UL/CSA UPDATEINDUSTRY ISSUES – Environmental

CPSC Thursday – November 29, 2007Thursday – November 29, 2007

Omni La Mansion Del Rio HotelOmni La Mansion Del Rio Hotel

San Antonio, TexasSan Antonio, Texas

UL 5085UL 5085 CSA C22.2 No. 66.1-06CSA C22.2 No. 66.1-06 First EditionFirst Edition Binational StandardBinational Standard

Covers:Covers: Low Voltage Transformers –Low Voltage Transformers – Part 1: General RequirementsPart 1: General Requirements Part 2: General Purpose TransformersPart 2: General Purpose Transformers Part 3: Class 2 and Class 3 TransformersPart 3: Class 2 and Class 3 Transformers

The Standard covers:The Standard covers: Air-cooled transformers & reactors for general useAir-cooled transformers & reactors for general use General purpose autotransformersGeneral purpose autotransformers Ferroresonant transformersFerroresonant transformers Class 2 and Class 3 transformersClass 2 and Class 3 transformers Cord-connected transformersCord-connected transformers Transformers incorporating overcurrent or over-temperature Transformers incorporating overcurrent or over-temperature

protective devices, transient voltage surge protectors, or protective devices, transient voltage surge protectors, or capacitorscapacitors

Permanently-connected transformersPermanently-connected transformers

These standards were developed without the benefit of a formal These standards were developed without the benefit of a formal Technical Harmonization Committee (THC).  Technical Harmonization Committee (THC).  

However, binational harmonization is intended to be an industry-driven However, binational harmonization is intended to be an industry-driven effort.  In anticipation of the future maintenance of these standards (UL effort.  In anticipation of the future maintenance of these standards (UL has already received a proposal request for UL 5085-3), UL and CSA are has already received a proposal request for UL 5085-3), UL and CSA are in agreement that in keeping with current harmonization practices, a in agreement that in keeping with current harmonization practices, a THC should be established for this Standard.  THC should be established for this Standard.  

The THC would be charged with the review and resolution of proposals The THC would be charged with the review and resolution of proposals and comments received by the involved Standards Development and comments received by the involved Standards Development Organizations (SDOs), presently, UL and CSA.  It should also be noted Organizations (SDOs), presently, UL and CSA.  It should also be noted that this industry has agreed to a 3-year revision cycle. that this industry has agreed to a 3-year revision cycle.

UL and CSA would like to request TTA's UL and CSA would like to request TTA's participation as the THC Secretariat and to request participation as the THC Secretariat and to request TTA's help in identifying a representative of TTA's help in identifying a representative of industry to serve as the THC Chair.   industry to serve as the THC Chair.  

The THC Chair is responsible for organizing the The THC Chair is responsible for organizing the THC meetings and for the progression of the THC meetings and for the progression of the development of the harmonized standard. development of the harmonized standard.

The THC Secretariat is charged with issuing The THC Secretariat is charged with issuing agendas and meeting reports for the THC meetings; agendas and meeting reports for the THC meetings; collecting the THC comments and distributing them collecting the THC comments and distributing them to the THC for consideration; ensuring that the THC to the THC for consideration; ensuring that the THC provides a draft of the harmonized standard and provides a draft of the harmonized standard and rationales in accordance with established processes rationales in accordance with established processes and format, and providing copies of THC meeting and format, and providing copies of THC meeting agendas, reports, and draft standards to the agendas, reports, and draft standards to the Publication Coordinator. Publication Coordinator.

