Should Design Engineers Run Environmental Compliance?

The recent addition of two new exemptions to the European Union's RoHS (Restriction on Hazardous Substances) directive shows how quickly changes come to compliance regulations.

The endless stream of changes to RoHS, REACH (Registration, Evaluation, Authorization, and Restriction of Chemicals), WEEE (Waste Electrical and Electronic Equipment), and other regulations falls on the bench of the design engineer. They further complicate matters that each geographical region has its own version of these regulations.

News of two new RoHS exemptions was detailed by Gary Nevison from Premier Farnell in his blog.

The gist is that component manufacturers can now include lead in PZT (lead zirconate titanate)-based dielectric ceramic materials for capacitors. Also on vacation from RoHS is cadmium used in photo resistors for analog optocouplers applied in professional audio equipment. This comes just a few short weeks after the European Commission released the RoHS recast. The exemptions will automatically expire in five to seven years unless they are renewed.

Keeping up with these changes becomes the responsibility of the design engineer, unless the company has developed a compliance function to support design. "Design engineers are there to design products. Someone else should be there to let them know what they can and cannot do," Ken Stanvick, Vice President of Design Chain Associates (DCA), told Design News. DCA is a San Francisco firm that helps companies cope with environmental compliance in the electronics industry. "In some cases, this responsibility ends up on the design engineer," said Stanvick.

Design engineers have enough on their bench just making sure their designs work and meet budgets. Environmental compliance is a separate skillset. "When design engineers have to chase down environmental compliance regulations, it's a waste of their talent," said Stanvick. "We continually hear the complaint from design engineers, 'I can't track this and do my job. Just tell me what I can and can't use. Give me the list.' "

Large companies tend to have an internal compliance function to support design engineers. Medium- and small-size companies may hire an outside firm such as Design Chain Associates or simply let it fall on the design engineer. Meanwhile, the changes just keep coming.