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IPC 2-18b – IPC 1752A Material Declarations Committee Meeting Rosemont, IL

IPC 2-18b – IPC 1752A Material Declarations Committee Meeting Rosemont, IL. September 30, 2014 8:00am - 5:00pm. Co-Chairs: Mark Frimann Aidan Turnbull. Agenda. Welcome/introductions Annual review process for solution providers Recap and results from 2014 review process

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IPC 2-18b – IPC 1752A Material Declarations Committee Meeting Rosemont, IL

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  1. IPC 2-18b – IPC 1752A Material DeclarationsCommittee MeetingRosemont, IL September 30, 2014 8:00am - 5:00pm Co-Chairs: Mark Frimann Aidan Turnbull

  2. Agenda • Welcome/introductions • Annual review process for solution providers • Recap and results from 2014 review process • Lessons learned in 2014 and recommendations to improve the review process in 2015 • Additional elements to evaluate in 2015 review • Promoting the standard • Discussion of how to include PAH restrictions in Appendix E • Proposal for a new METI Appendix G to IPC 1752A • AOB and next steps

  3. Annual Review of Solution Providers for IPC 1752A • Purpose • Recognition by IPC as an approved solution provider for IPC 1752A • Ensure that software tools are compliant to the latest released standard, schema and IPC lists of Substance Categories and Exemptions • Ensure that solution providers keep their systems up-to-date • This annual review is not a certification of tools. • Solution providers were invited to submit Class A, Class C and/or Class D XML files for the data sets to IPC by April 1 • Scope of initial review: • Current IPC lists of Substance Categories and Exemptions are being used; and • The XML files provided can validate against the current schema

  4. Annual Review Timeline √ April 1: Deadline for Solution Providers to submit data set √ April 1-30: Review Committee to review and comment on XML files for data sets submitted • Each solution provider’s XML files to be reviewed by at least 3 Review Committee members • Review Committee members cannot comment on their own solution • Review Committee members to submit comments on the solution provider’s XML files to IPC by April 29 √ April 30: IPC to circulate all comments received to Review Committee and schedule conference call √ May 30: Review Committee to determine next steps for each solution provider • Approve • Disapprove - needs improvements. Review Committee to specify the required improvements √ August 31: If necessary, solution providers to resubmit corrected XML files to IPC √ September 17: Review Committee to review resubmitted XML files September 30: IPC to notify solution providers on the Review Committee’s findings October: Publish to the IPC website the 2014 approved list of IPC 1752A solution providers

  5. Current Review Committee Members open invitation to join • Forrest Christian, Innovation Machine, 2-18 Committee Chair • Roger Franz, TE Connectivity • Mark Frimann, Texas Instruments, 2-18b Committee Co-chair • Jason Gooden, Anthesis • Nikki Johnson, Total Parts Plus • John Kuta, Mark Williford PTC • Travis Miller, Foresite Systems • Dr N. Nagaraj, Papros • John Sharp, TriQuint Semiconductor • Aimee Siegler, Benchmark Electronics • Aidan Turnbull, ENVIRON, 2-18b Committee Co-chair • Tedie West, Teamcenter

  6. Draft results from 2014 review process

  7. Recommendation 1: Data sets for solution providers to report against should be checked carefully • There was an inconsistency between the Class C declaration statements for Data Set 2 and the data table for the Class D declaration for Data Set 2. The Class D data table for Data Set 2 should have called out Lead/Lead compounds and the 7(c)-I exemption, as highlighted in red bold in the document referenced below. • For this first year of the Annual Review process, solution providers were asked to report the Data Set 2 Class C XML and Class D XML exactly as they were written in the Word document. This inconsistency does not affect the objective of this first annual review, which is to check that current IPC lists of Substance Categories and Exemptions are being used and that XML files provided can validate against the current schema

  8. Recommendation 2: Provide a prescriptive review form to guide review committee members to only comment on items in which are in scope of the review • The 2014 Review Form did not restrict reviewers to only comment on items which are in scope of the review. As a result, over 300 comments were received, more than half of which did not relate to the items under evaluation • The 2015 review form should specifically ask only for comments on items which are in scope of the review. For example:

  9. Recommendation 3: Solution Provider’s XML files should be anonymous • This year’s review process associated the solution provider and their XML files to the Review Committee • In future years, solution providers will be kept anonymous by allocating a unique identification to each solution providers set of XML files. • All solution providers will be asked to use the following file naming convention for their XML files DataSet1ClassA.xml, DataSet1ClassC.xml, DataSet1ClassD.xml, DataSet2ClassA.xml, DataSet2ClassC.xml, DataSet2ClassD.xml • IPC will allocate unique identification to each solution providers set of XML files before distribution to the review committee. For example: Sol1DataSet1ClassA.xml, Sol1DataSet1ClassC.xml, Sol2DataSet1ClassA.xml, Sol2DataSet1ClassC.xml

