“We focus on products that are safe for environment”


TÜV Rheinland is a global provider of testing, inspection and certification services. Founded in 1872, the company has its headquarters in Cologne, Germany employing more than 16,000 people in 500 locations in 65 countries. The Group’s mission and guiding principle is to achieve sustained development of safety and quality in order to meet the challenges arising from the interaction between man, technology and the environment.

Shanmuga Sundaram, country head–material testing laboratories, TUV Rheinland India spoke to Ashwin Gopinath of EFY about TUV’s operations in India and future plans.

Shanmuga Sundaram

Q. Could you start by giving us an overview of TUV India?
A. TUV Rheinland is a Germany-based notified body. We are extensively involved in 6 major different activities, which include industry service, mobility, product safety and quality, training and consultancy, health care and system certifications. Our industry service departments are extensively involved in third-party inspections, material characterisations, pressure equipment directives compliance and certifications. From a mobility point of view, we certify cars for their safety.

TUV is involved in Testing Inspection and Certification (TIC). We evaluate men, machine, material and methodology and certify them. We even certify the organisations against various international standards, which include ISO 9001 for system level compliance – quality management system (QMS), ISO 14000 for environmental compliance, ISO 22000 for food safety, ISO 27000 for information security.

Q. Could you tell us about any on-going projects of TUV?
A. The project DG-HSPM (Hazardous Substance Process Management Standard), which is a part of our Corporate Social Responsibility (CSR) activity, is a partnership program funded by DEG Industrial Bank in Germany. The aim of this project is to help the electrical and electronic equipment manufacturing industry in India to comply with a new standard called HSPM Standard. In other terms, the standard can be identified as ICQ HSPM QCO 80000.

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Q. Could you elaborate on the challenges of working with environmental directives for foreign markets?
A. Today if you are looking to enter the European market, you need to comply with certain environmental directives. These environmental directives look to safeguard the safety of the environment and of the people. So all along, we not only concentrate on producing a quality product but a very important criterion is that it shouldn’t be unsafe to the people and the environment. In other words, every product you manufacture should be free from certain identified hazardous substances and the product should be designed in such a way that even after the life cycle gets over, it should be easily recyclable or recycling activity friendly.

This environmental directive is called WEEE (Waste Electrical Electronic Equipment) Directive. It clearly indicates RRR (Recovery Recycling Ratios) which is very important. After the usage, the product should be re-cyclic friendly and easily dismantled. Even if it is recycled, you should be in a position to recover more material out of that and if material recovery is not possible you need to have a better energy recovery out of that. After material & energy recovery, the left overs going for land fill should not contain any hazardous substance in it. In simpler terms, your product should be free from hazardous substances, environmental friendly, and a green product.

So this particular project helps these industries to meet new environmental directives in Europe, which is called ROHS (Restriction of Hazardous Substance). This particular directive can be identified with a specific European Directive Number 2002/95/EC.

Q. Could you give us more insights on the ROHS Directive and how this project benefits the industries?
A. This particular directive talks about the restriction of 6 hazardous substances, which includes Lead, Mercury, Cadmium, Hexavalent chromium, Polybrominated biphenyl (PBB) and Polybrominated diethyl ethers. All these 6 substances have to be restricted and at the moment, the directive is applicable only in Europe.

Even India has introduced India-specific ROHS Regulation known as Indian ROHS. Already the legislation is in force. So all the electronic component manufacturers in India with certain categories will have an obligation to meet this hazardous substance level by May, 2014 i.e. they have to control the hazardous substance even if electronic manufacturing industries are either exporting to Europe or operating domestically. Our idea is to help them meet this new environmental initiative. So this project ensures that they meet this hazardous substance requirement not only on a product level but also raw materials, intermittent products and process chemicals.

