creating manufacturing efficiency. accelerating your profit. what they are and how they impact you...

Creating Manufacturing Efficiency. Accelerating Your Profit.

What they are and how they impact you

EnvironmentalInitiatives

Worldwide

Copyright 2007 by Brooks Automation, Inc.

Training TopicsTraining Topics

The Concern The Focus The Legislation The Primary Substances The Products Covered Legal Requirements vs. Customer Requirements Brooks Current Status Next Steps and the Roadmap to Compliance


The Concern - What is driving environmental change?The Concern - What is driving environmental change?

The number of disposable electrical and electronic equipment (EEE) is increasing very rapidly Cell phones, PDAs, laptops, desk tops, printers, other

office and mobility products Toasters, coffee makers, sandwich machines,

household appliances, televisions

End of life usually means the trash can and then the land fill

There is not enough voluntary recycling

Toxic waste material is getting into the waste stream and into natural resources – land, water, air


The Focus – What products are affected?The Focus – What products are affected?

Consumer products Products that are replaced often Products that are disposed of easily

Office products Office machines that are replaced due to obsolescence Machines that are no longer needed

Industrial products Production equipment, tools Anything from hand tools to very large machines

Virtually any electrical or electronic

product is covered by this legislation


The LawThe Law

All legislation is similar but there are key differences

Some are aimed at consumer products only Some allow exemptions based on equipment type Some allow exemptions based on equipment

function Some do not allow any exemptions

Worldwide Requirements are similar more than they differ.


The Primary RoHS SubstancesThe Primary RoHS Substances

The focus is on Heavy Metals There are 6 basic substances:

Lead Mercury Cadmium Hexavalent Chromium PBB (used in plastics as a flame retardant) PBDE (used in plastics as a flame retardant)

These are known health hazards


The Primary RoHS SubstancesThe Primary RoHS Substances

There is a Maximum Concentration Value (MCV) for each of the substances

MCV for all is .1%, except for Cadmium which is .01%

MCV is based on the lowest homogeneous part of the product Homogenous level has a uniform composition and no

further separation by mechanical action (such as unscrewing, cutting, brushing or grinding) can be accomplished. Chemical separation is not allowed

These limits are the same for all current requirements


Products CoveredProducts Covered

Varies by legislation EU RoHS has 10 categories of electrical and electronic products

based on EU WEEE Directive EU RoHS currently exempts:

Large Scale industrial Tools (as part of Category 6 products they are exempt from WEEE and therefore also RoHS)

Medical Products – Category 8 Control & Laboratory Products – Category 9

China has a list of EIP – Electronic Information Products – that covers most of the known electrical and electrical products today

This is for Phase 1; different list will be used for Phase 2 All others are a subset of one of the above

Basic requirement is that the product use electricity


RoHS Comparison ChartRoHS Comparison Chart

EU CHINA JAPAN KOREA USASTATES

OTHERS

Implementation Date

Currently in Effect Phase 1 in effect

Currently in Effect

January 1, 2008

CA – in effect

Work is in progress in Australia, Canada, New Zealand and 26 US cities and States.

US will most likely follow California.

Australia will probably follow EU RoHS.

Canada is monitoring the US and EU

Legally required action at this time

LSIT – noneCat 9 – noneCat 6 (other than LSIT) – currently in effect

Disclosure by EPUP label and information table

No Legal Requirement at this timeDisclosure and prohibited use per Tables

None (will be same as EU ? ? ?)