  10. Recommendation 4: Provide a short tutorial on how to use XML validation tools • Review Committee members are free to use any tools to check whether an XML file validates against the current IPC XML schema, for example commercial tools such as XMLSpy. In 2015, Committee members will be asked to report which validation tools they used to check that the XML files validate • Some free online tools which review committee members may like to consider include: http://www.corefiling.com/opensource/schemaValidate.html http://www.freeformatter.com/xml-validator-xsd.html http://www.utilities-online.info/xsdvalidation/ • For the 2015 review, a short web meeting tutorial will be provided for the Review Committee to go through the 2015 review process with a ‘dummy’ XML before the 2015 solution provider XMLs are issued to the review committee for evaluation

  11. Recommendation 5: Need to track the current version of the Schema as amendments/corrections are made • 2014 review process identified two errors in the IPC 1751A Schema which were corrected in June 2014 • A typographic error in the signature field in the Schema has been fixed. This caused all XML files to fail the validation check, even when the XML conformed to all requirements in the IPC 1752A standard. • The schema has been corrected so that numberOfInstances is not a required field. • The current version of the Schema which includes these corrections is currently named “IPC1751A-corrected.xsd” and has a date stamp of 18 June 2014. This current version of the schema is included in the zip file when you download IPC 1751A standard from the IPC website at http://www.ipc.org/ContentPage.aspx?pageid=Materials-Declaration • However, when you download the IPC 1752A standard from the IPC website then the zip file includes the un-corrected schema name “Amendment 2 to IPC 1751A schema.xsd” which has a date stamp of 17 April 2014

  12. Recommendation 5: Need to track the current version of the Schema as amendments/corrections are made • We need to: • Find a way to name the current version of the schema so that all solution providers know which is the current version • Ensure that the current version of the Schema is provided in the zip files when you download the IPC 1752A standard and the IPC 1751A standard • One recommendation is to include the revision date in the file name for the latest version of the IPC 1751A schema. For example, “June 2014 revision of IPC 1751A schema.xsd” • Another recommendation is to change the text on the IPC website to indicate where the latest version of the schema can be downloaded

  13. The latest version of the IPC 1751A standard and IPC 1751A Schema can be downloaded by visiting www.ipc.org/1751

  14. Additional elements to evaluate in 2015 review • The scope of the 2014 review should be carried forward into the 2015 review, to check that • Current IPC lists of Substance Categories and Exemptions are being used; and • The XML files provided can validate against the current schema • Additional elements which could be added to the scope of the 2015 review include • Checking that Class A XMLs include the correct statements for the data sets • Checking that Class C and Class D XML files correctly report the substance masses and concentrations provided in the data sets

  15. Promotion of Standard • Articles in trade press • Presentations at conferences • Information on IPC website

  16. Brief overview of REACH Authorisation process • An SVHC is included in the Candidate List. Article 33 requires suppliers in the EU to inform EU customers if the supplied article contains > 0.1% w/w of the REACH Candidate List substance • ECHA prioritises the substances from the Candidate List to determine which ones should be included in the Authorisation List (Annex XIV of REACH) and therefore, subject to authorisation • Companies who want to continue to manufacture or use the substance in the EU after the Sunset Date must apply for Authorisation for that specific use. The European Commission will grant an Authorisation if the applicant can demonstrate that the use of the substance in the EU is adequately controlled. • For example, in August 2014 the European Commission granted an Authorisation to Rolls-Royce Plc to use the substance Bis(2-ethylhexyl) phthalate (DEHP) in a formulation used during the bonding and manufacture of aero engine fan blades. The Authorisation only permits Rolls-Royce (the Applicant) to use this substance in the EU for this specific use.

  17. Comparison of RoHS substance restrictions and REACH substance restrictions • RoHS substance restriction • All applications of the RoHS substance are restricted in Electrical and Electronic Equipment, except for these specific applications which are exempt • REACH substance restriction (Annex XVII) • These specific applications of the substance are restricted and all other applications are not covered

  18. Discussion of how to include new REACH substance restrictions on PAHs in Appendix E • Four options have been proposed for how these REACH substance restrictions on PAHs could be included in Appendix E. The Committee will discuss these options and decide the best approach.

