Meeting Summary
Coated Wire and Cable Industry
Lead Alternatives and Testing for Restricted Substances
March 23, 2004 Bose Corporation Framingham, MASUMMARY
On March 23, 2004, a group of approximately 70 representatives from the wire and cable supply chain gathered to discuss new research and technology options for lead alternatives and testing for restricted substances. These restrictions and the need for testing are due to increasingly stringent international materials restrictions. These include the recently approved EU Directive on the Waste Electronic and Electrical Equipment (WEEE Directive) and its companion Restriction of Hazardous Substances Directive (RoHS), the EU End-of-Life-Vehicle (ELV) Directive, as well as increasing focus in the US on lead, PBDEs and other brominated flame retardants, antimony and other halogenated materials. This was the fifth in a series of meetings for the wire and cable supply chain in Massachusetts sponsored by TURI. Participants in the previous meetings expressed a strong interest in maintaining the dialogue and meeting periodically for updates on legislative issues and technical developments in alternatives to lead, brominated flame-retardants and other materials of concern contained in wire and cable products. At this meeting, after an update on the legislative issues, the participants heard about alternatives to lead stabilizers, testing for the presence of restricted substances and how a number of companies are facing the challenges of these upcoming restrictions. The following is a brief summary of the meeting’s presentations and discussion.
Jack Bailey (Bose Corporation) welcomed us to the Bose facility and showed the group a virtual tour of the Bose Corporation. The video highlighted the technology research and development including the work on radios, car audio systems and reminded us that TECHNOLOGY IS FUN – TECHNOLOGY IS COOL!
Liz Harriman (TURI) started the supply chain workgroup in 2001 to assist MA wire and cable firms facing international materials restrictions enacted beginning in 2004. TURI is working to keep MA industries competitive in the changing marketplace. TURI has hosted previous other workshops including ones on Proposition 65, Lead Stabilizers, Fire Safety and Flame Retardants, Customer Requirements and Materials Declarations, as well as presentations on emerging research and materials in the industry. Ms. Harriman then reviewed the day’s agenda.
Tim Greiner (Greiner Environmental) updated us on material restrictions, RoHS and California Proposition 65. He discussed the most recent developments with the restrictions from Europe and what has developed in US. The WEEE directive includes treatment according to minimum requirements as well as specific targets for recovery and reuse for a specific list of products (including large and small household appliances and telecommunications equipment). The WEEE was adopted in December of 2002 and a date of December 2006 is set for the collection and financing targets to be attained.
The EU RoHS directive looks at specific materials in the European Union including lead, mercury, cadmium, and hexavalent chromium, brominated flame retardants (including PBBs and PBDEs). The RoHS directive phases out the use of all PBDEs, but sets a priority for reviewing deca-BDE at the conclusion of a risk assessment study, to determine if an exemption is appropriate. The fate of deca-BDE is uncertain, with the EU expressing concern over possible debromination of deca to lower-brominated congeners and possible toxicity issues. New studies (an EST journal article was cited) cast further doubt on the toxicity profile of deca. This will be re-examined in the fall when more information is expected.
Susan Landry (Albemarle Corporation) offered that no risks from deca have been identified and additional testing will be done. Significant risks were not found for debromination and additional testing on development and neuro-toxological effects are being explored.
Ms. Landry also mentioned that there was some confusion about whether the default for deca BDE was to phase it out. Further exploration into this issue after the meeting showed that there was indeed a conflict between the text as approved by the Conciliation Committee on 8 November 2002 and the text published in the Official Journal of the European Union on 13 February 2003. TURI obtained an unofficial copy of a letter dated 29 March 2004, from Ms. Margot Walstrom to several European members of parliament acknowledging the conflict, and stating: ”As a result of the confusion caused by the existence of two separate, contradictory texts, my services have already made it clear to the Technical Adaptation Committee (TAC) that they consider that Deca-BDE is currently covered by the substance ban in Article 4(1) and they will take the appropriate steps to correct the error which has arisen over the text.”
The EU End of Life Vehicle Directive limits the use of hazardous substances in vehicles. These hazardous substances include lead, mercury, cadmium, and hexavalent chromium to be phased out by July 2003. Small levels are allowed in autos, and manufacturers need to track every bit of material in their products.
There are implementation concerns as we see these directives being put into force. The EU and some several member states such as the UK have held stakeholder consultations via surveys with stakeholders to assist in the process. One implementation issue is the definition of “put on the market” which is still unclear. While the meaning inside EU countries could be “manufactured after 7/30/06”, outside the EU countries there is still not firm definition. Further exploration into this issue after the meeting showed one possible definition of "put on the market" is that time in which a transfer of title takes place and not the date of manufacture, nor the date that the product clears customs. The EC is expected to provide greater clarification on this matter in 2004. Another definition discussed by Mr. Greiner is the de-minimums for RoHS substances. There was a EU consultation in May 2003 but no final decisions have been made.
Tim then discussed similar legislation outside of the EU. There has been legislation in China, California, Michigan, Washington, RI, and Maine. The various US state and national efforts being forwarded in legislatures across the country, makes us realize that these issues are not likely to go away.
