China RoHS and beyond - interview with Underwriters Laboratories executive David C. Haataja

VentureOutsource.com caught up with Underwriters Laboratories’ David Haataja. Mr. Haataja is vice president and general manager for the company’s restricted substances compliance solutions. He is also vice president for the company’s North American consumer and medical operations. Below are transcripts from that discussion.

VO: What are your thoughts on China RoHS (Restriction of Hazardous Substances) as it compares to EU RoHS?

Haataja: These are just two of the many pieces of legislation enacted globally to curb the use of hazardous substances. China RoHS is more encompassing since virtually all electronic products sold in China must adhere to China RoHS. This includes companies with products that currently have exemptions in the EU such as medical equipment.

China RoHS regulation addresses the same substances; however, what constitutes compliance is quite different. Whereas EU RoHS follows a self-declaration approach, China is clearly going to a compulsory certification requirement. More, all indications so far are that testing and certification must be done by a Chinese operated lab and certifier. There is no clear indication of whether China will accept testing that has already been performed outside of China.

David C. Haataja Vice President & General Manager Restricted Substances Compliance Solutions Underwriters Laboratories

Standards for testing remain an issue as the international community has yet to publish a standard that is globally accepted. China appears to have adopted, with some changes, the recent work drafted by the Technical Committee of the International Electrotechnical Commission – IEC TC 111, on environmental standardization for electrical and electronic products and systems. We’ll have to wait and see how this turns out once the IEC is done with their standard.

VO: What do you feel are the top five concerns of North American executives regarding European Union (EU) RoHS, today?

Haataja: First and foremost is what constitutes compliance or, put another way, how much due diligence is enough? There are a multitude of the things you can due to satisfy yourself the restricted substances have been controlled, but since there is no definitive document or standard to follow, the question is left open as to how much is enough.

Second is the potential damage to the brand. For example, reliance on an attestation from suppliers that all components are compliant without providing data to support the attestation places a company on dangerous ground. One front-page news story could be devastating.

Third is trepidation about receiving a notice from an enforcement agency requesting technical documentation showing that the producer’s RoHS compliance assurance system is functioning and is effective. What will you send and how fast can you send it?

Fourth is cost and a level playing field. The cost of procuring compliant parts and maintaining that compliance is significant. For products where margins are thin this is especially important. If all producers are doing the same thing there isn’t a competitive edge, which brings us back to the first concern, how much is enough?

And lastly, what’s next in terms of environmental regulations? Designing for the environment is an imperative all executives should be concerned about. This involves so much more than electrical or electronic products and so much more than six substances. Various states in the US, along with developed and developing countries across the globe, are either actively pursuing regulations or enacting regulations. It is only a matter of time until all products and producers will be scrutinized for the impact they have on the environment.

VO: What should company executives be doing to help improve their chances of locating RoHS-compliant suppliers and vendors for their supply chains / products?

Haataja: They need to satisfy themselves their company is using reliable databases of information that declare RoHS compliance with some form of support for their declaration. Materials declarations by themselves are not good enough.

Verify and validate. Implement a surveillance system for suppliers at their location. This should include random testing checks on product materials and checks on the supplier’s process with emphasis on their quality management system.

A program for checking incoming material / components using XRF (X-ray Fluorescence Spectroscopy) screening can be helpful as long as there is a clear understanding of the limitations of XRF screening. XRF does not replace the need for analytical testing for those material / components that are high risk.

Last, learning and keeping data on suppliers and components to develop ‘risk profiles’ will enable executives to focus their attention on the highest risk suppliers and components in their supplier base.

VO: What are the top three (3) challenges you see companies facing in terms of monitoring and documenting RoHS compliance?

Haataja: First and foremost is the lack of a standard for what constitutes compliance.

Next is the sheer size of the problem. Hundreds of parts from thousands of suppliers are not uncommon. You really need a management system in place. Relying on an agreement with your tier 1 suppliers to give you compliant product is risky.

It’s your company’s name on the product not theirs. The entire supply chain needs attention from the bottom where raw materials are produced to the sub-assemblers and on through final production. The challenge is obtaining confidence the substances are under control.

Keeping the information fresh is difficult. Part number changes alone constitute a major problem. This is especially true now since suppliers are working to sell compliant parts and are changing part numbers to differentiate parts. Companies will need a robust information management system that is continually updated to show they are actively managing ongoing compliance.

VO: What role does Underwriters Laboratories play in helping companies along the path to RoHS compliance?

Haataja: It’s all about confidence; helping our customers confidently declare their product are compliant. UL, as the leader in testing and certification, has worked closely with customers to develop solutions tailored to meet their needs at all tiers in their industries.

Beginning with the regulations and requirements, our UL University offers online and in-class programs targeted to specific customers’ needs. We also offer customers consultative support to develop a compliance strategy and a road map that fits their specific needs. Auditing suppliers is one of UL’s many strengths with field services staff around the globe.

Customers can select one of our advanced analytical labs to assist with testing their products. They can also engage us for an evaluation that leads to using our UL RoHS product mark, which proves particularly valuable for producers of base-materials and components. Additionally, we offer management system certification geared toward RoHS compliance.

The UL RoHS Management System Certification has shown effectiveness among OEMs and complex components manufacturers. Our solutions are flexible and can be used together, or separately, to address the needs of the customer.

VO: Where do you feel environmental compliance for the technology sector (on a global scale) is headed and which particular legislative developments already in place in the USA, or currently taking shape, will help to move things in this direction?

Haataja: Designing for the environment is the new face of corporate social responsibility. Companies that realize this are already differentiating themselves and branding themselves around being green. Given the attention the environment is getting from people around the world, it comes as no surprise governments are reacting with environmental regulations. We will be seeing more, not less.

We can expect to see recycling and restricted substances regulations being bolstered by environmentally conscience design and control of the fundamental chemicals used throughout the globe. In Europe, the Energy Using Products (EUP) and REACH directives are already moving toward this.

Next on the horizon will be the migration of these requirements to other industries outside of electronics and high-tech. For instance, legislation has been proposed to limit use of brominated flame retardants in mattresses.

Although the USA is very much behind the rest of the developed world in environmental regulatory action, the USA is catching up. The question in the USA is whether the federal government will step in with preemptive legislation or, will it be left to the individual states to do as they see fit.

Harmonization across the states, and across the world, is highly desirable in that it frees companies’ brainpower to design and build environmentally-friendly products rather than spend valuable time just trying to keep up with all of the different rules.

VO: Please share with our readers a few things about you many people do not know.

Haataja: Gladly. Outside of the workplace you’re likely to find me in the outdoors running, roller skating, hiking, hunting, fishing or golfing. I’ve never been much of a fan of the big cities but I have worked in big cities my entire life.

After living for 6+ years in South America, my wife and I have acquired a love for Latin culture. We are both inspired by the Latin culture’s work and life balance and we adore its food, music and dance.

We also have a taste for travel to off-the-beaten-path places. Most recently, this included penguin rookeries in Antarctica and a trip to the North Pole on a Russian nuclear icebreaker where we had a chance to watch polar bears and take a (very quick) swim at the pole.

As an added benefit, it was quite stunning and mind-opening to see some of the effects of global warming first hand.

VO: Thank you, David.

Haataja: You’re welcome. Thank you.