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1 IPC Low Halogen Electronics Standard Task Group 4-33a & JEDEC JC14 Committee March 30, 2009 S. Tisdale, Intel & S. O’Connell, Dell Task Group Co-Chairs

Low Halogen Electronics

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IPC Low Halogen Electronics Standard Task Group 4-33a

&

JEDEC JC14 Committee

March 30, 2009

S. Tisdale, Intel & S. O’Connell, DellTask Group Co-Chairs

Current Status of Ballot IPC Ballot Results

Yes Votes – 28 No Votes – 23 Comments – 77 pages

JEDEC Results Yes Votes – 11 / 15 No Votes – 6 / 2 Abstains – 3 / 3

Note : 4 No Votes in JEDEC have been resolved and changed to Yes Votes

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Major Groupings - Comments

Should be guideline not a standard No Scientific Justification Homogeneous Materials Elemental Br / Cl 900ppm vs 1000ppm Iodine & Fluorine Inclusion “Low Halogen” vs “Halogen Free”

terminology

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Guideline vs Standard “There are too many technical comments that

need addressed before this document could be considered for publication. In addition it should be a guideline only until further data is generated to make rational technical decisions as to the test methods and requirements for each material.”

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No Scientific Justification “Change title to “Limits for using materials objectional to Greenpeace in electronics”*

“Note: this standard is not based on scientific consensus or environmental impact.”

“As currently drafted, this standard is only directed to very specific types of halogenated products and even more specifically to certain “flame retardants” or PVC. This is discriminatory. It is based on Greenpeace dogma and does not have scientific consensus. Therefore the title, scope and purpose should be clearly stated as such. In addition, because standards from credible ANSI based organizations such as IPC are generally known to be based on consensus science rather than marketing, a disclaimer (*note) should be clearly attached to the title.”

“A few IPC members have assumed according to Greenpeace dogma that certain flame retardants and PVC deserve being singled out from other halogens and all other materials because they may create dioxin emissions during manufacturing or upon burning. Singling out requires in depth explanation because emissions of PTBs during manufacture and burning of alternative materials is also an important and pertinent subject broader than just dioxins, flame retardants and PVC. The scope should be broader and should include Polyaromatic hydrocarbons (PAHs), furans, and other PTBs that are emitted from any and all materials that might be used to replace flame retardants or PVC in electronics. If these alternatives are used to replace the feared large volumes of BFRs or PVC in electronics, then the alternatives’ emissions in turn may impact the environment more negatively. This is because different materials may create or emit larger volumes of PTBs or may even be more toxic, impactful on the environment. This could be true even if the alternatives are used in lesser quantaties than BFRs or PVC in electronics.”

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Homogeneous Material “Limits on Br, Cl should apply to all homogeneous

materials, and not be limited to only a subset of compounds that are vaguely defined. The draft standard is not independently verifiable through testing and creates loopholes that can be exploited. A standard that adopts limits on elemental Br, Cl (regardless of their source), on each homogeneous material is recommended as it is the only rigorous and measurable approach.”

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Elemental Br / Cl “Standard should address Br/Cl, not

BFR/CFR/PVC. Proposal introduces a subjective threshold of 'intended as a flame retardant'. INTENT cannot be measured. Furthermore, it is not clear why Br/Cl that is not a FR would be acceptable for the environment. Hence, the proposed standard would create confusion and would see limited acceptance.”

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Threshold Limits – 900ppm vs 1000ppm

“IPC4101 is referenced and Printed Circuuit Boards are listed but the levels for BR and Cl are different.”

“Is the PCB definition still: Bromine (Br) < 900 ppm (0.09%) Chlorine (Cl) < 900 ppm (0.09%) Total concentration of Both Cl and Br < 1500ppm

(0.15%)”

“What is the reason for the difference? Should the limits be the same? If not the same this should be noted or the reference to PCB laminate removed and limited to other materials”

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Inclusion of I & Fl – All Halogens “The scope should be for the halogens F, Cl, Br, and I and

should not single out what types of materials those elements are bound to.”