European RoHS Directive European RoHS Directive (2002/95/EC)(2002/95/EC)

Bill in place since 1st July 2006 Bill in place since 1st July 2006 ((Lead, mercury, Lead, mercury, cadmium, hexavalent chromium, PBBs, PBDEs)cadmium, hexavalent chromium, PBBs, PBDEs)

Surveillance has been light in the first year; will Surveillance has been light in the first year; will vary by country; More vendors asking for “proof”vary by country; More vendors asking for “proof”

Other countries/states considering legislation; Other countries/states considering legislation; CEA organizing trade associations to create a CEA organizing trade associations to create a framework for future materials legislationframework for future materials legislation

California RoHS (AB 48)California RoHS (AB 48) Bill AB 48 reintroduced to implement the EU’s Bill AB 48 reintroduced to implement the EU’s

RoHS DirectiveRoHS Directive Includes Transformers; passed the Assembly and Includes Transformers; passed the Assembly and

is in the Senate; still has cost concernsis in the Senate; still has cost concerns Effective Jan, 2010Effective Jan, 2010 Process to petition (DTSC) Department of Toxic Process to petition (DTSC) Department of Toxic

Substances Control for specific exemptionsSubstances Control for specific exemptions Current language will ban various materials Current language will ban various materials

mirroring the EU regulationsmirroring the EU regulations

New Work Item Proposal (NWIP)China RoHSChina RoHS EU restricted materials sold into China;EU restricted materials sold into China; After After

2008, products containing these will require 2008, products containing these will require certificationcertification

Product schedule will be published; Focus on Product schedule will be published; Focus on electronics, electrical components, transformers, electronics, electrical components, transformers, batteries, chargers and radio in scope (limited batteries, chargers and radio in scope (limited understanding – a dynamic situation)understanding – a dynamic situation)

Labelling requirements in place Jan 2007; Labelling requirements in place Jan 2007; green/orangegreen/orange

Committee Draft (CD)

E-WasteE-Waste States continuing toStates continuing to introduced legislation; introduced legislation;

Most electrical and electrical products, Most electrical and electrical products, including transformers are included in most including transformers are included in most legislationlegislation

Note – Important to monitor ‘Product Note – Important to monitor ‘Product take back’ at the state level as this is one of take back’ at the state level as this is one of the most likely types of legislation, aside the most likely types of legislation, aside from material restrictions to impact from material restrictions to impact transformers.transformers.

Committee Draft for Vote (CDV)

Energy Using Products (EuP)Energy Using Products (EuP) In development – expected late In development – expected late

2007/early 20082007/early 2008 Provides framework for “Eco” design Provides framework for “Eco” design

requirementsrequirements Covers energy efficiency and standby Covers energy efficiency and standby

losses including transformerslosses including transformers

Committee Draft for Vote (continued) Energy Using Products (EuP)Energy Using Products (EuP) Legislation could lead to mandatory Legislation could lead to mandatory

energy loss product declarationenergy loss product declaration Future - Unknown product implications Future - Unknown product implications

as standards are not yet developed to as standards are not yet developed to address Eco design; Likely that address Eco design; Likely that companies will need an “EMS” companies will need an “EMS” (Environmental management system) in (Environmental management system) in place to comply [ISO 14000]place to comply [ISO 14000]

Final Draft International Standard (FDIS)RRegistration, egistration, EEvaluation and valuation and AAuthorization uthorization

of of ChChemicals emicals (REACH Directive)(REACH Directive) European Chemical Policy European Chemical Policy In force June, 2007; First restrictions on usage In force June, 2007; First restrictions on usage

2009; minimum amounts for usage start to 2009; minimum amounts for usage start to reduce by 2011reduce by 2011

The administrative impact of this directive could The administrative impact of this directive could be much greater then RoHSbe much greater then RoHS

Cost and availability risks, and impact on Cost and availability risks, and impact on product design unknownproduct design unknown

RRegistration, egistration, EEvaluation and valuation and AAuthorization of uthorization of ChChemicals emicals (REACH Directive)(REACH Directive)

Need to identifyNeed to identify high concern materials, high concern materials, over life cycle, estimate volumes and over life cycle, estimate volumes and register if required register if required

Requires pre-registration of chemicals used, Requires pre-registration of chemicals used, prioritized by volume; Polymers exempt prioritized by volume; Polymers exempt

