UL/CSA UPDATE INDUSTRY ISSUES – Environmental CPSC Thursday – November 29, 2007 Omni La Mansion Del Rio Hotel San Antonio, Texas
n UL 5085 n CSA C22.2 No. 66.1-06 n First Edition n Binational Standard
n Covers: n Low Voltage Transformers – n Part 1: General Requirements n Part 2: General Purpose Transformers n Part 3: Class 2 and Class 3 Transformers
n The Standard covers: n Air-cooled transformers & reactors for general use n General purpose autotransformers n Ferroresonant transformers n Class 2 and Class 3 transformers n Cord-connected transformers n Transformers incorporating overcurrent or over- temperature protective devices, transient voltage surge protectors, or capacitors n Permanently-connected transformers
n These standards were developed without the benefit of a formal Technical Harmonization Committee (THC). n These standards were developed without the benefit of a formal Technical Harmonization Committee (THC). n However, binational harmonization is intended to be an industry-driven effort. In anticipation of the future maintenance of these standards (UL has already received a proposal request for UL 5085-3), UL and CSA are in agreement that in keeping with current harmonization practices, a THC should be established for this Standard. n However, binational harmonization is intended to be an industry-driven effort. In anticipation of the future maintenance of these standards (UL has already received a proposal request for UL 5085-3), UL and CSA are in agreement that in keeping with current harmonization practices, a THC should be established for this Standard. n The THC would be charged with the review and resolution of proposals and comments received by the involved Standards Development Organizations (SDOs), presently, UL and CSA. It should also be noted that this industry has agreed to a 3-year revision cycle.
n UL and CSA would like to request TTA's participation as the THC Secretariat and to request TTA's help in identifying a representative of industry to serve as the THC Chair. n UL and CSA would like to request TTA's participation as the THC Secretariat and to request TTA's help in identifying a representative of industry to serve as the THC Chair. n The THC Chair is responsible for organizing the THC meetings and for the progression of the development of the harmonized standard.
n The THC Secretariat is charged with issuing agendas and meeting reports for the THC meetings; collecting the THC comments and distributing them to the THC for consideration; ensuring that the THC provides a draft of the harmonized standard and rationales in accordance with established processes and format, and providing copies of THC meeting agendas, reports, and draft standards to the Publication Coordinator.
European RoHS Directive (2002/95/EC) n Bill in place since 1st July 2006 (Lead, mercury, cadmium, hexavalent chromium, PBBs, PBDEs) n Surveillance has been light in the first year; will vary by country; More vendors asking for “proof” n Other countries/states considering legislation; CEA organizing trade associations to create a framework for future materials legislation
California RoHS (AB 48) n Bill AB 48 reintroduced to implement the EU’s RoHS Directive n Includes Transformers; passed the Assembly and is in the Senate; still has cost concerns n Effective Jan, 2010 n Process to petition (DTSC) Department of Toxic Substances Control for specific exemptions n Current language will ban various materials mirroring the EU regulations
New Work Item Proposal (NWIP) China RoHS n EU restricted materials sold into China; After 2008, products containing these will require certification n Product schedule will be published; Focus on electronics, electrical components, transformers, batteries, chargers and radio in scope (limited understanding – a dynamic situation) n Labelling requirements in place Jan 2007; green/orange
Committee Draft (CD) E-Waste n States continuing to introduced legislation; Most electrical and electrical products, including transformers are included in most legislation n Note – Important to monitor ‘Product take back’ at the state level as this is one of the most likely types of legislation, aside from material restrictions to impact transformers.
Committee Draft for Vote (CDV) Energy Using Products (EuP) n In development – expected late 2007/early 2008 n Provides framework for “Eco” design requirements n Covers energy efficiency and standby losses including transformers
Committee Draft for Vote (continued) n Energy Using Products (EuP) n Legislation could lead to mandatory energy loss product declaration n Future - Unknown product implications as standards are not yet developed to address Eco design; Likely that companies will need an “EMS” (Environmental management system) in place to comply [ISO 14000]
Final Draft International Standard (FDIS) Registration, Evaluation and Authorization of Chemicals (REACH Directive) n European Chemical Policy n In force June, 2007; First restrictions on usage 2009; minimum amounts for usage start to reduce by 2011 n The administrative impact of this directive could be much greater then RoHS n Cost and availability risks, and impact on product design unknown
n Registration, Evaluation and Authorization of Chemicals (REACH Directive) n Need to identify high concern materials, over life cycle, estimate volumes and register if required n Requires pre-registration of chemicals used, prioritized by volume; Polymers exempt
Systematic Review of International Standards Carbon Footprinting n Measure the climate impact of a product, organization, activity (meeting) or group of people n Carbon labels communicate the impact of a product to customers n Piloting on foods and pharmaceuticals in Europe; governments and retailers beginning to apply pressure to disclose n Standards are being developed with social pressure against “abuse” e.g. patio heaters
IEC General Corporate Social Responsibility (Sustainability) n Three leg stool: Profits, people and the planet n Business impacts u Eco labeling u Investor proposals u Toxic material concerns u Supplier controls u Green purchasing u Green buildings
n Future Trends n Climate change legislation n Green building n Energy efficiency n Materials focus
n Consumer Product Safety Commission n HR 4040 n Federal Reports Elimination and Sunset Act of 1995 (three changes) n Consumer Product Safety Act (50 changes) n the Federal Hazardous Substances Act (24 changes) n Flammable Fabrics Act (five changes).
n S 2045 n Consumer Product Safety Act (75 changes) n Poison Prevention Packaging Act of 1970 (one change) n Federal Hazardous Substances Act (21 changes) n Flammable Fabrics Act (three changes) n one change to 15 U.S.C. 2053 n three changes to 31 U.S.C. 1113
n Increase the CPSC's authorized budget to $80 million in FY 2009, with 10 percent n Increases thereafter, until it reaches $141.7 million in FY 2015 (FY 2007 budget was $62.7 million) n Increase staffing to 500 employees from 420 n Increase civil penalties for violations of the Consumer Product Safety Act (CPSA) from $5,000 per violation to $250,000 per violation, capping at $100 million (currently capped at $1.25 million)
n Increase criminal penalties for knowingly violating the law to five years in prison n Require that CPSC enforce whistleblower protections for employees of manufacturers and importers n Allow state attorneys general to bring civil suits n Outlaw children's products containing lead
n Make it illegal to sell recalled products; n Specify consumer safety provisions for a variety of products, including all-terrain vehicles and garage door openers; and n Provide whistleblower protections for CPSC employees.