“The material is not truly halogen-free, or low-halogen if half of the halogens are arbitrarily excluded from the scope. No reason is provided as to why F and I are not included here other than saying that Cl and Br are the primary halogens used in electronic components. In fact, fluorine is also used in certain connector parts and cable systems and is considered part of the flame retardant package. Fluorine is also used in low loss PWB applications. Iodine is indeed much less common.”

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Terminology – Low Halogen vs HF

“Replace subtitle "BFR/CFR and PVC-Free" Definition By : Halogen-free Definition: and in thefirst sentence below

replace as "BFR/CFR and PVC-Free" by "Halogen-Free”

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Path Forward JEDEC

Continue to try to resolve remaining 3 No Votes Pass the current draft in JEDEC

IPC Resolution of the 77 pages of comments needs to be completed Updated draft sent out for re-ballot Target for resolution is by end of Q2’09 Re-ballot (if possible) will be as soon as comment resolution is completed

Note : Any technical revision based on IPC comments will force a re-ballot in the JEDEC committee as well.

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BACKUP

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Purpose of Standard

Definition of low halogen (not regulatory requirement)Establish an industry standard for the definition and threshold limits associated with “low-halogen” electronics, including electronic components, electronic assemblies, cables and mechanical plastics.......

Taken from section 1.1 of IPC/JEDEC J-STD-709

Status Standard was out for ballot and comments

on January 26th for both IPC & JEDEChttp://members.ipc.org/committee/drafts/4-33a_d_J709PSB.zip

21 day JEDEC ballot / comment period ended 23 Feb 2009

30 day IPC balloting / comment period ended 1 March 2009

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Key features

Single class definition BFR/CFR/PVC onlyNot all Br and Cl compounds

Definition based on plastics in component Threshold levels 1000ppm

Elemental, but only if source is BFR/CFR/PVC

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DEFINITION

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Compromised Component DefinitionA Component must meet all of the following requirements to be defined

as “BFR/CFR and PVC-Free”:1. All Printed Board (PB) and substrate laminates shall meet Br and Cl

requirements for low halogen as defined in IPC-4101B. Printed Board (PB) and substrate laminates do not include the solder mask . Solder mask is considered a plastic material (Section 2 below).

2. For components other than Printed Board (PB) and Substrate laminates: Each plastic within the component contains < 1000 ppm (0.1%) of

Bromine [if the Bromine (Br) source is from BFRs] and < 1000 ppm (0.1%) of Chlorine [if the Chlorine (Cl) source is from CFRs, PVC or PVC congeners].

Higher concentrations of Br and Cl are allowed in plastics of components other than Printed Board (PB) and Substrate laminates as long as their sources are not BFRs, CFRs, PVC or PVC congeners.

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4-33a Subcommittee Update

Purpose of standard Status of standard Key features of current draft

Modified component definition Thresholds Testing

Deadlines for commenting and voting

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Good Aspects of the Compromise

1. Component definition

2. Allows many components to declare compliance by design (if no plastics are present, part is compliant, like MLCC)

3. Has the good features of homogenous material, but focuses on likely locations of BFR/CFR/PVC

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Outstanding issue with compromise

Still may be difficult to test each plastic in certain parts

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THRESHOLDS

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Survey 1 - 900 ppm vs. 1000 ppm threshold

Since 63.5% Respondents Support the 1,000ppm Threshold Limit, the Definition in the Standard Will be Based on 1,000ppm

TESTING

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Analysis and Testing No specified/required analytical techniques Definition in Section 5 specifically says:

Although the elemental analysis for Br and Cl can be performed by any analytical method with sufficient sensitivity and selectivity, the presence or absence of BFRs, CFRs, PVC and PVC congeners must be verified by any acceptable analytical techniques and/or material declaration that allow for the unequivocal identification of the specific Br or Cl compounds, or by appropriate material declarations agreed to between customer and supplier.

Section 6 gives more detail on test approach

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Contact InformationStephen TisdaleIntel Corporation5000 W. Chandler Blvd.CH5 – 155Chandler, AZ 85226Phone : 480-554-4234Email : [email protected]

Scott O’ConnellDell IncOne Dell WayMS: 6630Round Rock, TX 78682Phone: 512-723-2512Email: [email protected]

Fern AbramsIPC1901 N Moore Street, Suite 600Arlington, VA 22209Phone: 703-522-0225Email : [email protected]