A graduate of Auburn University, Douglas Letlow holds a Bachelor of Science Degree in Business Administration. For the last several years, Douglas Letlow has focused his professional energies on sales in electronics compliance and testing, and he currently serves as a Sales Manager at SGS U.S. Testing Company, Inc.

Douglas Letlow possesses comprehensive experience in marketing, sales, and leadership. Douglas Letlow has demonstrated his strong capability to lead teams and collaborate across national and cultural borders, launching new global products and providing solutions to international customers.

In addition to his time at SGS U.S. Testing Company, Douglas Letlow was a key contributor to business development at CD Group, Inc., a software solutions company based in Norcross, Georgia. Douglas Letlow held the position of Sales Manager at Intertek Testing Services in Dallas, Texas, before transitioning to his role at CD Group, Inc.

Outside the office, Douglas Letlow is dedicated to giving back to his community. Douglas Letlow supports 7 Bridges, The Locker Room, and Perimeter Church, and he has supported charities such as Christian Children’s Fund and The Salvation Army. Douglas Letlow also has coached a local Boys Youth USSSA AA Travel Baseball Team known as the North Gwinnett Bulldogs Black as well as assisted coaching other Youth Sports Teams.

Douglas Letlow recently wrote the following article:

RoHS and other Restricitive Substance Testing Requirements Continuing to expand globally.

Many countries around the world have imposed regulations regarding Restricitve or hazardous Substances in products. Many health issues have been tied to some of these hazardous substances and the world is trying to curb the mounting problems associated with these types of substances. This includes substances such as: Lead, Cadmium, mercury, hexavalent chromium, polybrominated biphenyls (PBB), and polybrominated diphenyl ethers (PBDE) and many more. In some countries their have been over 30,000 different chemical substances that have potential risk to the environment and/or human health. Although, the vast majority of the chemical substances have not been banned from use in manufacturing products, it is expected that the amount of Restrictive Substances that will be banned will rapidly increase over the next 5 years.
These growing requirements are part of the Green Inititatives many countries are embracing, however, it has put an increasing burden on manufacturers and the entire supply chain for products being sold around the globe. Although many countries around the world have implemented regulations regarding restrictive substances in products, the European Union has been the most progressive in implementing regulations such as The Directive on the restriction of the use of certain hazardous substances in electrical and electronic equipment 2002/95/EC commonly referred to as the Restriction of Hazardous Substances Directive or RoHS. This Directive was adopted in February 2003 by the European Union. The RoHS directive took effect on 1 July 2006, and was required to be enforced and become law in each member state. Currently this directive restricts the use of six hazardous materials in the manufacture of various types of electronic and electrical equipment, however there are more hazardous materials being consider to be added to the RoHS Directive. It is closely linked with the Waste Electrical and Electronic Equipment Directive (WEEE) 2002/96/EC which sets collection, recycling and recovery targets for electrical goods and is part of a legislative initiative to solve the problem of huge amounts of toxic e-waste.

More recently the REACH (Registration, Evaluation, Authorisation and restriction of Chemical substances program) regulation was added in 2007 which affects virtually all manufacturers and importers selling products in Europe. This includes raw materials, components, and end consumer products. In fact, the REACH regulation recently added additional Substances of Very High Concern (SVHC) to the existing list bringing the total to 29 on the Candidate List. Some experts say this number could very well quadruple over the next 5 years. Under REACH, information identifying any SVHCs present in a given product at 0.1% by weight plus any information necessary to enable safe use, must be disclosed upon supply of the product directly to commercial customers or with in 45 days after a consumer request the information. Failure to provide the requested information will result in a forced withdrawal of the product from the market and may include fines and penalties imposed by individual EU countries.

Substances included in REACH and RoHS regulations have been or are still being used in products around the world such as rubber products, plasticizers, polyurethane, PVC, dyes, paint pigments, polyesters and other polymeric and flame retardant materials. They include forms of polyaromatic hydrocarbon anthracene, high temperature coal tar pitch, acrylamide, 2,4-Dinitrotoluene, lead chromate molybdate sulphate red, lead sulphochromate yellow, tris(2-chloroethyl) phosphate, disobutyl phthalate, aluminosilicate refractory ceramic fibers, and zirconia aluminosilicate refractory fibers and lead chromate. It is estimated that millions of products around the world use some of these substances in their products. Many companies have already spear headed making the necessary changes in their products to comply with the current regulations, however, many more are just now beginning to embrace the issues. This means, many products may have to be redesigned and the supply chain of raw materials and components may need to change in order to be compliant. Companies with the man power to consider the sustainability of the materials used in their products will in the end have a leg up on their competitors since many companies may switch to new materials that may currently be non-regulated, but 3-5 years down the road may become regulated causing more design changes and possible retooling in the manufacturing process.

China has followed implementing regulations similar to the EU for RoHS or commonly referred to as China RoHS. Many other countries have followed suite and implemented a version of RoHS or some type of Restrictive Substance control regulations.

The United States has certain States that have implemented their own regulations such as Lead restrictions in certain types of products in some states and Proposition 65 in California. There is current legislation pending in Congress http://frwebgate.access.gpo.gov/cgi-bin/getdoc.cgi?dbname=111_cong_bills&docid=f:h2420ih.txt.pdf but is being referred to as US RoHS.

The current legislation reads:
“Except for those electroindustry products and product categories set forth in paragraph (3), no electroindustry product shall be manufactured after July 1, 2010, that contains a concentration value greater than 0.1 percent by weight of lead, mercury, hexavalent chromium, polybrominated biphenyls (PBB), and polybrominated diphenyl ethers (PBDE) as measured in any homogeneous material contained in the electroindustry product, or a concentration value greater than 0.01 percent of cadmium as measured in any homogeneous material contained in the electroindustry product.”

As this U.S. legislation goes through the political process, electrical products and equipment companies should be preparing to have these substances taken out of their products and documentation to show proof. Although the legislation is not finalized, the time it takes manufacturers to take these substances out of their product designs and supply chain of the components and raw materials can take a large amount of time, preparation and documentation. Luckily for many company’s that sale products in countries already imposing RoHS regulations such as the EU, they have already been aware of this proposed regulation and have been preparing ahead of time. However, there are many companies in the U.S., who have not had to learn about these new regulations until recently and they may run into issues dealing with this type of regulation in their product designs and supply chain as well as some companies have different versions of the same type of product sold in different countries. Many companies selling different versions of the same type of product in different countries may have only addressed specific product versions going into specific countries for compliance with the individual country regulations. This means that once the U.S. legislation is passed, many of these companies will need to redesign their products and change their bill of materials (BOM) used in the products.

This is especially tough for many companies to face given the current economic uncertainties and is most likely being considered by policy makers.
About the author, Douglas Letlow has worked in the compliance engineering and testing industry for over 16 years and has expertise in RoHS, REACH, Product Safety, EMI/EMC, Wireless, Battery testing and more.

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