Reduction of Hazardous Substances (RoHS) ..................................
Reduction of Hazardous Substances (RoHS), an EU directive that is part of a
global push toward more environmentally sound manufacturing practices
and policies, restricts the use of six substances in new electrical and elec-
tronic equipment placed on the market after July 1, 2006. By making it illegal
for companies to manufacture products with more than 0.1 percent of lead,
mercury, cadmium, hexavalent chromium, polybrominated biphenyls (PBB),
and polybrominated diphenyl ether (PBDE), RoHS aims to reduce pollution
and prevent human health problems. China, Japan, and all EU countries are
bound by RoHS.Evidence of compliance with RoHS needs to be provided only if an enforcement
authority asks for it. Failure of an organization to comply with RoHS can result
in serious penalties (including heavy fines and jail time), not to mention a black
eye for your reputation. When requested, you must provide documentation of
compliance to the governing bodies through materials declarations or analysis.
Some medical devices and military equipment that contain lead are exempt
from RoHS regulation.234 Part III: Going Green
One approach to REACH: Dow Corning
Dow Corning, a manufacturer of silicones and
polycrystalline silicon, is one of numerous com-
panies in the chemical industry that sees the full
scope of implications posed by REACH and is
taking active steps to address them all on every
front, including those to ensure sustainable
development and improve the levels of protec-
tion to human health and the environment.
Preparing internally for SIEF and consortia par-
ticipation, as well as for the registration of
nearly 100 Silicon-based substances and other
raw materials, filling gaps in data needed for
registration dossiers, updating compliance doc-
umentation, and managing an extensive IT port-
folio are only a few of the things Dow Corning is
doing to ensure that their company is still viable
under REACH.Their business-centric approach also entails
conducting product-line REACH workshops, edu-
cating professionals about REACH, highlightingissues specific to products lines, mining data,
evaluating entire product portfolios, determining
the volumes of substances manufactured and
imported into Europe, and assessing the impact
of REACH on sales and profits. In addition, to
guarantee communication requirements both up
and down the supply chain, the company is
engaging in comprehensive dialogues with its
suppliers, customers, and distributors. The
immediate effort includes identifying a REACH
contact person at each company and establish-
ing solid REACH messaging.
Finally, the company’s concern with future
directions is manifested in their ongoing exam-
ination of the various business and investment
decisions that will be driven by REACH to refor-
mulate and requalify their product lines.