1. RoHS and REACH Update
19 July 2011
Technology & Engineering

2. What is RoHS?
Restriction of the use of certain Hazardous Substances in electrical and electronic equipment
Directives of the European Parliament and of the Council
2002/95/EC, 2005/618/EC, 2011/65/EU
Certain exemptions, including some medical and some military equipment

3. Definition – European Directive
A LAW of and within the European Union!
Rules of a government that must be obeyed upon threat of penalties.

4. RoHS Controlled Substances
Lead (0.1%, 1000 ppm)
Mercury (0.1%, 1000 ppm)
Cadmium (0.01%, 100 ppm)
Hexavalent chromium (0.1%, 1000 ppm)
Polybrominated biphenyls (PBB) (0.1%)
Polybrominated diphenyl ethers (PBDE) (0.1%)
Loss of the DecaBDE exclusion forced OCC product redesigns in 2008!
The Commission must consider amendments to the list before July 22, 2014, so additions should be expected in the future.

5. News! RoHS Recast !
RoHS was replaced with a new directive: RoHS Recast (08 June)
Possible effects of this new directive are being determined - may impose
new compliance data
declaration of conformity
CE marking of product
labeling requirements
importer requirements

6. What is REACH?
REGULATION (EC) No 1907/2006 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL
Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH)
“This Regulation should ensure
A high level of protection of human health and the environment
Free movement of substances, preparations and, articles
...while enhancing competitiveness and innovation”
Establishes a European Chemicals Agency (ECHA)
The Agency, located in Helsinki, maintains a database of registered chemicals
Far more chemicals than RoHS

7. REACH vs. RoHS Chemicals Lists

8. Substances, Preparations, Articles
REACH Definitions
Substance: Chemical element and its compounds including additives necessary to preserve its stability and any impurity deriving from the process used
Preparation: Mixture or solution composed of two or more substances
Article: An object which during production is given a specific shape, surface or design, which determines its function to a greater degree than its chemical composition

9. REACH Registration Requirements
Manufacturers and importers of substances are required to register information in the ECHA central database
ECHA registration requires a legal entity in the EU familiar with the safe handling of the substances
As a manufacturer of “articles” OCC is required to register substances under the normal rules if any substances are
intended to be released from articles during normal and reasonably foreseeable conditions of use, and
are present in the articles above 1 tonne per year
No OCC articles meet these criteria.

10. Substances of Very High Concern
In addition, all substances of very high concern (SVHC) must be identified
Category 1 or 2 carcinogens, mutagens, toxic for reproduction, and other substances of equivalent concern
SVHC must be notified if present in articles
above a concentration limit of 0.1% by weight, and
In such case safety instructions should be provided

11. ECHA Candidate List of SVHCs (p.1)
Candidate List of SVHCs as of 20 June 2011
Number of Substances = 53
1,2,3-Trichloropropane
Anthracene
1,2-Benzenedicarboxylic acid, di-C6-8-branched alkyl esters, C7-rich
Anthracene oil
1,2-Benzenedicarboxylic acid, di-C7-11-branched and linear alkyl esters
Anthracene oil, anthracene paste
1-Methyl-2-pyrrolidone
Anthracene oil, anthracene paste, anthracene fraction
2,4-Dinitrotoluene
Anthracene oil, anthracene paste,distn. lights
2-Ethoxyethanol
Anthracene oil, anthracene-low
2-Ethoxyethyl acetate
Benzyl butyl phthalate (BBP)
2-Methoxyethanol
Bis (2-ethylhexyl)phthalate (DEHP)
4,4'- Diaminodiphenylmethane (MDA)
Bis(tributyltin)oxide (TBTO)
5-tert-butyl-2,4,6-trinitro-m-xylene (musk xylene)
Boric acid
Acrylamide
Chromic acid, Oligomers of chromic acid and dichromic acid, Dichromic acid
Alkanes, C10-13, chloro (Short Chain Chlorinated Paraffins)
Chromium trioxide
Aluminosilicate Refractory Ceramic Fibres
Cobalt dichloride
Ammonium dichromate
Cobalt(II) carbonate

