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
– 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
2
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
3
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
4
Current Review Committee Members
open invitation to join
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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
5
Draft results from 2014 review process
Solution provider
Approved declaration classes
PLM
A, C and D
Dassault Systemes
A, C and D
Total Parts Plus
A, C and D
Foresite
D
Anthesis
A and D
Papros
A, C and D
BOMcheck
C and D
6
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
7
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:
8
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
9
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
10
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
11
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
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The latest version of the IPC 1751A standard and IPC 1751A Schema can be downloaded by visiting www.ipc.org/1751
13
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
14
Promotion of Standard
• Articles in trade press
• Presentations at conferences
• Information on IPC website
15
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.
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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
17
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.
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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
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Option 1: Include 2 separate substance categories
Any individual PAH
compound
0.0001% by weight (1 ppm) in plastic or
rubber material that come into direct,
prolonged or repetitive skin or oral
cavity contact
Any individual PAH
compound – toys and
childcare articles
0.00005% by weight (0.5 ppm) in plastic
or rubber material in toys and childcare
articles that come into direct, prolonged
or repetitive skin or oral cavity contact
Similar to historic approach in Appendix C for JIG substances.
For example,
“Lead/lead compounds- All, except batteries”
“Lead/lead compounds- Batteries”
20
Example XML for Option 1
21
Option 2: Include 1 substance category
Any individual PAH
compound
0.0001% by weight (1 ppm) in plastic or
rubber material that come into direct,
prolonged or repetitive skin or oral cavity
contact or 0.00005% by weight (0.5 ppm)
in plastic or rubber material in toys and
childcare articles that come into direct,
prolonged or repetitive skin or oral cavity
contact
Similar to historic approach in Appendix E for the REACH substance
restriction for Benzene. For example:
Benzene
Content must be less than 0.0005% w/w
in toys and less than 0.1% w/w in any
substance or preparation
22
Example XML for Option 2
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Option 3: Include 1 substance category and
2 “REACH exemptions”
Any individual PAH
compound
0.00005% by weight (0.5 ppm) in plastic
or rubber material that come into direct,
prolonged or repetitive skin or oral cavity
contact
•
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
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Example XML for Option 3
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Option 4: Include 1 substance category and 2
reportable applications and thresholds
Reportable Application
Threshold
Any individual
PAH compound
Plastic or rubber material
that come into direct,
prolonged or repetitive skin
or oral cavity contact
0.0001% by weight (1
ppm) in plastic or rubber
material
Any individual
PAH compound
Plastic or rubber material in
toys and childcare articles
that come into direct,
prolonged or repetitive skin
or oral cavity contact
0.00005% by weight
(0.5 ppm) in plastic or
rubber material
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).
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Example XML for Option 4
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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
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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 infohandling 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.
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Laws & Industry Criteria covered by Draft SHELPA Declarable Substances List
Substance
List ID
the specification
standards for the
Declarable
Substances
content
<information>
number of substances
/ substance groups
［2014-08-26］
LR01
CSCL(Japan)
Class I
Chemical Substances Control Law (Japan) : Class I
Specified Chemical Substances
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LR02
TSCA: Section 6
Toxic Substances Control Act (TSCA) (US) : Section 6
13
LR03
EU ELV Directive
Directive 2011/37/EU Targeted substances list
4
LR04
EU RoHS
directives
2011/65/EU Targeted substances list
6
LR05
EU POPs Annex I
EU POPs REGULATION (EC) No 850/2004 Annex I
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LR06
EU REACH
SVHC,
Authorization
EU REACH REGULATION (EC) No 1907/2006
The Candidate List of Substances of Very High
Concern for Authorization (SVHC), Authorization List
155（SVHC）
31（Authorization）
LR07
EU REACH
Restriction
substances
EU REACH REGULATION (EC) No 1907/2006
Annex XVII Substance Restrictions
IC01
GADSL
Global Automotive Declarable Substance List
IC02
IEC 62474
IEC 62474 DB Declarable substance groups and
declarable substances
64（entry）
132
104
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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
31
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
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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
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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
34
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
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EU POPs Regulation
EU REACH REGULATION (EC) No 1907/2006
Candidate 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
36
EU REACH REGULATION (EC) No 1907/2006
Annex 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
37
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EU REACH REGULATION (EC) No 1907/2006
Annex 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.
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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.
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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
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AOB and Next Steps
42