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Enviromental Issues Facing the Metal Finishing Industry For decades the powder coating industry has experienced growth fueled in part by the global focus on environmental health and by the economics and superiority of the powder finishing process. As an air quality compliant alternative to conventional painting, thousands of companies have converted their old solvent-based paint lines to powder coating. Either by choice or by force, these companies have evolved as a result of some kind of legislative action targeting the environment. The metal finishing industry as a whole faces diverse environmental issues in the wake of a variety of worldwide legislative measures seeking to reduce the environmental impact of vehicle and electronic products and their manufacturing processes. A growing number of nations and states have passed or are considering legislation and regulations, which would severely impact the ability of the automotive and electronics industries to ship and sell products globally. At face value, the purpose and scope of the overall goal is to proactively develop programs to reduce the environmental impacts of these products and manufacturing processes throughout their entire life cycles—from design through use to end of life. European Union directives In an effort to minimize the risks and the impact on the environment and human health, the European Union (EU) has passed new directives and legislation restricting the use of hazardous substances, including use, treatment, and disposal of waste electronic equipment and automobiles. The legislation will affect all companies that use electronics in their products. Affected products include household appliances, information technology (IT) and communications equipment, lighting, electrical and electronic equipment, automobiles, toys, and sports equipment among others. Countries exporting electronics, vehicles, and IT hardware products to the EU may have their products rejected if they do not comply with the standards. Many leading automotive and electronics component manufacturers have already started modifying their processes to manufacture lead-free and hazardous-materials-free products. Manufacturers of products that are distributed globally are now faced with the financial and legal realities of adapting to “green” technologies. Many large manufacturing companies that outsource metal finishing directly or indirectly are now requiring certification of compliance to environmental regulations and requirements. Large high-volume custom coating companies that support manufacturers of products must be aware of these new requirements. Custom coaters generally have a very diverse customer base that is a typically a mix of manufacturing companies such as automotive, appliance, gaming equipment, lawn and garden, architectural, electrical enclosures, lighting and electrical products, and general metals applications.  Many of these customers are asking their raw metal suppliers as well as their metal finishing suppliers to formally address the issues of WEEE, RoHS, and ELV compliance. Briefly, these acronyms mean the following: • WEEE (Waste Electrical and Electronic Equipment) was introduced in 1998 by the EU as a directive (law) that banned the selling, importing, or both of all electronic/electrical equipment containing lead and other heavy metals by Jan. 1, 2004. WEEE is one of the largest known sources of heavy metals and pollutants in the waste stream. The producer (the original equipment manufacturer, or OEM, whose name is on the product) will be responsible for recycling the product at the end of its service life. • RoHS (Restriction of Hazardous Substances) is an EU initiative adopted on June 13, 2000, to ban six hazardous materials from electronic products by July 1, 2006. The materials are cadmium (Cd), mercury (Hg), hexavalent chromium (Cr [VI]), polybrominated biphenyl (PBB) and polybrominated diphenyl ether (PBDE), and lead (Pb). Products sold in the EU after July 2006 must contain less than a maximum concentration value of 0.1 percent by weight in homogeneous materials for Pb, Hg, Cr (VI), PBB, and PBDE. The maximum concentration value for Cd is 0.01 percent by weight.  ELV (End of Life Vehicles) was passed into European law in October 2000. It’s aimed at the prevention of waste from vehicles and at the reuse, recycling, and other forms of recovery of end-of-life vehicles and their components to reduce the disposal of waste in the EU. This directive only applies to automotive vehicles, including their components and materials. An example. Without getting into too much detail, here is an example. Approximately 76 percent by weight of the average car is metal, most of which is comprised of sheet steel. The overall metal content of cars has declined rapidly during the past 20 years accompanied by an increase in the proportion of nonferrous metals used in their manufacture, such as aluminum and magnesium. Currently, about 98 percent of the metals in a car are recycled. Or shall I say downcycled. Don’t bother looking up the word, downcycling is a new word for the recovery of a tangible material for reuse in an application requiring a lower level of quality. For example, metals are recovered by the vehicle dismantling industry and subsequently used by the steel industry and re-smelting plants for applications such as steel reinforcing bars for concrete. From the carcass of an unwanted vehicle, a mass of metals, fluids, plastics, and rubber products can be separated for recycling purposes. This cradle-to-cradle philosophy is a far cry from the cradle-to-grave mentality that so many of us have grown to accept. As Albert Einstein observed, if we are to solve the problems that plague us, our thinking must evolve beyond the level we were using when we created