Published in November 2007

Environmental Directives
By Jon Melchin, CSI

What they mean to the US construction market.

The Boston Children’s Museum, designed by architectural firm Cambridge 7 Associates, is LEED certified and incorporates environmentally friendly features as an integral part of the design.

Editor’s Note: In September 2006, Scott Fehl reported for us about “RoHS Compliance.” Here, Jon Melchin, CSI, offers additional information about that, and related initiatives.

    The booming construction market in the United States has spawned an increased awareness of the built environment’s ecological impact. With an estimated 118 billion buildings in the States by 2010, there has been widespread adoption by the architectural community, building owners and design/construction professionals of initiatives producing structures with minimal negative impact on public health and the environment.
    Perceptive designers are always looking for products or technologies that, when used appropriately, can contribute to a project’s sustainability. Perhaps more significantly, there has been a tremendous amount of recent media attention drawn to environmental issues, such as global warming and pollution, that has engaged both governmental entities and the general public. The US Green Building Council’s (USGBC) Leadership in Energy and Environmental Design (LEED) program, and other such rating/certification systems, has created specification guidelines on which designers can focus to achieve green initiatives.
    Lowering effects on the environment, maximizing energy efficiency and conserving natural resources are all major aspects of LEED. In one category, Materials and Resources (MR) Credit 4, Recycled Content, LEED allows up to two points for products made with pre- and post-consumer materials. However, the rating system does not yet have a credit for specifying products that have reduced environmental impact during manufacture and/or are easily recycled at the end of their useful life. Although recycling has been mainstream for decades, these other attributes are still important aspects of sustainability.
    A development making its way onto the environmentally conscious scene could help bring them to the forefront. The Restriction of Hazardous Substances (RoHS) directive was established by the European Union (EU) and went into effect in July 2006. (It is important to note that it is not a law but, rather, a popular guideline.) Although it is still under the radar of many “green” specialists in North America, RoHS could soon have substantial impact on the way products are selected for sustainable projects.1

Directive Details
    RoHS traces its beginning back to 2003, when the European Union’s 25 member states first adopted this directive. Research conducted by the EU’s environmental collaborative in the late 1990s revealed large amounts of hazardous waste were being dumped into landfills across Western Europe. This would lead directly to RoHS.
    This directive drastically reduces the permitted amounts of six hazardous materials in the manufacture of various types of electronic and electrical equipment, with the maximum concentration levels not to exceed 0.1% by weight per substance. The targeted substances include:
•  Lead and Mercury, often found in electronic and electrical equipment;
•  Cadmium, found in certain types of batteries and used in the production of electronic circuit boards;
•  Hexavalent Chromium, compounds exist in chromate pigments for dyes, paints, primers and other decorative/protective coatings; and
•  Polybrominated Biphenyls (PBB) and Polybrominated Diphenyl Ether (PBDE), used as flame retardants in some plastics. WEEE Initiative
    Another recent EU environmental initiative is the directive of Waste Electrical and Electronic Equipment (WEEE), which took effect in August 2005. Similar in many respects to RoHS, it is designed to minimize the waste stream of electrical and electronic equipment, complementing EU measures on landfill and waste incineration.
    Trends in electronics waste generation suggest that increased technological change and decreasing chip costs are driving the development of new products, along with accelerating the obsolescence rates of older ones. WEEE emphasizes the need for recycling these end-of-life products. The directive imposes the responsibility for the ecological disposal or reuse/refurbishment of such equipment on the manufacturer. (In the US, the Environmental Protection Agency (EPA) reports that most states and local municipalities participate in various similar “e-cycling” programs.)
    Trends suggested that the toxic waste stream would only escalate, creating a massive, growing source of contamination. This caused the European Union to take measures to clamp down on these hazardous substances. Although compliance is widespread, each EU member state can adopt its own enforcement and implementation policies using the directive as a guide. Therefore, there could be many different versions of the directive in use throughout Europe.
    At the end of February 2006, China instituted a similar law, entitled Administration on the Control of Pollution Caused by Electronic Information Products. This has the same goal as the EU’s RoHS; in fact, it is referred to commonly as “China RoHS.” One of the important similarities between the EU’s directive and China’s RoHS law is the list of substances that are restricted.

