to the data is provided to authorized customers and suppliers through mechanisms established for this purpose (e.g., an Internet web site), reducing the cycle time and resources currently required to request and obtain such data. Undertaking such a project has been challenging, requiring issues to be addressed such as collecting data so that trade secret disclosure is prevented. The effort has necessitated substantial communication and education among customers and between customers and suppliers.

THE RESULTS

Implementation of the EPD Database and the associated restricted substance management system has had tangible benefits for Quantum. Specific examples include:

• Faster response to original equipment manufacturing (OEM) customer-restricted substance inquiries, which must be completed prior to product sale and shipment. In many cases, response times have been reduced from greater than six months for detailed product restricted substance data to less than one day.

• Avoidance of nonessential uses of restricted substances. One design change identified as a result of the system, for example, eliminated the use of several tons of lead from the product line, resulting in lower liability for the product at the end of its life.

Acknowledgments

The authors acknowledge the following individuals for contributing to the development of ideas and approaches represented in this article: Richard VanLandingham, Texas Instruments; Chuck Fraust, Lucent Technologies; and David Newman and Gina Durante, Environmental and Occupation Risk Management, Inc.

COMPANY INFORMATION

Founded in 1980, Quantum Corporation designs and manufactures storage products including hard drives, DLT tape systems, and solid state disk drives. The company is headquartered in Milpitas, California, USA, and has operations in the United States, Europe, and Asia, where the local headquarters is in Singapore. With approximately 6,300 employees worldwide, the company had sales in 1998 of $5.8 billion.

EORM was founded in 1990 to provide high-value, strategically oriented EHS consulting services to the high-technology industry. Today, with nearly 100 employees, five offices, and an international client base, EORM is an established leader in the application of EHS tools and strategies for the semiconductor, biotechnology, and other rapidly changing and competitive industries.

CONTACT INFORMATION

Quantum�s web site is http://www.quantum.com. Information on the EPD Database can be found on EORM�s web site at http://www.eorm.com/products /products.htm#EPD