Restriction of Hazardous Substances in Medical Devices WHITE … · 2015-09-30 · Overview of RoHS...
Transcript of Restriction of Hazardous Substances in Medical Devices WHITE … · 2015-09-30 · Overview of RoHS...
Big Data Analytics In M2M
WHITE PAPER
Restriction of Hazardous Substances in
Medical Devices
Big Data Analytics In M2M
WHITE PAPER
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Table of Contents
Abstract ............................................................................................. 3
Abbreviations .................................................................................... 4
Overview of RoHS ............................................................................. 5
Uses of RoHS Substances .................................................................. 6
Environmental Effects of RoHS Substances ...................................... 6
Implications from RoHS .................................................................... 8
Benefits of RoHS Implementation .................................................... 9
HCL’s Business Model Support to Industries .................................. 80
References ...................................................................................... 11
Author Info ...................................................................................... 11
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Abstract
Medical devices, medical equipment, and many electronic products are a complex mix of various
components made up of heavy metals and dangerous chemicals. These chemicals and heavy metals
have adverse effects on human health, like cancer, kidney damage, increase in blood toxic levels, and
more. They also affect the environment with air pollution, water pollution, food contamination, etc. In
order to prevent this, the European Commission implemented the RoHS Directive.
EU RoHS Directives
RoHS I - 2002/95/EC (Came into force 1st July 2006)
RoHS II- 2011/65/EU (Came into force 2nd Jan 2013)
The RoHS Directive restricts the use of certain hazardous substances in medical, electrical, and
electronic products. RoHS has environmental benefits but may result in high compliance costs which
could affect the healthcare industry. Products that do not comply could be removed from the market
within the EU.
Deadline according to RoHS II
Figure 1: Deadline according to RoHS II
Source: http://ec.europa.eu/environment/waste/rohs_eee/pdf/faq.pdf
This paper provides an overview of RoHS, the usage of RoHS substances in healthcare and the various
environmental effects of RoHS substances. It also covers the implications and the benefits of RoHS,
particularly for healthcare, and provides a brief solution through HCL’s business model for industries.
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Abbreviations Sl. no. Acronyms Full forms
1 RoHS Restriction of the use of certain Hazardous Substances
2 EEE Electrical and Electronic Equipment
3 EU European Union
4 IVD In Vitro Diagnostic medical devices
5 EC European Commissions
6 EEC European Economic Community
7 Ppm Parts per million
8 R&D Research and Development
9 REACH Registration, Evaluation, Authorization and Restriction of chemicals
Overview of RoHS RoHS mandates that medical devices, medical equipment, and EEE products must not contain more than
0.1% (except for cadmium which is limited to 0.01%) by weight of homogenous material of any of the
listed substances. Homogenous material denotes a material that cannot be mechanically disjointed into
different materials.
RoHS substances Threshold Limit
Lead (Pb) 0.1% by weight (1000 ppm) of homogeneous materials
Mercury (Hg) 0.1% by weight (1000 ppm) of homogeneous materials
Cadmium(Cd) 0.01% by weight (100 ppm) of homogeneous materials
Hexavalent chromium (Cr(VI)) 0.1% by weight (1000 ppm) of homogeneous materials
Polybrominated biphenyls (PBB) 0.1% by weight (1000 ppm) of homogeneous materials
Polybrominated diphenyl ethers (PBDE) 0.1% by weight (1000 ppm) of homogeneous materials
New proposed substances that are not in scope - as of now
• Hexabromocyclododecane (HBCDD)
• Bis (2- ethylhexyl) phthalate (DEHP)
• Butyl benzyl phthalate (BBP)
• Dibutyl phthalate (DBP)
When substances are present in quantities more than the threshold limit, the product will be marked as
non-compliant, unless there is an exemption available for the particular application. For some
applications, there are no suitable alternatives available, so exemptions were given under RoHS
directives. But exemptions have an expiry date. Active implantable medical devices are currently
excluded from the scope of RoHS, and may be included in the future.