Dave Kidoo (Alphagary Corporation) spoke about lead substitutes and the challenges for fire performance. He reminded the group that wire and cable materials have not been shown to pose an immediate or environmental threat. He then discussed lead alternatives including the mixed metal stabilizers barium/zinc and calcium/zinc complexes. With the help of TURI, alternatives better than lead based stabilizers have been achieved. Dave then raised the question, what is the definition of lead-free?” Is it zero lead, the detection limit for a certain test, is it less than 100 ppm, less than 300 ppm? Dave emphasized that the measured lead content in a material will depend on the test method used. Furthermore, it is difficult to guarantee extremely low levels of lead or no lead in PVC compounds because it is present as a contaminant in some other additives (e.g., antimony). He expressed the opinion that OEM’s were establishing inappropriate and illconsidered lead targets. He then reminded us that the global goals and objectives for wire and cable are to generate sound requirements as well as use guidance and regulation. Mr. Kiddoo then turned to fire safety. He told us that new fire safety technology for wire and cable significantly reduces smoke spread and fuel load. He added there is a technology gap when it cones to getting enhanced safety and transmission performance while dealing with environment concerns. Dave explained how forthcoming EU standards conform more to the US system for flame retardant requirements in wire and cable.
Dr. Joey Mead (University of Massachusetts Lowell, Plastics and Chemical Engineering Departments) spoke about the work being done in her lab on the development of non-lead stabilizers used in elastomers. It is necessary for wire and cable to have superior electrical properties as well as resistance to moisture and weather. Insulation materials for wire and cable include natural rubber, ethylene and propylene elastomers, and chlorinated polymers (PVC). Chlorinated polymers, and those that contain residual chlorides from catalysts (e.g., EPDM manufactured using Ziegler-Natta process) used in wire and cable require lead for stabilization. Dr. Mead’s research team has been investigating using an anion scavenger (hydrotalcite) with a co agent cure system as an alternative means of stabilization. They have also identified a metallocene catalyst that would eliminate the need for stabilization in EPDM resins.
Scott O’Connell (Dell Inc.) told us about Dell’s environmental programs that include complete coverage from the development of the system to the end of life of products. Since Dell’s development cycle is short, the environmental work needs to happen very early. Scott then discussed and updated us on the restricted substance legislation including EU RoHS, China RoHS and WEEE, and the U.S. States including California, Massachusetts, and Wisconsin. Dell’s restricted materials program includes goals to eliminate lead in external cable insulation by May 2004, to reduce the amount of lead per display and eliminate halogenated flameretardants in computer chassis plastic parts by the end of 2004. Scott reports that they are on track to meet these goals.
Dell’s list of banned or restricted substances includes cadmium, halogenated flame-retardants, lead (in paints, packaging, cables and connectors) and PVC (except for cables and interconnect parts). Substances under consideration for restriction (but not banned) include antimony, arsenic, beryllium, ethylene glycol ethers, and organic tin compounds. Dell is using these lists to collect information in anticipation of possible future restrictions. They are asking suppliers to provide a supplier declaration, with information on banned substances and substances under consideration.
Scott then shared Dell’s formal position statement on RoHS and brominated flame-retardants. Finally he discussed some emerging European legislation including Energy-using Products (EuP), Integrated Product Policy (IIPP) and the REACH Chemicals Policy. Lorraine Braunsdorf (Technor Apex) spoke about Technor Apex’s work on lead replacements, specifically the non-lead stabilized PVC wet electrical market. These replacements have now passed the U.L.’s elevated temperature water bath for 26 weeks, and they have checked resistance every few weeks without reduced resistance. Apex 80853-C is the 75 degree Celsius wet rated calcium/zinc stabilizer. Apex 80853-F is the 90 degree Celsius wet rated calcium/zinc stabilizer.
Kevin Nicolette (SGS Consumer Testing Services). SGS is a company that does consumertesting services and deals with regulatory compliance and industry standards. SGS is equipped to do RoHS testing in Asia.
Dr. Val Tramontano (Consultant to SGS) discussed the testing using state-of-the-art equipment that SGS does when asked to test a product for restricted substances. In order to sample cable and wire you need to sample the jacket, insulation, strain relief, copper wire, and the cable tie. Each part will be sampled and tested for the restricted limits of each banned substance. The analytical chemical testing for metals is done by ICP or UV-VIS and gas chromatography mass spec for organics. Dr. Tramontano closed by discussing additional methods that are used in sampling analysis.
Several representatives of SGS were present to answer questions from the group. Questions focused on sampling protocols, determining allowable limits for restricted substances and quick screening test equipment. Mr. Harry Marcoux pointed out that the limits shown in their presentation were examples taken from clients testing programs, and offered that most clients wanted to set a testing limit that was enough lower than the “legal” limit, to allow an adequate margin of safety. When asked about the accuracy of hand-held XRF, Mr. Marcoux said that SGS was in the process of evaluating it.
