There's a new EIA standard out (released in May) that covers some of the things being discussed here. EIA/ECCB-954, "Electrical and Electronic Components and Products Hazardous Substance Free Standard and Requirements," identifies procurement routes, traceability, handling and corrective actions for electronics designers and manufacturers. It stipulates processes for products with hazardous substances. It's very similar to ISO in that it focuses on what needs to be documented.
It does not advise how procurement or design or manufacturing should be performed. It does, however, establish that all those affiliated with the producing of electronics products must understand the regulatory and statutory requirements covering those products, and have processes in place to manage their operations based on their own declaration of how they comply.
Compliance to EIA/ECCB-954 is based on a company's own assumptions as to the completeness of its HSF standards.
The standard defines requirements for implementing processes to test and analyze any HS content, but doesn't state what those test procedures are.
Companies will comply to EIA/ECCB-954 by ensuring their suppliers are qualified to the "root" of supply. That means, for example, an OEM would audit their suppliers, who in turn would audit theirs, and so on, back to the mines. The OEM wouldn't have to specifically check their component supplier's resistor material, but would need to confirm that resistor manufacturer's documents are in place.
The assessment period is based on a company's size. An organization with less than 100 employees would undergo two to three days of on-site surveillance followed by one to 1.5 days of record review. A firm with 500 employees would be subject to 5.5 days of on-site visits and three days of records checks.
Auditing is performed much like ISO. In fact, some of the same companies are expected to do the audits. Once a company is registered as in compliance, they become part of the equivalent of a qualified manufacturers list. Certificates are renewed automatically, provided companies stay in compliance with the documentation requirements.
The standard has already made its way to the international level. ECCB is the U.S. representative to the International Electrotechnical Commission, and the latter's quality management systems group, the IECQ, is reviewing the standard for international approval.
Mike Buetow
Editor in Chief
Circuits Assembly
30 Glenburnie Road
Boston, MA 02131 USA
W/mobile: 617-327-4702
PCB Design East
Manchester, NH
www.pcbeast.com
Did you know UP Media produces Webinars? www.pbrseminars.com
>>> [log in to unmask] 09/09/05 1:02 PM >>>
You have to consider the potential litigation as well as the compliance.
It is important that you get the conformance certification through your
supplier - which is probably these days your contract manufacturer. You also
have to have an audit system that verifies that he is collecting and storing
data correctly, and that he is also auditing his suppliers the same way.
It is not sufficient to just gather data from the component manufacturer,
since in most cases you do not do business with them you purchase nothing
from them and no purchasing agreements are in place. In the event of a
dispute it would make it difficult for a court to award damages against a
company that you do not do business with... - but your contract manufacturer
does buy those parts from the vendor, and those purchase agreements are in
place.
It will not be about the fine that the EU may impose for importing non
conforming materials, it will be about all of the non - conforming product
in Europe that gets frozen at customs, in stores and warehouses, the
lawsuits for third party loss of business ,the field recall, re-manufacture
etc that will cost the real money - now that will make any fine look like
pocket change............
IPC 1752 hazmat compliance declaration is a start, I am on the committee and
for one will be glad when it is "officially" released so that it can then be
referenced in purchase agreements between companies.
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 MA/NY DDave
Sent: Friday, September 09, 2005 8:46 AM
To: [log in to unmask]
Subject: Re: [LF] RoHS: Proof of Supplier Component Compliance
Hi Jeff, NIST-John, Chris, , IPC LF Listservers,
Great topic.
I read the notes as of last night so let me start with your launch note and
then read what everyone posted today (2005.0909)
A COC or letter of conformity to RoHS but with no Evidence of compliance is
INSUFFICIENT and is not due dilligence.
For your company's protection you might wish to do more. If you run into an
EU or other problems your supplier may not even answer the phone and will
pay no penalty. Long term they will pay a penalty yet your company will pay
a heavy burden that might stop or slow sales. A No No to CEO's and CFOs.
Options (yours first, and a few other ideas)
* Blindly accept their COC/Letter of conformance and HOPE they really are
compliant and do not exceed the hazardous threshold limits.
NOT GOOD, unless for some reason you view your risk at being audited or
evaluated by someone as 0%. Remember some ISO people are chomping at the
bit and a good one will catch you.
You know this answer best and your management team should decide if you
wish the "Blind Faith" pathway.
If your attorneys or purchasing agreements are such that these large
suppliers will pay all your bills, walk hand and hand with you through all
fires, including rebuilding customer good then I guess a Blind faith COC is
somewhat acceptable. BTW I don't know of any that will unless you are a
HUGE customer like IBM.
* Have their components tested. ( An expensive option )
For select components you know have contained RoHS restrictions you
probably should do some testing.
As this RoHS expands we will find other testing and record keeping
companies supplying this data. Yet you will still should do due dilligence
with them.
* Change suppliers to one that can provide this info ( A very very painful
and expensive option at this point )
Check out alternative suppliers first, without even telling your current
supplier. If you find them responsive and communicative consider switching.
I know (sadly) maybe it will cause design changes.
Yet a supplier who will work with you is an ally in more way than RoHS.
If component suppliers start losing customers they will grow up fast.
* Research & Examine their technical reports/white papers/other
Although they won't give you what is reasonable for you to retain as back
up engineering records huge companies might have web sites, or have
written articles on how they are complying.
I would probably choose this route first
* Other OEMs, Users Experiences with these companies
You are already doing this here yet also do this in your industry sector.
* Large Component Distributors
If you can buy through them and you are a small company they can create a
larger presence to butt heads.
-----------
<So I know this is a rhetorical question but how can they claim compliance
for their components and not know the Mass and % of Content of the banned
substances?>
If they are large and they have used the restricted RoHS substances then
they will know these answers. They still might not share them yet with
analytical chemists and others on their staff they will have the answers.
Your in Engineering, Dave
YiEngr, MA/NY DDave
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