  19. Discussion of how to include new REACH substance restrictions on PAHs in Appendix E • Option 1 and Option 2 follow historic approaches already used in Appendix C for JIG substances and Appendix E for the REACH substance restriction for Benzene • Option 3 and Option 4 are new approaches which would require a change to the IPC 1752A standard

  20. Option 1: Include 2 separate substance categories Similar to historic approach in Appendix C for JIG substances. For example, “Lead/lead compounds- All, except batteries” “Lead/lead compounds- Batteries”

  21. Example XML for Option 1

  22. Option 2: Include 1 substance category Similar to historic approach in Appendix E for the REACH substance restriction for Benzene. For example:

  23. Example XML for Option 2

  24. Option 3: Include 1 substance category and 2 “REACH exemptions” • Exemption 1: Part is not used in toys and childcare articles and contains less than 0.0001% of any individual PAH in plastic or rubber material that come into direct, prolonged or repetitive skin or oral cavity contact • Exemption 2: Part is not used in toys and childcare articles and plastic or rubber material does not come into direct, prolonged or repetitive skin or oral cavity contact • Would require IPC to create (and maintain) our own IPC list of “REACH exemptions” and amend the IPC 1752A Standard to allow use of “REACH exemptions” in Appendix E. Note: These are implied exemptions – the REACH Regulation does not include exemption texts

  25. Example XML for Option 3

  26. Option 4: Include 1 substance category and 2 reportable applications and thresholds Would require IPC to update Appendix to include Reportable Applications for all entries and to amend the IPC 1752A Standard to make the Reportable Application field Mandatory if Appendix E substance category list is reported in the XML. (Use of reportable application field is already mandatory for Appendix E substance category list is reported in the XML).

  27. Example XML for Option 4

  28. Proposal for a new METI Appendix G to IPC 1752A • Following meetings with Aidan Turnbull (co-chair of IPC 1752A) in Tokyo, the Japanese Ministry of Economy, Trade and Industry (METI) has asked if IPC would consider supporting lists of regulated substances which are important for the new Japanese Chemical Management Scheme. • Supporting the METI lists in a new Appendix G to IPC 1752A could enable the IPC 1752A standard to become recognized in Japan as a suitable standard for materials data exchange with Japanese companies

  29. Selection rules for laws/regulations and industrial standards to be incorporated in the substance list for the new scheme The new scheme will seek to create a common substance list that reflects needs of entire supply chain and therefore forges their consensus, in order for facilitating more efficient and secured information handling practice for chemical substances in products (CSiP) over a supply chain. Selection criteria for laws/regulations and industrial standards to be incorporated in the substance list for the new scheme Select substance lists from existing laws/regulations(*) and industrial standards which contain CSiP-related provisions for products in the market (*)Designated substances (or substance groups) under laws/regulations in place are subject to selection for the time being, setting aside those in preliminary lists unless controlled by industrial standards. Attentions should be paid to how to handle substances under public consultation, assuming that such substances are soon to be designated. Contents (condition, term, criteria, etc.) of original lists will be imported as a whole without modification. No intention to examine each of individual substances for selection. The substance search list is provided for users’ convenience to support more efficient info-handling practice and therefore is not available to the public. Such positioning should be explained to users in order to avoid unintended use, noting that users need to fully refer to relevant laws/regulations as long as the search list is nothing but a reference material. The substance list initially covers laws/regulations in the EU, the US and Japan, which can be expanded to those in Asian countries based on a full examination in accordance with modification procedure, if assessed as an appropriate element to be incorporated in the common list.

  30. Laws & Industry Criteria covered by Draft SHELPA Declarable Substances List

  31. Japan Chemical Substances Control Law: Class 1 Specified Chemical Substances Applies to manufacture and use of chemical substances, and also applies to intentionally added substances in articles (components, equipment etc) • Prior permission is required for manufacture and/or import of any of the chemical substances on the list (or any mixture or preparation which includes the chemical substances) and articles which contain intentionally added chemical substances on the list • Implementation of recall and other measures may be ordered Supporting this list in IPC 1752A Appendix G, with METI Substance List ID = LC01, would enable companies to use IPC 1752A XML to report compliance for Japan CSCL : Class 1 Specified Chemical Substances

  32. Toxic Substances Control Act (TSCA) (US) : Section 6 Applies to manufacture and use of chemical substances, and also applies to intentionally added substances in articles (components, equipment etc) • TSCA Section 6 regulates certain hazardous chemical substances and mixtures and authorizes EPA to take regulatory action to protect against unreasonable risk of injury to human health or the environment due to the manufacture, import, processing, distribution in commerce, use or disposal of a chemical substance or mixture. Supporting this list in IPC 1752A Appendix G, with METI Substance List ID = LC02, would enable companies to use IPC 1752A XML to report compliance for US TSCA Section 6 chemical substances

