When Electrical Equipment Should Not Go To Waste
Defence companies supplying electronics for EU-based contracts could face environmental compliance regulations. In the first of a two-part look at compliance, columnist John Maclean describes what this could mean for the industry.
A few years ago, the volume and toxic content of electronic and electrical equipment finding its way into landfill was second only to the enormous quantities of household waste that went into local authority dumps.
This prompted the EU and national authorities to act with regulations and enforcement schemes. One such scheme prevents hazardous substances being used in the first place (RoHS or restriction of certain hazardous substances). Another is the requirement for responsible disposal known as the WEEE regulation (waste electrical and electronic equipment) that became law two years ago.
By and large, producers have taken these legal obligations seriously and many manufacturers positively advertise their compliance. But behind the scenes there are still some design and manufacturing issues. For instance, moving to new types of solder to avoid traditional use of lead (now restricted under RoHS), carries implications for board components because of higher temperatures used for effective bonding.
It is also proving challenging to replace hexavalent chromium. This environmentally unwelcome substance is used to ensure high reliance in electrical connectors, providing corrosion protection and assuring electrical conductivity in many 'shake, rattle and roll' performance tests.
At the disposal end, a subtle but significant aspect of the WEEE regulation is the shift of responsibility from the business end-user to the supplier when the product becomes waste: producers pay for the treatment, collection and recycling in most cases including disposal of batteries under a separate EU directive.
Encouraging RoHS and WEEE
Unlike their consumer electronics counterparts, defence companies have lagged behind in 'green' manufacture. Contrary to long-held belief, the MoD does not encourage exemption for equipment built for military programmes and sounds a wake-up call on RoHS and WEEE legislation embodied in UK law.
The directive of the secretary of state for defence defining MoD safety and environmental policy is clear in requiring compliance where practicable.
"We seek to disapply legislation on the grounds of national security only when essential to maintain operational capability." - secretary of state statement 8 December 2008.
The move is also inkeeping with supplier involvement in through-life management of service equipment and acknowledges pre-eminence of commercial standards within the procurement procedures.
The statement is reinforced by the DESB (Defence Environment and Safety Board) chaired by 2nd PUS, by Joint Service Publications, compliance with project-oriented environmental management systems (POEMS), generic guidance under defence standards and the MoD's defence equipment and supply standard contracts.
Case history indicates it is unwise to adopt a 'die in a ditch' attitude to change. Those who have challenged the EU for exemption of military material have mostly failed.
... Court ruled that articles in which the treaty provides for such derogations (including article 296 TEC) deal with exceptional and clearly defined cases. - C 414 commission vs Spain.
This is especially reinforced where IT and dual-use (military and civilian) equipment, such as radios, is concerned.
The general principle of free trade within member states applies with suppliers subject to agreed build standards. It is therefore harder for the defence industry to argue successfully against legislative compliance for conventional electronic boards based upon the security interests of the country.
Benefits of defence compliance
Often the imperative to provide robust circuitry for military requirements has led to design constraints with only a passing regard for RoHS compliance. This may not extend beyond defence engineers relying upon components sourced from trusted suppliers.
But their counterparts manufacturing civil or consumer products now ignore RoHS at their peril for there are obvious financial and marketing consequences to producers of these items if whole consignments are rejected as non-RoHS compliant by a national enforcement agency.
There are equally risky implications for export of defence electronic equipment. The scenario may be 'over the horizon' for the moment, but it's not hard to envisage how RoHS can be used as a competitive ploy or a licensing hurdle to thwart or delay an export opportunity.
So there is clearly a benefit to defence companies in designing and producing within RoHS criteria so as to avoid future rework, retesting and additional costs.
Furthermore attention to supplier obligations under WEEE offers maintenance and support opportunities to recover high value or limited edition components in sub systems that have been returned for repair or disposal.