If you are like me, you may be having trouble wrapping your mind around the EU's comprehensive REACH program. For the benefit of those unfamiliar with this term, REACH stands for Registration, Evaluation, and Authorization of Chemicals.
The purpose of REACH is to identify and restrict certain harmful chemicals used in industry, which can be classified as substances, mixtures, or articles manufactured or sold into the EU. The REACH program is being overseen by the European Chemicals Agency (ECHA) and is a long overdue, urgently needed, and excellently contrived initiative.
I have been reading articles, attending numerous Webinars, watching countless videos, talking to key REACH involved individuals, camping out at the ECHA Website, and trying to grasp the scope of the current and potential impact of REACH on the electronics industry. In my last article, I listed both RoHS and REACH compliance as requirements for a part to be included on the Preferred Parts List (PPL), especially for those firms that are marketing into the REACH countries. (See: Developing the Preferred Parts List.)
But, here is what all this reminds me of. I believe it is called the “God Paradox.” The question, as usually posed, is: “Can God create an object so heavy that even He can't lift it?” My answer to that is easy. “If God, with all of His infinite capabilities, chose a moment in time when He decided to construct an object He couldn't lift at that particular moment in time, then the answer would be 'Yes,' ” But I would also continue my response by saying, “Not for long,” because in the next moment, being Master of All Things where nothing is impossible to Him by definition, He could remove the self-imposed restriction and toss the object like a paperweight far out into the Universe… and beyond.
Let me ask another question. “Can man, with all of his finite capabilities, create a program that would be so expensive, so expansive, so bureaucratic, so time consuming, so difficult, so industry cramping, that even he, man, couldn't manage it?” My answer, after familiarizing myself with the REACH initiative, is a resounding “yes.”
Don't misunderstand me please. The Registration, Evaluation, and Authorization of certain Chemicals classified as substances of very high concern (SVHC), is a very good and necessary program, but it has been introduced late in the game, and consequently, it is like trying to stuff the feathers that have been scattered by the wind, back into the pillows from whence they came. Where are these feathers now? Some have come to rest in toys, packaging, pharmaceuticals, cosmetics, food, clothing, tools, appliances, household cleaning products, computer hardware, and all manner of products we use every single day.
Let me cite from a Wikipedia article I read identifying just one of these “feathers,” DEHP. This is added to plastics to make them more flexible. DEHP phthalates were banned in the EU in 1999. China responded by facilitating two toy production lines. One line was introduced for the EU producing the same toys without DEHP, and another line, processing with DEHP, was maintained for the US and other countries.
The US didn't ban DEHP in toys, baby powder, shampoo, teething rings, and other products targeted for the infant to early childhood market sector until Feb. 2009 — 10 years after the EU determined DEHP posed a health hazard. Even today, DEHP is in common use for all other markets in the United States. Here's more from the Wikipedia article:
- Phthalates are used in a large variety of products, from enteric coatings of pharmaceutical pills and nutritional supplements to viscosity control agents, gelling agents, film formers, stabilizers, dispersants, lubricants, binders, emulsifying agents, and suspending agents. End-applications include adhesives and glues, agricultural adjuvant, building materials, personal-care products, medical devices, detergents and surfactants, packaging, children's toys, modeling clay, waxes, paints, printing inks and coatings, pharmaceuticals, food products, and textiles.
Phthalates are also frequently used in soft plastic fishing lures, caulk, paint pigments, and sex toys made of so-called “jelly rubber”. Phthalates are used in a variety of household applications such as shower curtains, vinyl upholstery, adhesives, floor tiles, food containers and wrappers, and cleaning materials. Personal-care items containing phthalates include perfume, eye shadow, moisturizer, nail polish, liquid soap, and hair spray.
They are also found in modern electronics and medical applications such as catheters and blood transfusion devices. The most widely used phthalates are the di-2-ethyl hexyl phthalate (DEHP), and diisodecyl phthalate (DIDP). DEHP is the dominant plasticizer used in PVC due to its low cost. Benzylbutylphthalate (BBP) is used in the manufacture of foamed PVC, which is mostly used as a flooring material. Phthalates with small R and R' groups are used as solvents in perfumes and pesticides.
The Wikipedia article is an eye-opener and is on just one chemical covered by Annex XIV of the REACH program. Consider the effort and cost implications to companies that currently include phthalates in their major product lines. Is it any wonder that corporations are reluctant to volunteer to take it out or substitute other processes or substances to achieve the same plasticized products? (It is interesting to note that both camphor and castor oil were used before the introduction of DEHP.)
Whatever the EU does in the interest of human safety concerns, count on the US to lag by several years. When you read the Wikipedia article, you see the number of human maladies brought on by extensive exposure to DEHP. Now add just one more substance on the SVHC list like cobalt (and its related compounds and various uses), and again you will see major industry sectors severely impacted.
There are now 73 SVHC items on the latest REACH list. Every company that uses any of these substances in excess of 0.1 percent by product weight is subject to major remediation costs and mountains of paperwork to obtain REACH compliance mandates. Millions — no, billions — of dollars are involved. This might include millions of animals used in testing for chemicals evaluation and analysis and probably billions of documents proving compliance.
The SVHC list gets significant additions about every six to nine months. The added substances are being pulled from a candidate list of thousands upon thousands of chemicals. Effectively, the potential size of the final SVHC list is almost limitless. It boggles the mind as to how this program will ever be managed effectively if a producer constantly has to change or adjust products to comply with the latest SVHC requirement. What may be OK today may be banned tomorrow.
So, how do we even begin to resolve the multitude of REACH implementation and management problems? The ability to retrieve the most accurate, thorough, and timely information is certainly one key. In this article I have opened Pandora's Box. In subsequent articles, I will be introducing tools and resources that will provide some means for taking control of these many “evils” now in the wind.
The articles will be targeted to individuals responsible for or impacted by REACH compliance concerns within their respective organizations. I encourage everyone to add to the practical knowledge base for these REACH articles by responding to every posting. Please feel free to offer any experience, guidance, or creative ideas you may have addressing these REACH discussions.