Systematic Review of International StandardsCarbon FootprintingCarbon Footprinting Measure the climate impact of a product, Measure the climate impact of a product,

organization, activity (meeting) or group of peopleorganization, activity (meeting) or group of people Carbon labels communicate the impact of a Carbon labels communicate the impact of a

product to customersproduct to customers Piloting on foods and pharmaceuticals in Europe; Piloting on foods and pharmaceuticals in Europe;

governments and retailers beginning to apply governments and retailers beginning to apply pressure to disclosepressure to disclose

Standards are being developed with social pressure Standards are being developed with social pressure against “abuse” e.g. patio heatersagainst “abuse” e.g. patio heaters

IEC General

Corporate Social Responsibility Corporate Social Responsibility (Sustainability)(Sustainability)

Three leg stool: Profits, people and the planetThree leg stool: Profits, people and the planet Business impactsBusiness impacts

Eco labelingEco labeling Investor proposalsInvestor proposals Toxic material concernsToxic material concerns Supplier controlsSupplier controls Green purchasingGreen purchasing Green buildingsGreen buildings

Future TrendsFuture Trends Climate change legislation Climate change legislation Green buildingGreen building Energy efficiencyEnergy efficiency Materials focusMaterials focus

Consumer Product Safety CommissionConsumer Product Safety Commission HR 4040 HR 4040 Federal Reports Elimination and Sunset Act of Federal Reports Elimination and Sunset Act of

1995 (three changes)1995 (three changes) Consumer Product Safety Act (50 changes)Consumer Product Safety Act (50 changes) the Federal Hazardous Substances Act (24 the Federal Hazardous Substances Act (24

changes)changes) Flammable Fabrics Act (five changes).Flammable Fabrics Act (five changes).

S 2045S 2045 Consumer Product Safety Act (75 changes)Consumer Product Safety Act (75 changes) Poison Prevention Packaging Act of 1970 (one Poison Prevention Packaging Act of 1970 (one

change)change) Federal Hazardous Substances Act (21 changes)Federal Hazardous Substances Act (21 changes) Flammable Fabrics Act (three changes)Flammable Fabrics Act (three changes) one change to 15 U.S.C. 2053one change to 15 U.S.C. 2053 three changes to 31 U.S.C. 1113three changes to 31 U.S.C. 1113

Increase the CPSC's authorized budget to $80 Increase the CPSC's authorized budget to $80 million in FY 2009, with 10 percentmillion in FY 2009, with 10 percent

Increases thereafter, until it reaches $141.7 million Increases thereafter, until it reaches $141.7 million in FY 2015 (FY 2007 budget was $62.7 million)in FY 2015 (FY 2007 budget was $62.7 million)

Increase staffing to 500 employees from 420Increase staffing to 500 employees from 420 Increase civil penalties for violations of the Increase civil penalties for violations of the

Consumer Product Safety Act (CPSA) from $5,000 Consumer Product Safety Act (CPSA) from $5,000 per violation to $250,000 per violation, capping at per violation to $250,000 per violation, capping at $100 million (currently capped at $1.25 million)$100 million (currently capped at $1.25 million)

Increase criminal penalties for knowingly Increase criminal penalties for knowingly violating the law to five years in prisonviolating the law to five years in prison

Require that CPSC enforce whistleblower Require that CPSC enforce whistleblower protections for employees of manufacturers protections for employees of manufacturers and importersand importers

Allow state attorneys general to bring civil Allow state attorneys general to bring civil suitssuits

Outlaw children's products containing leadOutlaw children's products containing lead

Make it illegal to sell recalled products;Make it illegal to sell recalled products; Specify consumer safety provisions for a Specify consumer safety provisions for a

variety of products, including all-terrain variety of products, including all-terrain vehicles and garage door openers; andvehicles and garage door openers; and

Provide whistleblower protections for Provide whistleblower protections for CPSC employees.CPSC employees.