those problems in the first place. So why should we as metal finishers be concerned? Recycling is a good thing isn’t it? The fact is there are problems to the seemingly simple solution of eliminating the “bad stuff” in raw materials and finishing processes. The elimination of lead, cadmium, hexavalent chromium, and other constituents that make up alloys of metals, and that may be found in diminutive proportions in coatings and conversion coating formulations, may result in problems that would adversely change the quality and performance of the end product. Recently, numerous powder coating companies have discovered that some of the so-called RoHS compliant ferrous metal alternative alloys don’t produce the favorable reaction to the conventional phosphate pretreatment process as the traditional ferrous metal alloys do. Adhesion of the organic coating to this new metal substrate has proved to be problematic. In some extreme cases, the compliant metal surface must be physically abraded by sanding, grinding, or abrasive blasting to achieve the necessary bonding characteristics that are required of the organic coating. As a result of a seemingly simple change in metal alloy formulation, the cost of finishing skyrockets. The financial chain reaction that occurs can be devastating. If the adhesion problems aren’t caught early enough by in-process testing, the cumulative losses of field failures can result in millions of dollars of liability, a complete recall of the manufactured product, or both. This is a prime example of regulation slowing down commerce. For example, a US manufacturer might spend more money to provide an improved product that is compliant under current regulations to meet the European directive, but its local commercial customers, who want products quickly and cheaply, may be unwilling to absorb the additional cost of compliance. They may then find what they need elsewhere, perhaps offshore, where regulations are less stringent. Business today is a day-to-day instant exchange of value. The driving force of the urgency within this exchange is currency, not compliance.  Unless there is a real and credible threat of products being banned, the manufacturing companies that are first to become compliant may realize that they become the financially disadvantaged. As a custom coating job-shop owner, I hear fabrication customers complaining constantly about of the unfair advantages that countries like China, Korea, and Mexico have over us here in the US.  I hear of the advantages that other countries have of low-cost labor and a seemingly blatant disregard for the ecology of the planet. Where and when will it ever stop? Will other countries be forced to produce products that are free of these constituents that are so unfriendly to recycling or downcycling? Or will the US continue to be held to a higher standard at a cost that few can afford? The inevitable question must be asked: At what point will all countries that manufacture globally distributed products make them from recycling compliant materials of same or similar quality? I feel it necessary to share the following story. In the third quarter of 2003, our company was under close observation for a mysterious problem that was causing what was described as premature coating adhesion field failures. Our customer at the time sold high volumes of outdoor lawn and garden products that were cast from what they believed to be a specific high quality cast aluminum alloy that was recommended for exterior weatherability. The customer recently had changed from a casting supplier in the US to a casting supplier in China that was offering a substantial reduction in price. As we methodically hammered our way through a lengthy and costly root-cause analysis, we discovered that the alloy was nowhere near the quality that was originally specified and deemed appropriate for exterior use.  The problem took months to resolve and tens of thousands of dollars to correct. The lesson that was learned is “you get what you pay for! To that end, it’s my belief that you get what you plan for as well! Rest assured that what’s happening in the European community will soon influence what we’re doing here to one degree or another. Our industry will continue to be affected by changes in the global focus of our economy and ecology. The science, chemistry, and technological aspects of our industry will continue to be challenges as we address future environmental and economic issues of concern. Yesterday, it was the alleged triglycidyl isocyanurate (TGIC) toxicity issue and employee exposure threat that consumed so much of our time, money, and effort. Today, the screws are getting tighter as the world is looking for ways to regulate industry to solve the complex problems of the planet. Will these European directives influence the manufacturing companies of Asia, Mexico, or other countries at all? Who knows? I do know that many large US manufacturing companies are taking these issues very seriously. The rules of the global manufacturing game keep changing, and futuristic companies need to learn to adapt to these changes. A company is said to be either growing or dying. There is no static state in business. We don’t mean to downplay those who are working with good intentions to create and enforce laws meant to protect the environment.  I share with you this profound statement of political wisdom: “Ultimately, a regulation is a signal of design failure,” author unknown. As finishing professionals, job-shops everywhere need to stay in the know regarding these and other upcoming regulations, directives, limitations, restrictions, and requirements.                                 Author: Michael W. Cravens Presidient, IKON Powder Coating, Inc CEO, Powder Finishing Consultants, Inc Copyright 2006  
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