Disclosure, prohibited use and mandatory recycling

Products Covered

1 - Large household appliances2 - Small household appliances3 - IT and telecommunications equipment4 - Consumer equipment5 - Lighting equipment6 - Electrical and electronic tools (with the exception of LSIT)7 - Toys, leisure and sports equipment8 – Medical Products9 - Monitoring and control instruments10 – Automatic Dispensers

As Listed in the EIP(if it uses electricity assume it is covered)

Japan RoHS Consumer Products- - - - - - - - Japan’s Green Initiatives covers all products and uses JIG-101 as the restrictive document; covers any B2B product as requested by the customer; also requires ISO 14001 Certification

Same as EU (???)Electrical & Electronic Products including components

Vehicles including components

May only include high volume waste products – yet to be determined

CaliforniaCRT, LCD, Plasma Displays ≥ 4” diagonal display

“Not covered if they are part of industrial, commercial or medical equipment”



EU CHINA JAPAN KOREA USA OTHERS

SubstancesCovered

LeadCadmiumMercuryChromium VIPBBPBDE

Same As EU Same as EU plus:

JIG = JIG A + JIG BJIG A = ( EU + 8)

JIG B = (+9)

Same As EU LeadCadmiumMercuryChromium VI

Pending

Future

legislation

MaximumAllowableLevel

Cadmium ≤ 0.01%All others at ≤ 0.1%

Same As EU Same as EU forRoHS + JIG 101values

Same As EU SameAsEU

ExemptionsAllowed

Based on applicationto and approval by EU; exemptions allowed forsubstances necessaryfor product function(lead in X-rays,mercury wetted relays,etc.

None None If elimination ofhazardoussubstance isextremelydifficult due toSpecialCharacteristicOf productsconcerned orthere is nosubstitute, andfor R&D andproducts forExport

Asallowedby the EU;

Also ifSubstanceuse isrequired toMeetsafetystandards

Pending

Future

legislation



EU CHINA JAPAN KOREA US

Compliance Drivers

Legally required forcovered products

Competitive Position

LegallyRequired


Customers who have adopted a “Green Procurement” program


ISO14001

Will belegallyrequiredfor covered products

CompetitivePosition

Legallyrequired for CoveredProducts

Comments and Notes

Cat 8 and Cat 9 willprobably be included inRoHS by 2010-2012

LSIT may be the topicof a future EUconsultation report (~2012)

Phase 2 will require restriction onsubstance usebut in a smallerproduct listingCatalog will becreated forproduct list

Customer Driven as noted above

SupportLegislationnot yetreleased

Does notaffectBusiness tobusinessProducts


Environmental TimelineEnvironmental Timeline

ID Task Name Start2006 2007 2008 2009

Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

1 8/15/2005EU WEEE

2 7/3/2006EU RoHS

3 3/1/2007China RoHS Phase 1

4 1/1/2009China RoHS Phase 2

6 1/1/2008Korea RoHS

1/2/2006Japan JIG-1015

anticipated date


StatusStatus

What Brooks is currently doing

and what we will be doing next to bring our

products into compliance with legal

requirements and customer expectations


How are we doing this?How are we doing this?

The Green Initiatives Steering Committee was formed to: Analyze and document the external threats and opportunities emerging

from environmental regulations Develop and champion strategies necessary to sustain business in

light of these emerging issues. Create internal programs intended to meet or exceed our customer’s

expectations for environmental compliance Use the opportunities resulting from these initiatives to distinguish

Brooks as an environmentally friendly company. Working Groups:

This committee established Working Groups to address specific environmental topics such as China RoHS.

There are representatives from each Division on the Steering Committee and Working Groups.

These Divisional representatives then work within their Working Groups to develop and implement plans, with review and approval by the EHS Steering Committee and Senior Management.


How are we doing this?How are we doing this?

Green Initiatives Working Groups: RoHS Marketing WG for all Divisions (TBD)

They will determine product status and roadmap, per the earlier slides

The Material Content WG through Global Sourcing interfaces with our suppliers to get the information we need in the form we need it.

Materials Declaration WG to work with IT to determine the tools needed to get the information from our suppliers into your ERPs

WEEE Registration WG is responsible for evaluating and implementing registration for certain products in EU member states.

ISO 14001 WG is responsible for planning and execution of ISO certification.


Brooks Automation Environmental PolicyBrooks Automation

Environmental Policy

Development of a Environmental Policy Statement:

“Brooks Automation recognizes that the protection of the earth's environment is one of the most important issues for all mankind.

We are committed to protecting the environment for our Customers, Partners, Employees, Friends and Neighbors in the workplace and the community.