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So, the new standards are the IECQ HSPM 80000 or IECQ HSPM QCO 80000. This particular standard is an ideal approach for the industry to adopt a system level compliance. ROHS works on the product level and this particular initiative will help them to meet this new standard and this industry will have a complete know-how about this standard out of this project. We have selected 10 SMEs (Small and Medium Enterprises) in and around Bengaluru and Hosur and these industries participated in this project. People from these industries are completely trained by our experts and get a qualification of an Internal Auditor. We train them thoroughly and with this they build the in-house capacity. We also consulted them and helped them identify what is the gap they have with their existing system.

Q. What are the criteria for these SMEs to participate in this project?
A. Basically the 2 important criteria are, firstly, the organisation should deal with electrical or electronic equipment or they can be one of the suppliers to these equipment industries. Secondly, the SMEs must have an ISO 9000, a basic quality management system. Based on that out of the 15 companies that participated in the beginning, we have selected 10 companies.

Q. Could you brief us on the training given to the selected SMEs?
A. These 10 identified SMEs deputed their team members whom we trained with our experts from US and Taiwan, transferred our know-how and developed them as Internal Auditors to implement QCO 80000. Moreover, we provided adequate documents for putting tools and consulting all the activities that were carried out with their team members and conducted GAP assessment audit at all these 10 SMEs. In addition, we identified the gaps and supported them on how they can fill these gaps, and gave them a long enough time line and the project went on for almost 14 months.

During these 14 months, these industries completely transferred themselves from existing level to a HSPM Compliance Level. We conducted the final assessment audit and out of these 10 companies, 7 companies were completely qualified with HSPM and we are going to certify these companies in our final forum called Best Practice Exchange Forum. We are going to invite all these 10 companies and issue a TUV Rheinland Specific Certificate which clearly talks about their HSPM Compliance and whatever the best practices done at their level. At the moment this project is India-specific project but once these industries have implemented and transferred completely in a long run, they can even go for an integrated management system type of approach. The IECQ is still working as a very new concept in India but many industries are facing a problem to switch over from existing lead technology to lead-free technology. This is the reason I told you that out of 10 companies, only 7 companies completely were qualified out of this project. To ensure the sustainability we will also support this industry with all the know-hows and if necessary we will also do the future assessment and audit. At this moment this project is purely part of our Corporate Social Responsibility.

Q. Is HSPM compulsory in India yet?
A. HSPM, even across the globe, is not compulsory but it will help you to meet some compulsory regulation in Europe.

Q. So does that mean that if you don’t have HSPM in Europe, you probably would not be able to operate?
A. That’s very correct. In China, 1500 companies have already gotten a certification. It is very active in Taiwan, the whole of Europe and the US because all these countries already have their restriction of hazardous substances related regulations. In India, it started in May 2012. Of course, there is a 2 year transition period but by May 2014, certain electronic component manufacturing industries will have a specific obligation to control these hazardous substances. So this standard in a long or short run will help the Indian Electronic Component Manufacturing Industry to control the hazardous substances.

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Q. What would companies do who already have an ISO 9001?
A. The idea is that, at the moment, most of these companies are either ISO 9000 certified or 14000 certified or may be even 27000 certified, but this particular standard will help them to control the hazardous substances. So their quality, policy, management, objectives, communications and management representatives will also have a specific method to control the hazardous substances. They even have to plan the hazardous substance assessment and control it at a regular interval. So the entire activity of the organisation will ensure the HSPM is implemented thoroughly. That is the reason this standard works on top of ISO 9001. So most of the clauses in ISO 9001 are common here in QCO 80000. But this will be a very new approach in India.

It is not practically possible to analyse every product or sample. It is time consuming and a lot of capital is needed. Instead, a system level approach where the system will not allow to process or procure any of the hazardous substance material is the ideal situation. So this standard will help the industries to transfer from the existing level to that of a particular hazardous substance-free level.

Q. Could you tell us about what kind of clients do you have?
A. Basically we do not use the term ‘clients’. They are either participants or a beneficiary industry. I can name some of the beneficiary industries like EXA Thermometrics, TTK Prestige, Optocircuits, Magnatech, KHMDL and so on.

