Is there a possible similarity in this discussion of "testing everything" that is a forerunner of the REACH legislation?
As I understand, there thousands of chemicals will have to be tested. It doesn't make sense to me for everyone to test every chemical mixture that comes in for every component. I had expected to see some kind of coordinated industry effort to say - Company X, you test chemical A because you make that, and Company Y, you test chemical B because you make that. We will all share results so we can all stay in business.
But I don't know what kind of international industrial association is capable of coordinating this base of previously tested materials. I understand REACH has designated a European organization (in Finland?) to be the data keeper, but I don't know if this is to be available to companies or just to enforcement agencies.
How can we make sense of all this without going bankrupt?
Denny Fritz
MacDermid, Inc.
-----Original Message-----
From: [log in to unmask]
To: [log in to unmask]
Sent: Wed, 25 Apr 2007 12:14 PM
Subject: Re: [LF] Blanket RoHS certification
Ryan,
My advice is to do your "due diligence". The directive does not require
independent lab testing to be compliant (China RoHS will, as it stands
now) and neither should your customer, unless they determine the risk of
non-compliance to be high.
Assess the risk of suppliers, validity of data, and volume of product
put on the market. Get testing, independent or in house, for the parts
that appear to be high risk (for all banned substances or the ones
likely to be present) and use supplier data (or supplier certifications)
for the others. Based on that, you can make a blanket statement for your
product (with the normal disclaimers off course) for your customers.
If you put a million products on the market then you have the resources
to get complete materials declaration and should pursue that to mitigate
any risks.
By the way, there is a lead exemption for steel, aluminum and copper
alloys.
Not sure if this helps or it means more work for you.
Regards,
LS
-----Original Message-----
From: Leadfree [mailto:[log in to unmask]] On Behalf Of Ryan Grant
Sent: Tuesday, April 24, 2007 6:59 PM
To: [log in to unmask]
Subject: Blanket RoHS certification
Hi All,
I'm getting pressure from QA, who is getting pressure from customers, to
provide a chemical declaration and independent laboratory certification
of RoHS compliance for EVERYTHING that is in our products. This
includes: plated copper, bar copper, alloy 42, aluminum 1050, aluminum
6063, stainless steel 310, etc.
Is there an industry standards organization out there (ANSI maybe) that
can blanket certify that if something is an industry standard alloy, it
is by default, RoHS compliant?
This is getting ridiculous... In the absence of blanket
'certification', I'm actually going to be required to demand our
suppliers prove their 6063 aluminum doesn't contain lead, arsenic, PPB,
etc.!
Thanks,
Ryan Grant=20
Memory Modules SQE
Micron Technology Inc.
(208) 363-3683
------------------------------------------------------------------------
-------Leadfee Mail List provided as a service by IPC using LISTSERV
1.8d
To unsubscribe, send a message to [log in to unmask] with following text
in
the BODY (NOT the subject field): SIGNOFF Leadfree
To temporarily stop/(start) delivery of Leadree for vacation breaks
send: SET Leadfree NOMAIL/(MAIL)
Search previous postings at: http://listserv.ipc.org/archives
Please visit IPC web site
http://www.ipc.org/contentpage.asp?Pageid=3D4.3.16 for additional
information, or contact Keach Sasamori at [log in to unmask] or 847-615-7100
ext.2815
------------------------------------------------------------------------
-------
THIS EMAIL AND ANY ATTACHED FILES ARE CONFIDENTIAL AND MAY BE LEGALLY
PRIVILEGED.
If you are not the addressee, any disclosure, reproduction,
copying, distribution or other dissemination or use of this
communication is strictly prohibited. If you have received this
transmission in error, please notify the sender immediately
and delete this email.
It is the policy of ACR Electronics, Inc. that no legally binding
statements, representations or commitments
(collectively statements) may be made by email.
Any such statements must be confirmed either by facsimile
transmission or by postal mail before they will have
legal effect. The sender of this email is not authorised to
commit the company in any way and the addressee is
hereby notified of that fact.
-------------------------------------------------------------------------------Leadfee
Mail List provided as a service by IPC using LISTSERV 1.8d
To unsubscribe, send a message to [log in to unmask] with following text in
the BODY (NOT the subject field): SIGNOFF Leadfree
To temporarily stop/(start) delivery of Leadree for vacation breaks send: SET
Leadfree NOMAIL/(MAIL)
Search previous postings at: http://listserv.ipc.org/archives
Please visit IPC web site http://www.ipc.org/contentpage.asp?Pageid=4.3.16 for
additional information, or contact Keach Sasamori at [log in to unmask] or
847-615-7100 ext.2815
-------------------------------------------------------------------------------
________________________________________________________________________
AOL now offers free email to everyone. Find out more about what's free from AOL at AOL.com.
-------------------------------------------------------------------------------Leadfee Mail List provided as a service by IPC using LISTSERV 1.8d
To unsubscribe, send a message to [log in to unmask] with following text in
the BODY (NOT the subject field): SIGNOFF Leadfree
To temporarily stop/(start) delivery of Leadree for vacation breaks send: SET Leadfree NOMAIL/(MAIL)
Search previous postings at: http://listserv.ipc.org/archives
Please visit IPC web site http://www.ipc.org/contentpage.asp?Pageid=4.3.16 for additional information, or contact Keach Sasamori at [log in to unmask] or 847-615-7100 ext.2815
-------------------------------------------------------------------------------
|