We are committed to complying with environmental laws and regulations that affect our products worldwide.”


Current Compliance Status by Region – European UnionCurrent Compliance Status by Region – European Union

RoHS – Position papers has been issued for TAD, GCS and VPD Products. Most products are out of scope as “Large Scale

Industrial Tools” Continue to monitor EU activity for any changes

in current legal requirements.

WEEE – Working Group has been formed to complete the Registration for some VPD products (GP & CTI) in selected EU states. GP products contain the EU WEEE symbol,

indicated “not to be disposed of as trash”


Current Compliance Status by Region - ChinaCurrent Compliance Status by Region - China

Phase 1 Brooks products shipping directly to China are compliant

with Phase 1 requirements: EPUP label, MCV Table and Spares Identification.

We continue to monitor status in China for problems or scope change

We will do a review in July to see if we need to change anything in our current process

Working with various industry groups (SEMI Asia RoHS WG, ASTM F40 (Materials Declaration and Testing)

Position Paper Issued (www.brooks.com)

Phase 2 Monitor progress in China



EPUP label: All EIP products to be used in China require a label indicating the ”Environmentally Protected Use Period”. This is a period in years during which the product will not degrade, causing pollution. For products containing no RoHS materials above the Maximum

Concentration Values (MCV):

For products containing one or more RoHS materials above the MCV:

These labels are applied on the product and on the packaging. Draft Guidance Document is out for review



The Divisions make their own business based decisions for product labeling: They can label all products they ship, or If they know which ones go to China then can only label those

If a Brooks product is being shipped to a customer not in China it may not be labeled (depends on above decision)

If the customer then ships it to China it is now a component of their system They have to label their end product We will provide content information to them upon request.



Spare parts, replacement parts, or parts for upgrade are out of scope of China RoHS based on the MII’s China RoHS FAQ

Stamps or labels may be added to the shipping documentation to indicate that the shipment contains Spares, Replacements or Upgrade parts:

这些是零配件 , 维修用零件 , 更换用零件THESE ARE SPARE PARTS, REPAIR

PARTS OR REPLACEMENT PARTS

•这些零件用于设备升级THESE PARTS ARE TO UPGRADE

AN EXISTING INSTALLATION



A table (in Mandarin) is added to the User Documentation. Brooks declares presence of all 6 RoHS substances,

unless we have sufficient evidence that these substances are not present.

The table includes the top level product and one level below.

铅(Pb) 汞(Hg) 镉(Cd)六价铬

(Cr(VI ))多溴联苯

(PBB)多溴二苯醚

(PBDE)

真空机器手包括: MagnaTran® 7 vacuum robot i ncl udes: X X X X X X

机器手驱动本体 Robot dri ve body X X X X X X

机器手臂组合 Arm assembl y X X X X X X

机器手终端受动器组合 End eff ector assembl y X X X X X X

操作包 Operati ng package X X X X X X

O:表示该有毒有害物质在该部件所有均匀材料中的含量均在SJ / T11363-2006规定的限量要求以下X:表示该有毒有害物质至少在该部件的某一均匀材料中的含量超出SJ / T11363-2006规定的限量要求。

部件名称有毒有害物质或元素

表1 有毒有害物质或元素名称及含量标识格式


Current Compliance Status by Region - Japan Current Compliance Status by Region - Japan

We remain “legally” out of scope with current Japanese legislation

Customer driven Green Initiatives programs are requesting: RoHS/JIG-101 product compliance or roadmap A plan to achieve ISO 14001 certification Demonstration of corporate social responsibility.


Current Compliance Status by Region - KoreaCurrent Compliance Status by Region - Korea

Act for Resource Recycling of Electrical and Electronic Equipment and Vehicles Legislation released in early April, 2007 Translation available at

http://www.kece.eu/data/Korea_RoHS_ELV_April_2007_EcoFrontier.pdf *

Supporting legislation has not been released yet Korea RoHS begins on January 1, 2008 Scope covers:

Electrical and Electronic Equipment - equipment or device (including components and parts thereto) operated by electric currents or electromagnetic fields.

