In principle there is nothing wrong with ppm level reporting, but it
does not help with RoHS compliance. Knowing that part X contains less
than 1000ppm Pb is of no value under RoHS.
For RoHS you need to know the ppm level for each and every type of
material used in the construction of any component and whether each
material type contains regulated substances below the regulated limits
(1000ppm for all but Cd which is 100ppm), not the overall ppm level for
the whole component. Additionally, you need to be able to individually
discriminate materials that that make up each component which are
covered under the scope of RoHS, and those for which a RoHS exemption
applies and which you don't care about.
If all the materials (components, PCB laminate, solder, glues, screws,
metalwork, plastic fascias etc etc) that are used in the construction of
your unit of EEE are compliant, then the overall unit is compliant. So
the key is documented supply chain management to prove due diligence
along with compliant manufacturing processes.
As my colleague has pointed out, incorrectly arguing for ppm level
reporting in respect of RoHS will only serve to make it a de facto
requirement for other RoHS type legislation that may come along, and
that is a dangerous path to follow.
-----Original Message-----
From: Kallin, Dan [mailto:[log in to unmask]]
Sent: 19 May 2005 16:21
Subject: Re: Data gathering and maintenance requirement for RoHS
compliance
The Automotive manufacturers have been requiring PPM level reporting for
some time. Since we supply to both and have components used in both
theaters, we decided to collect PPM level data from all and 100 %
disclosure for automotive.
For most, I suspect it is a risk management question and will depend on
your company's risk acceptance level and the level of faith in the
supplier.
Some thoughts....
Collecting the extra data allows us to be better prepared for future
regulatory action and laws other than RoHS such as CA's Prop 65 and
other initiatives such as China and Norway.
Requiring the PPM level may also lead to much better data. It requires
more thought and commitment to say X PPM than simply yes its compliant.
How can a part be certified as compliant? They are not regulated, the
end product is. Compliant for use in a server? or Monitoring Equipment?
Telecom? Or consumer radio? You will need to be very careful in
crafting the question to which they reply.
Compliant to what? The levels have not been set. You will need to
specify the levels to which they must be compliant.
What are you going to do if some other country/market says, we want no
more than 100 ppm of anything.
There is still the unanswered question of what will be required for
disassembly info.
Dan
__________________________________________
Dan Kallin Environmental & Safety Engineer
Bose Corporation Framingham, MA 01701
[log in to unmask]
508-766-7136 (phone)
508-766-7086 (fax)
__________________________________________
-----Original Message-----
From: Leadfree [mailto:[log in to unmask]]On Behalf Of Blair K. Hogg
Sent: Thursday, May 19, 2005 8:23 AM
To: [log in to unmask]
Subject: Re: [LF] Data gathering and maintenance requirement for RoHS
compliance
Thanks all for the replies.
Chris and Nigel are saying that I don't need the ppm data, if all of my
suppliers cert that the parts are compliant, I'm OK. I'm leaning towards
agreeing with them.
On this side of the pond MA/NY DDave is suggesting that I do need the
ppm data. So we have a difference of opinion. BTW, Dave, I was up in
your area two weeks ago, checking out new SMT equipment at NepCon.
I don't see what having the ppm data gets me, if the directive applies
to individual parts. But I know how govt agencies can work when
enforcing these kind of regulations, so I'm worried.
Blair
>>> [log in to unmask] 05/19/05 08:05AM >>>
Yes you will need it to prove a route to compliance unless you are using
a
contract manufacturer in which case you can get him to do it.....someone
has
to do it to show due diligence in case there are any issues downstream.
Here is another link to get the data validated....
http://www.rohsusa.com
You can also get software through companies like E2open, worth checking
out
for larget corporations.
John
------------------------------------
Avanex
John Burke
Senior Manager RoHS Compliance
[log in to unmask]
40919 Encyclopedia Circle
Fremont
CA 94538
tel: 510 897 4250
fax: 510 979 0189
mobile: 510 676 6312
------------------------------------
-----Original Message-----
From: Leadfree [mailto:[log in to unmask]]On Behalf Of Blair K. Hogg
Sent: Wednesday, May 18, 2005 12:05 PM
To: [log in to unmask]
Subject: [LF] Data gathering and maintenance requirement for RoHS
compliance
Avnet (US distributor) was here today making a presentation on a service
they are offering to customers (either free or for a fee, based upon
level
of service) that will collect and organize data for RoHS compliance.
Something in their presentation stirred up a few brain cells and I
decided
to go to this forum to see how everyone else is approaching compliance,
or
demonstration of compliance.
Avnet will supply the materials content in ppm for each of the RoHS
substances, along with other component data such as weight.
I'm wondering if I really need this information.
The directive covers "homogenous materials" as needing to be compliant
and
the accepted interpretation is that everything down to the plating on
the
leads of a resistor must be compliant. I don't see where the breakdown
in
ppm per part and weight are important. If I was taking the approach that
my
product weighed 25kg, I could have 25g of lead and be at the 100 ppm
level,
however, with the homogenous materials approach this doesn't matter.
So what I am looking for is a statement from the supplier or
manufacturer
that the part is RoHS compliant in itself. If all of the parts I use are
compliant, and my processes are compliant, then the assembly is
compliant by
default.
Do I need the materials content data for anything? I have heard that
some
customers are asking for this, as opposed to simply asking for a
statement
of compliance.
Thanks,
Blair Hogg
QA Manager
GAI-Tronics Corp
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