12. ECHA Candidate List of SVHCs (p. 2)
Candidate List of SVHCs as of 20 June 2011
Number of Substances = 53
Cobalt(II) diacetate
Lead sulfochromate yellow (C.I. Pigment Yellow 34)
Cobalt(II) dinitrate
Pitch, coal tar, high temp.
Cobalt(II) sulphate
Potassium chromate
Diarsenic pentaoxide
Potassium dichromate
Diarsenic trioxide
Sodium chromate
Dibutyl phthalate (DBP)
Sodium dichromate
Diisobutyl phthalate
Strontium chromate
Disodium tetraborate, anhydrous
Tetraboron disodium heptaoxide, hydrate
Hexabromocyclododecane (HBCDD) and Alpha, Beta, Gamma diastereoisomers
Trichloroethylene
Hydrazine
Triethyl arsenate
Lead chromate
Tris(2-chloroethyl)phosphate
Lead chromate molybdate sulphate red (C.I. Pigment Red 104)
Zirconia Aluminosilicate Refractory Ceramic Fibres
Lead hydrogen arsenate

13. REACH - We’ve only just begun.
Original SVHC list (15) released on 28 October 2008
14 added on 13 January 2010
1 added on 30 March 2010
8 added on 18 June 2010
8 added on 15 December 2010
7 added on 20 June 2011
ECHA plans to address 106 “priority” SVHC’s by 2012.
There are hundreds more substances with lesser priority.

14. SVHC Status - 19 July 2011
REACH requires notification to EU customers if SVHCs are present
We have contacted OCC Roanoke and Asheville materials suppliers (including packaging) to request SVHC status
Most Roanoke and Asheville suppliers have responded
Of hundreds of Substances requested, we have received no reported SVHC
Asheville survey includes supplier articles, so is more complex
Dallas SVHC survey needs to be done

15. Beyond REACH Requirements
Several customers have persistently requested complete chemical breakdown of all substances contained in OCC articles (Rosenberger OSI, Amphenol, Emerson Stratos)
“It is our expectation to receive a materials declaration to assess present and future substances of very high concern”
“Without material declaration, we will be required to perform quarterly inquires. A materials declaration will eliminate this requirement“
“In order to comply with our obligations under REACH, we need and expect your cooperation”
“You have to fill out the form with following information:
which parts do you use to produce that cable
what is the weight of each material which is in the cable
the name of the materials
the substance of the materials
the article numbers of that material
“We need it for our customer and when we couldn’t deliver that sheet we aren’t able to deliver him our products”

16. Materials Declaration Test Case
Because of strong customer demands, we decided to try a test case of three B-Series cables
No proprietary information would be revealed, but we need to know how our suppliers are responding to these requests
Requests were sent to 10 suppliers explaining our customer requests and that we were not asking for any proprietary information
Our suppliers validated our approach
Supplying SVHC information is all that REACH requires for articles which do not emit substances
Our suppliers will not reveal detailed Materials Declarations

17. Materials Declaration Worksheet
Example: OC BH002ZALS9KRG5-MSY
Breakdown of part
Material/substance name
CAS No. / Int. Identifier
Weight in grams
Color Concentrate PE
Optical Fiber
0.158
Fiber Buffer
PVC
Subunit Jacket
TPR
Subunit yarn
Aramid Yarn
Filler yarn
Polyester Yarn
Cable Jacket
Polyolefin
Ripcord
Water Block Aramid

18. Supplier Position on Material Declaration
Example: DuPont
“DuPont is a science based company and the technology we develop is related to the composition of our polymer compounds and the technology to produce them
We agree to share proprietary information in case this is needed, e.g. in case of medical incidences.
We are not able to share confidential information.
We provide the information related to substances of concern as required by regulations or certain industry agreements.
Neither the regulations nor these industry agreements have as an objective to transfer confidential know how to the broad public.”

19. Future Effects on OCC?
Customers continue to demand Materials Declarations
No good satisfying solution
SVHC list will grow
Plasticizers used in PVC, TPR, and packaging might be affected
Possible materials impairment similar to previous RoHS issues
New RoHS Recast may impose
new compliance data, declaration of conformity, CE marks, labeling, and importer requirements
Dallas needs to complete REACH and RoHS supplier surveys
Cannot rely on military exemption for general export