Q. Does TUV also test equipment?
A. Yes. We test the instruments for its safety and Quality. We also test the raw materials and Bill of materials (BOM) for their compliance. We have a material testing laboratory in Bengaluru where we test the ROHS and we also have NABL accreditation to do these tests. Ours is the first laboratory in India where we can handle all the hazardous substance directives which include ROHS, REACH, ELV and Packaging directive. Ours is the first Laboratory in India to get all these accreditations together. We are also doing the next level of activity to sustain the ROHS free level or the ROHS material.

Q. Which, according to you, is the most extensively used hazardous substance?
A. If you consider the electronics industry, one of the hazardous substances like lead is extensively used. Today lead-based solders are extensively used in the electronic industry. When the industries are switching over from lead-based solder to lead-free solder, they will face a very certain unique problem called tin whiskering. Instead of lead-based solder they use tin base or silver base solders, which causes a whisker growth or there will be a needle type growth. This needle growth leads to some premature failures. So, we are also helping the industry, once they switch over from lead-based solder technology to lead-free solder technology, by providing them solutions with the reliability and performance issues they face with the help of various simulation chambers and Scanning Electron Microscope (SEM) . Of course, it is not a part of the project but we fully build the in-house capacity and expertise to handle, consult and support them to switch over, which include testing their component and products for reliability, climatic conditions, safety level test, material level test and ensuring that the product will perform as good as it was performing with leaded solder.

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Q. Do you face any challenges from convincing companies to move, for example in this case, from lead solder to lead-free solder?
A. Definitely, we do face challenges. When moving from lead-based solders to the lead-free solders, there is a 20 degree increase in melting point. So obviously the complete soldering operations will occur 20 degree higher from normal operating point. Secondly other parts need not be changed. Only the compatible surface will be exposed to 20 degree higher temperature. In addition to that, these lead free solders in certain extreme environments will have a tendency to form some sort of a needle growth which is called tin whisker. So when tin whisker grows, it will lead to some sort of a short circuit on the boards. So if an automotive electronic component or may be a medical electronics device is to be designed out of a lead free solder, it has to function properly but because of this unwanted growth which leads to some short circuiting it starts malfunctioning and leads to a lot of premature failures. To avoid these things, it is very important to tackle all these things during the design itself. So that’s where TUV Rheinland plays a vital role to help these industries to switch over from leaded technology to lead-free technology.

Q. What about your future plans for TUV India?
A. With regards to CSR (Corporate Social Responsibility), we are now also helping the textile clusters and even the other industries to meet the new environmental directives like REACH. Only ten industries are benefited out of this project so we wanted to ensure these benefits are not going to other industries. We are conducting the open house training programme and creating awareness by conducting appropriate training in different regions. We are also associating with various agencies like Automotive Research Association of India (ARAI) to create the awareness on REACH. We are working with Apparel Export Promotion Council (AEPC) to create awareness on registration, evaluation and authorisation of chemical substance. The same way we are working with RUBBER BOARD to create awareness. Hence we are doing this type of hazardous substance related activities across India.

We also did some training in association with Confederation of Indian Industry (CII) especially with AEPC which is a part of the Ministry of Textile. They have identified us as one of their technical partner and we have conducted some awareness training related to reach in various clusters like Bangalore, Chennai, Mumbai, Gurgaon. So we are conducting this and trying to make the industry to understand (of course at the end of the day we also have our own interest) what exactly these hazardous substance directives are and what are the important regulations they have to fulfil.

Q. Could you please elaborate on marketing strategies of TUV in India?
A. DEG Reach Hazardous Substance Process Management (HSPM) for Electrical and Electronic Equipment (EEE) industry in India is a Corporate Social Responsibility initiative taken up by TÜV Rheinland India. This project is a benefit to the society which will help the environment to be greener and healthier. Therefore there are no marketing activities involved in the project.

Q. What are the hiring policies of TUV in India? Do you hire freshers?
A. We have hiring policies of TÜV Rheinland in India and we do hire freshers, but pertaining to this particular project we have not made any plans of hiring. We are using our in house human resources for the project.