Coming To America
    Japan, South Korea, Taiwan and Australia have adopted, or are poised to adopt, similar restrictions on electronic and electrical components. So far, neither the United States nor Canada has enacted any national RoHS- or WEEE-type regulations, but individual Canadian provinces (e.g. Alberta, Nova Scotia and Saskatch-ewan) and nearly 30 states have begun introducing similar rules for their own jurisdictions.
    In addition to Maine, Maryland and Washington, RoHS-like restrictions have had significant impact in the State of California. The California law, which took effect in January 2007, differs slightly from the EU directive. It applies to “covered electronic devices,” such as televisions, laptops, cathode ray tube (CRT) monitors, plasma screens and DVD players with liquid crystal display (LCD) screens. Further, it only restricts four out of the six substances singled out by the European RoHS: lead, mercury, cadmium and hexavalent chromium.
    California’s RoHS law prohibits the sale of any electronic device that does not minimize the restricted substances to accepted levels. (Years earlier, in September 2003, the Golden State adopted the SB-20 regulation, which is similar to WEEE in that it refers to the end-of-life handling of some electronic components.)

Building Environment Hazards
    Today’s construction and retrofit projects incorporate an evolving variety of new products that facilitate green design efforts and sustainability. Information technology, audiovisual, security and communication systems are prevalent in virtually every building, and often are considered fundamental within the built environment. These various components are selected and specified with occupational health, safety and productivity in mind, and are implemented into a design where people can thrive, and building performance is achieved in the most environmentally responsible way possible.
    As RoHS-like rules become more mainstream in the United States, the impact of this globally instituted directive can be of significant importance. The RoHS directive includes the restriction of one or more of the six banned EU substances from the following:
•  large appliances (plasma screens, LCD panels and CRT monitors),
•  small household appliances (DVD and VHS players),
•  information technology (IT) and telecommunication equipment,
•  consumer equipment,
•  lighting and lighting equipment,
•  electrical and electronic tools,
•  electric light bulbs and luminaries.
    Architects, engineers and interior designers all routinely specify many of the referenced products when creating a space, especially those involving learning or multimedia communications.
    Personal, mainframe and laptop computers, along with telephones, fax machines, copying equipment, video cameras, and various audiovisual and electronic signal processing equipment fall into RoHS’ targeted categories.

Known as WEEE Man, this sculpture was created by London’s Royal Society of Arts using 3.7 tons of electrical and electronic waste products.

Paving The Way For These Initiatives
    Now that California is paving the way for these initiatives here at home, the design community, building owners, developers, product manufacturers and government agencies must acknowledge the European restrictions’ impact. With more states proposing similar regulations, it will be challenging to keep up to speed with the various changes and exceptions to the original directive.
    As mentioned, California’s RoHS law focuses on covered electronic devices. However, the EU version applies to the larger category of “electrical and electronic equipment,” which is defined, in part, as equipment that is dependent on electric currents or electromagnetic fields in order to work properly, and equipment for the generation, transfer and measurement of such currents and fields....
    Tremendous amounts of toxic materials from these common electronic components are being dumped into landfills across the US and many other countries. In an effort to emphasize the ecological impact of these hazardous substances, the United Kingdom’s Royal Society of Arts, in conjunction with a major electronics manufacturer, created a sculpture 7 meters (23 feet) tall constructed from 3.3 tonnes UK (3.7 tons) of electrical goods, the average amount of electrical waste one British citizen creates in a lifetime. The giant figure, known as the WEEE Man, was erected on London’s South Bank in 2005.