  33. EU ELV Directive 2011/37/EU • EU ELV Directive 2011/37/EU restricts the use of lead, mercury, cadmium or hexavalent chromium in materials and components of vehicles put on the market after 1 July 2003 • The list of materials exemptions in ELV Directive 2011/37/EU is already included in Table B6 in Appendix B of IPC 1752A • Supporting the ELV restricted substances list in IPC 1752A Appendix G, with METI Substance List ID = LC03, would enable companies who supply to the automotive industry to use IPC 1752A XML to report compliance to the EU ELV Directive

  34. EU RoHS2 Directive 2011/65/EU • The list of EU RoHS substance restrictions is already included in Table B1 in Appendix B of IPC 1752A • IPC 1752A Appendix G would include METI Substance List ID = LR04 and would explain that the content for this list (i.e. the substance category names in the list) is provided in Table B1

  35. EU POPs REGULATION (EC) No 850/2004 Annex I Persistent organic pollutants (POPs) are chemical substances that persist in the environment, bioaccumulate through the food web, and pose a risk of causing adverse effects to human health and the environment. The POPs Regulation includes a range of substance restrictions • Some are relevant to articles in electrical and electronic equipment and other industries (examples include PCBs, Polychlorinated Naphthalenes) • Some are relevant to articles in other industries but EEE is exempt because the substances are already restricted under RoHS (examples include tetrabromodiphenyl ether, pentabromodiphenyl ether) • Other substances include pesticides, insecticides and herbicides (examples include DDT, Endosulfan, Hexachlorobutadiene) Supporting this list in IPC 1752A in IPC 1752A Appendix G, with METI Substance List ID = LC05, would enable companies who supply to a wide range of industry sectors to use IPC 1752A XML to report compliance to the EU POPs Regulation

  36. EU REACH REGULATION (EC) No 1907/2006Candidate List of Substances of Very High Concern for Authorization (SVHC), Authorization List • The list of EU REACH Candidate List Substances is already included in Table D1 in Appendix D of IPC 1752A • ECHA prioritises the substances from the Candidate List to determine which ones should be included in the Authorisation List (Annex XIV of REACH) and therefore, subject to authorisation. In other words, all substances on the Authorisation List are already included in the REACH Candidate List • IPC 1752A Appendix G would include METI Substance List ID = LR06 and would explain that the content for this list (i.e. the substances names in the list) is provided in Table D1

  37. EU REACH REGULATION (EC) No 1907/2006Annex XVII Substance Restrictions • REACH Annex XVII includes 64 different substance restrictions. • Some are relevant to articles in electrical and electronic equipment and other industries (examples include DBT, DOT, Nickel, selected group 1 phthalates) • Some are relevant to articles in other industries (examples include chromium VI in cement, ammonium nitrate in fertilisers, arsenic compounds in wood preservation, chloroethane (vinyl chloride) as a propellant in aerosols) • Many entries have an extremely complicated list of reportable applications. For example, the restrictions on Nonylphenol and Nonylphenol ethoxylates have nine (9) different reportable applications

  38. EU REACH REGULATION (EC) No 1907/2006Annex XVII Substance Restrictions • Table E1 in Appendix E of IPC 1752A already includes the screened list of 19 REACH Annex XVII substance restrictions which are applicable to electrical and electronic equipment (PAHs are still to be added to this list) • However, METI would like to include an inclusive list of all 63 substance restrictions in their list LR07 • As a starting point, METI agrees with the current IPC 1752A screened list of Annex XVII substance restrictions which are applicable to electrical and electronic equipment • METI and IPC should work together to develop a list which contains all of the Annex XVII restricted substances and their thresholds and applications. • More work is needed to develop a practical approach for this inclusive list. METI plans to develop a draft proposal for this new inclusive list LR07.

  39. Global Automotive Declarable Substance List • The Global Automotive Declarable Substance List (GADSL) includes substances which are restricted or declarable for parts and materials supplied by the supply chain to automobile manufacturers. • GADSL has 133 entries, some for individual substances and others for groups of substances. Supporting the GADSL list in IPC 1752A Appendix G, with METI Substance List ID = IC01, would enable companies who supply to the automobile industry to use IPC 1752A XML to provide materials declarations against the list of substances and substance groups in the GADSL list.

  40. IEC 62474 DB Declarable substance groups and declarable substances (slide 1) • Table F1 in Appendix F of IPC 1752A already includes the IEC 62474 list of declarable substance groups and declarable substances Appendix G would include METI Substance List ID = IC02 and would explain that the content for this list (i.e. the declarable substance groups and declarable substances) is provided in Table F1

  41. AOB and Next Steps

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