Joe Johnson (Microsoft Corporation) is in charge of the environmental regulatory compliance for consumer electronic products at Microsoft. His goal is to maintain and expand market access for Microsoft’s products. They have met compliance and customer requirements as well as market-driven initiatives including “design for environment” product attributes. Joe does the market assessment, product design, and product manufacturing compliance. Microsoft had an experience in 2000 with California Proposition 65 when the Mateel Environmental Justice Foundation brought suit for lead exposure in their products. Microsoft settled the case quickly and agreed to take lead out of cables. As a result they needed to do an exposure assessment to translate the exposure limits of 0.5 mg/day in Prop 65 into an allowable concentration of lead in the cable jacketing. After testing and negotiation, they agreed on a limit of 300 ppm lead.
Microsoft now has to ensure that their suppliers meet these material restrictions. They now test every lot of products to check for lead and cadmium. Cables have been key compliance risk for Microsoft and they have been testing since 2000. Microsoft uses a declaration and the supplier is required to sign that products are compliant. They also require disclosure of fire retardant materials.
They are now moving toward RoHS and WEEE compliance and fully lead free products. Microsoft is now facing how to achieve and certify compliance with RoHS. Microsoft has a supplier compliance plan that requires suppliers to provide a compliance risk assessment plan to manage compliance risks for each product. Their objective is to make sure that their suppliers are devoting adequate resources to managing their own supply chains and ensuring compliance. The rollout of Microsoft’s compliance plan is planned for mid 2004 with full compliance by suppliers in 2005 (a year ahead of the RoHS date).
Microsoft is currently using a portable XRF Unit as an easy way to test for RoHS substances. The XRF unit is a good screening tool but it also has significant limitations. Therefore, it is used in conjunction with more accurate analytical methods. In summary, Microsoft has made progress but stressed the need for regulators to provide clear definitions for terms such as “placed on the market” and homogeneous material, and provide clear guidance on RoHS test methods, WEEE separate treatment and information requirements.
Scott Fortier, (MA Office of Technology Assistance (OTA)). OTA, a sister agency of TURI, promotes toxic use reduction, environmental performance, as well as health and safety to maintain or improve the economic competitiveness of a company. OTA is a non-regulatory office of the Massachusetts Executive Office of Environmental Affairs that has helped companies in Massachusetts eliminate the use of millions of pounds of toxics and save millions of dollars.
OTA provides one-on-one technical assistance to Massachusetts’s facilities and has a staff with extensive experience in many different industry sectors. Due to state budget cuts, they have now re-focused their resources on PBTs and TURA High Priority Substance chemicals – especially lead.
Michael King (SelecTech Inc.) is a plastics recycler; they convert scrap plastic using a proprietary technology into high quality, low cost recycled plastic products. They use dirty pallet wrapping, old wire insulation, and old carpeting to make new products. SelecTech converts difficult plastics into finished products using a patented technology that is not product specific. Their product line includes planters, industrial flooring and traffic control (speed bumps and lane dividers). They are currently moving into flooring products. FreeStyle is a decorative flooring product (92% recycled PVC) that is designed to be heavy and does not require the use of adhesives.
Wire and cable scrap is less desirable because of the wide range of properties and the presence of lead and cadmium. There is such a range of materials even from one compounder; it is hard for them to get a consistent material.
They do not use any material with lead or other heavy metals. Desirable additives include antifungal agents, as well as fire and smoke resistant materials. Mr. King expressed interest in working directly with wire and cable extruders to secure lead-free PVC scrap as SelecTech’s sales of PVC flooring increases.
Kathy Hart (EPA) discussed the DfE (Design for the Environment) Program that encourages industry sectors to find Pollution Prevention (PP) opportunities. They create partnerships to assess and promote the use of cleaner, cost-effective products and technologies. They use flexible approaches such as
- Identifying the key pollution prevention opportunities in the industry.
- Evaluating and comparing the risk, performance, and cost tradeoffs of the alternatives.
- Disseminating this information to the entire industry community.
The EPA DfE program is interested in forming a partnership with the Wire and Cable supply chain. Ms. Hart explained that their approach is to decide on a focus area with a core group of industry participants, recruit industry representatives to form a technical workgroup, and proceed with a study to assist the industry sector in making decisions on processes and materials.
Maria Socolof (Center for Clean Products and Clean Technologies - University of Tennessee) has worked on the DfE projects doing Life Cycle Assessments; most recently for the lead free solder partnership. The life cycle concept is a cradle to grave perspective. According to Ms. Socolof, it is very important to define your scope before beginning the LCA. The first step is to begin the life cycle inventory by collecting all the data for the processes. Primary facility specific sources are best, secondary sources are used when necessary. Maria then shared preliminary results (not to be quoted or cited) from her lead free solder LCA . Finally, Maria shared possibilities for the wire and cable industry. An LCA allows for comparison of alternatives in all life cycle stages, identifies environmental tradeoffs, and identifies areas for improvement with each system examined.
Wrap-up The workshop concluded with a thank-you to Bose Corporation for their hospitality, as well as to all the speakers and participants. Following the workshop, an informal open meeting was held with the EPA DfE program to discuss possibilities for collaboration.