Smiths continues to track and prepare for the introduction of new product based legislation, which is due to come into force in Europe during the next few years:

• Waste Electrical and Electronic Equipment (WEEE) Directive
• Restriction of Hazardous Substances (RoHS) Directive

WEEE Directive

In 2005, the WEEE Directive will become law within EU Member States, requiring the recovery and recycling of separately collected electronic and electrical equipment in specific product categories. The divestment of our domestic ventilation systems business in 2002 has significantly reduced our product take back liabilities under this legislation. Medical devices are also covered, although recovery and recycling targets will not apply to this equipment until 2008 at the earliest.

We continue to consult with the UK’s Department of Trade and Industry to clarify the scope of the Directive’s ‘monitoring and control instruments’ category. Whilst we believe that our aircraft instruments will not be covered, we await clarification of the exemptions for monitoring instruments.

RoHS Directive

The RoHS Directive will ban the use of cadmium, mercury, lead, hexavalent chromium and certain brominated flame retardants in specific categories of electronic and electrical equipment from July 2006. These bans exclude medical devices and monitoring and control instruments until 2008 at the earliest. Products used solely for military and national security applications will be exempt from both WEEE and RoHS.

Lead Free Solder

Legislation and market pressures will force many electronics and electrical manufacturers to change from the lead based solder alloys they have been using for more than 50 years, to lead free alloys that may have an adverse impact on the reliability of long life and safety critical components and systems.

As a result, lead free solder sets a particular challenge for those Smiths products that have high integrity, safety critical and long life applications, such as those used on aircraft. Lead free solders such as Tin Copper Silver remain untested and unvalidated in highly regulated environments and lead continues to be used as the main solder element throughout the Group whilst research is undertaken into alternatives. Boeing has specifically required that lead solder continue to be used for equipment supplied on its current aircraft. Lead solder may also continue to be used on the JSF/F-35 programme.

Hazardous Materials Replacement on JSF/F-35
The F-35 will be the highest volume fighter jet in production worldwide, incorporating many Smiths systems from power management to actuation and microwave cabling. The programme has a list of prohibited substances and a list of restricted materials that may not be supplied without prior approval through Lockheed Martin. The restricted materials list includes cadmium and chromium used for plating and lead compounds - except solder - and beryllium used in connectors. We are working with Lockheed Martin and other programme partners to replace restricted materials with commercially available alternatives.

Life Cycle Assessment

Some customers have told us they would like to see Life Cycle Assessment techniques applied to our products. This is a significant challenge given the diversity of our product range but we have taken some first steps to help us evaluate the appropriate techniques for our types of products. We will also participate in the product technical panel of the UK Environment Agency’s electronic Life Cycle Assessment project (eLCA), which aims to develop web-based LCAs, eco-design tools and training materials to help produce more environmentally sound products. Polyphaser (Specialty Engineering) is the first of our businesses to embark on a product life cycle assessment study.

Polyphaser: First Mover on LCA

Polyphaser (Specialty Engineering) manufactures interconnect products at its facility in Minden, Nevada in the USA. As part of its ISO 14001 programme, the business is using a simple LCA methodology to help in: materials selection; assessing impacts from raw materials and assembly operations; and assessing impacts from the installation, use and disposal of the product, including providing product end-of-life recommendations. We await the completion of the project to determine what lessons there are for wider dissemination across Smiths.