Dear Colleagues,

I was contacted off-list by one of the list members
who had questions regarding whether North American
regulatory agencies seemed to be aware of RoHS and
lead-free issues.  After our discussion, he requested
that I post some version of my comments to the list as
a whole.

The only North American regulatory agencies I
regularly deal with are UL and CSA, and I don't deal
with CSA very much.  In addition to spending a fair
amount of time dealing with UL in my current position,
I worked for UL from 1998 to 2001 and I still keep in
contact with a number of colleagues who continue to
work there.  However, it HAS been four years since I
worked there and a lot can happen in four years,
especially given that UL has been going through an
extensive reorganization over the last couple of
years.
     That said, I have not talked to very many people
within UL who are aware of the changes RoHS are going
to make to product construction.  UL DOES offer a
service where (I think) they will send someone out to
your site to discuss RoHS and lead-free issues (see
UL's website for more information, www.ul.com), but I
think that is a separate department from the product
evaluation engineers and follow-up service auditors
that manufacturers probably have the most contact
with.
     My experience is that UL tends to be very
concerned about relays and enclosure plastics.  So as
manufacturers have to move to relays that don't have
cadmium contacts and plastics that don't use PBB or
PBDE (and I have been told by a plastics supplier that
almost all ABS's use PBB or PBDE, so that's a pretty
big chunk of the market), I expect there would
probably be a lot of revisions to the UL reports.
Those components are often called out very
specifically by manufacturer and model designation and
some amount of retesting is usually necessary when
adding another relay or plastic to the UL file.
     Most of my comments are with regards to the UL
standards and files dealing with electrical
end-products.  I don't have a lot of contact with the
UL materials evaluation groups (PCBs, wire & cable,
plastics, labeling, magnet wire, etc.) so there may be
more RoHS/LF research going on there.

With regards to CSA, I do know that the last time I
talked to the CSA follow-up service auditor for the
Portland area, he asked if I was aware of lead-free
and RoHS and he seemed to be fairly knowledgable about
it himself.  Whether that means that the whole CSA
organization is gearing up to deal with RoHS/LF is a
question I can't answer.

Has anyone else had any experience in dealing with UL
and/or CSA with regards to RoHS/LF issues?

-Camille Good
Portland, Oregon

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