While all the economic turmoil in Europe is occurring especially in Greece, Portugal, Spain, Italy and Ireland, lawmakers are still tackling issues in other areas as they arise. This is happening in the health, safety and environmental realms as well. One of the newest initiatives is the update of what is known as Restriction of Hazardous Substances Directive, or RoHS. This one is now known as RoHS2. It was adopted on June 9.
If you’re manufacturing electrical or electronic products for sale in Europe, you need to be aware of the restrictions that have been imposed. The first RoHS directive affected several Nova Scotia companies and at least one of them changed its manufacturing practice to take advantage of the regulations adopted a few years ago. By voluntarily removing a restricted substance, namely lead, from their product ahead of the regulation, they were able to compete successfully in the new marketplace.
These new regulations deal with both possible new restricted substances and new categories of equipment. For examples, if you manufacture medical devices and monitoring and control instruments that contain these restricted substances, you need to pay attention as their import into Europe may be curtailed in the future. The dates of application of these regulations vary depending on the category and the substance, so you might have two or three years to change your manufacturing process or inputs into the process.
The EU is attempting to determine whether four substances, one of which is a fire retardant (HBCDD) and three of which are plasticizers (DEHP, BBP, DBP) present an unacceptable risk to human health and the environment. As you may be aware, some plasticizers and fire retardants have been a concern on this side of the Atlantic as well. Concerns have been raised about mutagenic and carcinogenic activity and their hormone disrupting potential.
If your products are using any of these types of chemicals, you might want to begin researching alternatives that can be substituted. Your chemical suppliers might be able to assist you and I’m certain the chemical manufacturers themselves have research underway into safer and more benign alternatives.
The EPA Green Chemistry program site in the U.S. may also be a helpful source of information. There are also some university-based research groups that might provide additional information such as the Toxics Use Reduction Institute at the University of Massachusetts.
With that in mind, a particularly interesting report entitled Safer by Design: Businesses can Replace Toxic Ingredients through Green Chemistry, published by Environment America, will be very educational. You can find it on the web at www.environmentamerica.org/reports/toxic-free-communities/stop-toxic-pollution/safer-by-design.
Ray Côté is a Senior Research Fellow with the Eco-Efficiency Centre and a retired professor with the School for Resource and Environmental Studies at Dalhousie University.