Vehicle - means an vehicle (including components and parts thereto) as provided in Article 2, Section 1 of the Automobile Management Act.

*Courtesy of Eco-Frontier



Definitions: Electrical and Electronic Equipment -

equipment or device (including components and parts thereto) operated by electric currents or electromagnetic fields.

Vehicle - means an vehicle (including components and parts thereto)



Article 9 (Restriction on the Use of Hazardous Substances and Concentration Limits) Among electrical and electronic equipment or vehicles which

generates high volume of waste after use, any person who manufactures or imports electrical and electronic equipment prescribed by the Presidential Decree (hereinafter, producers or importers of electrical and electronic equipment) and who manufactures or imports vehicles prescribed by the Presidential Decree (hereinafter, manufacturers or importers of vehicles) shall comply with the concentration limits of such hazardous substances as heavy metals and flame retardants, which are stipulated by the Presidential Decree and have high potential of environmental pollution, so as to promote recycling of electrical and electronic equipment and vehicles. Provided that this shall not be applicable in cases that the elimination of hazardous substance is extremely difficult due to special characteristic of products concerned or there is no substitute, as prescribed by the Presidential Decree, and in cases of research and development or export of products.


Current Compliance Status by Region – United StatesCurrent Compliance Status by Region – United States

State legislation is aimed at the consumer market, not at business to business – for now

Primary focus is on lead and mercury Some states limit use of certain

substances, but most US State legislation is concerned with recycling

One information source for US State legislation is the Northwest Product Stewardship Council (www.productstewardship.net)


US Legislation by State – Enacted and/or PendingUS Legislation by State – Enacted and/or Pending

California Connecticut Hawaii Illinois Iowa Louisiana Maine Maryland Massachusetts Minnesota Nebraska

New Hampshire New Jersey New York State New York City North Carolina Pennsylvania South Carolina Rhode Island Utah Vermont Washington


Next StepsNext Steps

Let’s talk about what needs to be done

to achieve legal compliance

and customer satisfaction


Legacy ProductsLegacy Products

Marketing must determine the future status of legacy products Will or are they being sold in Japan, China, etc.? Will they be become EOL in a reasonable time? Is there a product to replace them?

Question to ask before determining material content For specific products or for specific customers? Do you charge a NRE?

Need to provide the customer with a plan and milestones We will or will not get the information for the specific product Do you only report it or do you bring the product into compliance? Who will pay for it?


New Product DevelopmentNew Product Development

RoHS compliance must be in the product specification for all new products

Redesigned products should fall into this category as well

Do you include JIG-101 information as part of the requirements?


What do you need to know and when do you need to know it?What do you need to know and when do you need to know it?

Material Content & Declarations For JIG-101, China Phase 2, possibly EU RoHS, and other

pending legislation you will need to determine the material content in your products

Expect to get only one chance with your suppliers You need to determine what information you need and what format

you want it in. i.e Only RoHS substances? Should you include JIG-101 Table A and Table B? Some other combination? IPC format or other Time line for this information


Everyone has a roleEveryone has a role

Operations need to evaluate RoHS compliant tools (solder, coatings, etc.) and processes

Sourcing will be asked to find RoHS compliant alternate components Engineering will evaluate the alternate components and test the

form, fit, function Quality will assure the reliability, safety, and product performance are

maintained and verify processes. Documentation Control needs to decide how to identify compliant

components. Marketing, when confronted with the cost of bringing legacy products

into compliance, has to consider end of life vs. redesign options.


And then…And then…

If you do your homework and implement correctly you will be ready for new environmental legislation.

It will take planning and a few years to get it all done.

Create, Implement and Maintain processes and prepare for the next environmental opportunities.


SummarySummary

RoHS is NOT going away

RoHS will impact all more and more products

We all have a role in obtaining and maintaining

RoHS Compliance.


And now it’s your turnAnd now it’s your turn

Questions?

Thanks for your attention.

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