|
|
 |
IECQ HSPM QC 080000 – A PRAGMATIC WAY TO CONTROL YOUR HAZARDOUS SUBSTANCES FREE PRODUCTION
Chris Yau
Global IECQ HSPM Product Manager
Ever since the European Council announced the Restriction of Certain Hazardous Substances in Electrical and Electronic Equipment (RoHS) Directive in 2002, which came into effect on 1 July 2006, many buyers have devised various ways to prevent the designated hazardous substances (HS) to enter into the final products. Some are passive (e.g. requesting the suppliers to sign the Declaration of Conformances, DoC), some are active (e.g. auditing the suppliers’ production site). Experience from Asia, especially China, is that passive controls of suppliers are generally not sufficient. Here are the experiences we have learned from the several hundred factories SGS have audited in the past 2-3 years in China and Taiwan:
- The list of banned substances passed down from the buyers to suppliers was often not clearly read, possibly due to language difficulties and its highly technical nature. As a result, DoC was often signed without factual verification of the components’ HS content. We have seen a DoC that said the supplier’s solder wire was lead-free while the wire had actually 37% lead. Another PVC conduit factory claimed that their products were PVC-free! This experience taught us that relying on DoC alone was not the proven way to control HS from the final products. A more pragmatic way is needed.
- Often times a supplier has several EU and American customers, and each of them demanded similar on-site HS audit to the same supplier using similar checklist. Because buyers normally wouldn’t accept the audit results from another buyer, suppliers often had to be audited multiple times – increasing their financial burden and interrupting the production. It was clear that if a common standard on HS management had existed, like ISO 9001 did for quality management, suppliers could have been audited against that standard and hence be answerable to all buyers.
- Many factories concentrated on ensuring that supplied components were HS-free (HSF), while ignoring that fact that production processes have equal, if not higher, chances to contaminate the final products. There was a factory that had lead and lead-free production lines in the same workshop, but both lines share the same re-work stations. Another factory had an inattentive warehouse storekeeper who mistakenly dispatched HS materials to the HSF lines. This experience indicated that process-approach to all processes of the production, not just supplier control, was required to ensure HSF in the final products.
A Pragmatic Way to Control HS
It is evident from the above experiences that although a DoC is useful on claiming the lost and compensation from the suppliers after the products are found non-compliance, a DoC does not guarantee components are HSF. A more pragmatic and proactive way to manage HS is necessary. This management not only needs to include suppliers, but to include other aspects of the production processes, from contract reviews, product design, purchasing, warehouses, production, to product dispatch as well. Also from the above experience, the management also needs to meet an internationally-accepted standard on HS controls so that customers would have confidence to the control’s adequacy and comprehensiveness. The IECQ HSPM QC 080000 standard meets all of these requirements.
IECQ HSPM QC 080000:2005
IEC introduced the IECQ HSPM 080000 standard for Hazardous Substance Process Management (HSPM) in November 2005. The standard is a framework for the management of HS control and defines the requirements for establishing processes that identify and control any introduction of HS into electronic products. QC 080000 was written using ISO 9001:2000 as the framework. HS-specific controls were added to the framework to form a complete standard. The structure and clause numbering is almost identical to that of ISO 9001, allowing an organization to integrate QC 080000 requirements into its QMS with ease. In fact, throughout the standard, ISO 9001 requirements are frequently referred to from QC 080000.
The acceptance of QC 080000 by the worldwide E&E sector can be seen from that fact that it is the 14th most popular standard sold by IEC. The number of certificates issued in the first quarter of 2007 surpassed the number of certificates issued in the entire year of 2006. It has perhaps the fastest adoption rate among all certification standards (418 certificates as of 1 Jul 2007, 19 months after its releases). Early adopters of this standard includes Giga-byte, a Taiwan consumer electronics manufacturer; GD Midea, the world’s largest microwave OEM and brand manufacturer; SMIC, largest semiconductor manufacturer in China, and Fook Tin Technologies, the world’s largest bathroom and medical scales manufacturer.
QC 080000 certification process
The QC 080000 certification process is similar to an ISO 9001 certification. It consists of a comprehensive document review and a final on-site assessment. Because of QC 080000’s reliance on the ISO 9001 framework, an established quality management system based on ISO 9001:2000 is required prior to QC 080000 certification. If the quality management system is not yet registered, extra time will be included in the proposal to assess the QMS as well.
QC 080000 certification does not replace lab testing. The two complements each other. Lab test results provide the scientific proof an organization needs to demonstrate the submitted sample complies with the HS requirements. QC 080000 certification provides the management proof an organization needs to demonstrate the processes and controls established would produce products that comply with the HS requirements.
More HS Regulations are Coming
The EU RoHS Directive certainly would not be the last legislation of this sort. Many industrial countries have established their own RoHS-alike legislation.
China
China announced its version of the regulation (Management Methods for Controlling Pollution by Electronic Information Products, nicknamed “China RoHS”) which came into effect on 1 Mar 2007. The China RoHS controls the same HS as the EU RoHS Directive plus additional marking requirements. Considering the size of the Chinese markets compared to that of EU, the impact of China RoHS to American buyers is similar to, if not bigger, than that of the RoHS Directive.
Japan
Effective 1 Jul 2006, televisions, refrigerators, washing machines, air conditioner, electric ovens, drying machines and personal computers sold in Japan must comply with JIS C 0950:2005, which controls the same six HS as well as special labeling requirements.
Korea
On 2 April 2007, the Act for Resource Recycling of Electrical and Electronic Equipment and Vehicles was adopted into law by the National Assembly of Korea. The regulation has provisions on HS restrictions as well as recycling and design requirements. The Act will come into effect on 1 Jan 2008.
US
On 24 Jan 2007, President Bush signed the GSA Executive Order 13423, which requires all federal government agencies to purchase electrical and electronic equipment which meets 95% of the EPEAT criteria (http://www.epeat.net/Criteria.aspx). The first requirement of the EPEAT criteria is “compliance with EU RoHS Directive”.
Why SGS?
SGS has the biggest IECQ HSPM audit team among certification bodies. It has over 50% market share in QC 080000 assessments as well as issuing the first QC 080000 certificate in China, and is authorized to audit against EU RoHS, China RoHS, the EU Packaging Directive (94/62/EC) and the Battery Directive (91/157/EC). Our people contributed to the translation of QC 080000 into Chinese (which later became the official Chinese version of QC 080000). SGS has 24 accredited laboratories worldwide concentrating on RoHS testing.
Brief Biography
Mr Chris Yau has involved in RoHS-related audits and trainings since 2005. He has audited over 50 organizations on IECQ HSPM and other hazardous substances requirements. He is an IECQ-approved HSPM assessor, an IECQ-recognized HSPM trainer, and is a registered QMS and EMS lead assessor. He is currently the Global Product Manager for IECQ HSPM in SGS.
|