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Uses of RoHS Substances
Substance Main Use in the Healthcare Industry
Lead
Lead in plating finishes and solder- X-ray, Ultrasound, MRI;
PVC stabilizer in medical tubing, ECG leadsets, cables and patient monitoring cables;
Anesthesia equipment
Cadmium
Cadmium pigments in ECG patient cables;
Flexible copper cadmium wire in Ultrasound equipment;
All diagnostic X-ray systems.
Mercury
Very high capacitance and loss measurement bridges
High frequency RF switches and relays in monitoring and control instruments;
reference electrodes
Hexavalent
Chromium
Alkali dispensers for in-situ production of photocathodes;
image intensifier tubes and assemblies;
All X-ray systems
PBB Flame retardant
PBDE Flame retardant
Environmental Effects of RoHS Substances The annual usage of RoHS substances in medical devices and in monitoring and control instruments is
listed.
Figure 2: Usage of RoHS Substances
Source: http://ec.europa.eu/environment/waste/weee/pdf/ia_report.pdf
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So, according to World Health Organization (WHO) and other surveys:
Source: http://www.who.int/en/
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Implications ofRoHS
Benefits of RoHS Implementation When the RoHS process is fully implemented, we can expect the following changes to happen.
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One of the surveys show that the usage of lead, cadmium and mercury has considerably reduced in the
EU, because of RoHS.
Figure 3: Percentage reduction in usage
Source: http://www.rsjtechnical.com/NewsRoHScost&benefit.htm
HCL’s Business Model Support to Industries This is mainly divided into 3 groups:
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1. Product Compliance Team
This team performs all RoHS compliance activities by themselves.
HCL’s Approach
Product code lifecycle analysis
Bill of materials analysis
Drawing analysis
Material weight calculation - substance level
Supplier material declaration
Compliance check
RoHS coding
Issuing compliance certificates
2. Compliance Support
This team supports the client’s compliance team in working with the supplier for material declaration.
HCL’s Approach
GAP analysis
Vendor / Manufacturer / Supplier interaction and follow-up
Compliance certificates collection
Verifying reports against regulatory standards / requirements
3. R&D Team
This team performs Design Review.
HCL’s Approach
Detailed analysis of product design and materials to reduce hazardous substance content
Identifying alternate materials
Performing change request activities
The flowchart below contains HCL’s detailed approach to RoHS.
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Figure 4: Approach to RoHS
Conclusion
RoHS regulations play an important role in encouraging the elimination of six hazardous substances.
Medical devices, medical equipment and EEE products need to comply with RoHS regulations
(2002/95/EC –RoHS I and RoHS II- 2011/65/EU –ROHS II). Hence, many organizations and institutions are
taking up RoHS initiatives and assisting OEMs in getting compliance certification for their products.
HCL believes in innovation and customer satisfaction, and has the ability to define more effective RoHS
regulation processes through its vast experience in supporting global organizations through
international standards, directives, and regulations. HCL can provide product, compliance, and R&D
support that helps in RoHS compliance, for healthcare product manufacturers.
Understanding that the intentions of RoHS are mainly to protect the environment and human health
from toxic, hazardous and dangerous substances, we can make this planet greener.
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References Official Journal of the European Union - Directive 2011/65/EU (recast) document-RoHS II
Directive 98/79/EC- In vitro diagnostic medical devices
Directive 93/42/EEC- Medical devices
www.ec.europa.eu
www.rsjtechnical.com
www.biois.com
www.export.gov
www.who.int
www.eucomed.org
Authors Info Glen Clifford Pereira
Glen has a Bachelor’s Degree in Mechanical Engineering from Don Bosco Institute of Technology
Bangalore, India (under VTU Belgaum). He has over 2 years of experience in Product Compliance and
Product Design in the Medical Devices domain.
Mathiyazhagan Muthusamy
Mathiyazhagan has a Master’s Degree in Applied Chemistry and Chemical Engineering. He has over 27
years of experience, of which he spent 18 years in the Medical Devices domain as the Quality Head, R&D,
the Quality Management Representative for US FDA-QSR, ISO 13485, MDD (CE Mark) and the Certified
Lead Auditor for the Quality Management System. He currently works in an engagement for a large
Medical Devices OEM across quality, design control, manufacturing, and sustaining services.
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