RoHS Compliance
    Found in virtually all buildings, products containing circuit boards and electronic components are impacted profoundly by RoHS and similar regulations. For example, environmental issues in the audiovisual industry are particularly broad. It staggers the imagination to consider the amount of electronic equipment requiring batteries, large and small, that can be impacted by RoHS.     In California, AA, AAA and nine-volt batteries all have to be shipped to a state-licensed recycling center; simply discarding them is no longer an option.
    Lead solder is used widely in electronic circuitry, but current RoHS regulations restrict that process. This is a big concern for many manufacturers because using a lead-free process requires the purchase and installation of new assembly lines, new equipment, and additional personnel and training.
    Although some companies are holding off as long as possible to become compliant, others realize that RoHS eventually will impact their business. In addition to following lead-free processing requirements, this might mean using increased recycled content for products. Having a higher recycled content actually can be more expensive than employing raw materials; this adds to the initial costs of being environmentally responsible.

    RoHS’ ramifications are having a ripple effect throughout the electronics industry. Various components of electronic goods are purchased from suppliers that may not be compliant, which profoundly affects manufacturers of electronic products that are moving toward compliance as these environment regulations become increasingly prevalent.
    Some multidisciplinary architectural firms offer audiovisual and technology consultation in addition to planning, interiors, landscape and other aspects of design. RTKL, a Baltimore MD-based architectural firm with locations across the country, is bracing itself for the RoHS impact. Tony Warner, who heads up RTKL’s Technology Division, is preparing for regulation enforcement.
    “Although our involvement has been minimal on the audiovisual front overseas, where RoHS has had the biggest impact, we have not felt much of its influence here to date,” he said. “However, given its recent adoption in California, we fully expect to be dealing with this domestically in the immediate future and have been watching developments with a critical eye.”

    Many specifiers and their clients are interested in designing sustainable, high-performance buildings with a long-term lifecycle in mind.2 Green initiatives in today’s new buildings, along with the environmental impact of the growing built environment, means that a variety of ecological solutions should be embraced by the design/construction community.
    Interest in LEED certification continues to be a hot trend. Although, currently, no points are awarded for designs using RoHS-compliant products, a credit under the Materials and Resources category could be a natural fit for future versions of the rating system. Designing for tomorrow should be a primary goal for savvy builders.
    In one form or another, the Restriction of Hazardous Substances directive will soon spread across the US. Although some may be reluctant to accept this, the ecological implications of these regulations can only be positive and beneficial.


Building Product Manufacturers
    Building product manufacturers provide materials vital to the structural scope of a building, as well as components critical to the project’s performance and sustainability. These products can greatly benefit the health, safety and productivity of a building’s occupants, as well.
    Manufacturers’ interest in recognizing the importance of the growing RoHS initiatives is twofold. Not only do they need to be aware of the impact in the United States, but they must also pay close attention to changes occurring in Europe, China, Japan and other regions embracing RoHS. Any product entering the European Union must be in compliance, and myriad US manufacturers have products made in part, or entirely, in China.
    If a product is being marketed in Europe, it is impacted by RoHS. For some manufacturers, Europe is an important and growing market, so compliance with the directive is considered a worthy strategic investment. Sales objectives for many companies could have major financial implications essential to technology business competitiveness.


1. Although there is no national equivalent to RoHS in the United States, the EPA has regulations that focus on hazardous waste management standards for federally designated “universal wastes,” which include pesticides, lamps, batteries and mercury-containing equipment. The regulations affect the collection and/or recycling of these wastes. However, the Restriction of Hazardous Substances directive goes a step further by reducing the hazardous materials during the manufacturing process.
2. For additional information about RoHS, visit, and

Jon Melchin, CSI, is the architectural development manager for FSR and works exclusively in support of architects, engineers and interior designers, facilitating the specification of RoHS-compliant FSR products. He is a frequent contributor to various trade publications and conducts American Institute of Architects (AIA)-related professional development courses. Reach him at

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