Dear Ziyi,
Thank you very much for the feedback.
I'm sorry that I might not be able to catch your idea in your first email,
but now I think I know better. I hope I can explain better this time.
As supplementary to other's answers, your question is about the
scope/concept of RoHS and other legislations, not necessarily to be the
relative toxicity of materials themselves.
What regulated by RoHS is determined by the EU commission, and the
material banned in RoHS have to link to the other directive, WEEE, waste
electrical and electronic equipment. The six substance (toxic or
carcinogen) were found to exist and used "intentionally" in a lot of
electrical and electronic equipment, for example, lead in soldering, Cr6+
is for most of shiny surface treatment, PBB/PBDE is for a lot of materials
need high performance flame retardancy, and so on. Intentionally means
the material is added by FUNCTIONAL purposes, not amount in trace by
pollution. The ultimate goal of RoHS is to push those substance out from
electrical and electronic equipment to make recycling profitable and
without accumulating of toxicity, as indicated in RoHS directive. For
example, lead existence in solder (37%) is called intentional, not by
pollution, the intention of RoHS is to stop industry from using lead
intentionally. 100 ppm for Cd and 1000 ppm for other substances are
concentrations of natural existence. Also it is the reason why RoHS
allowed self declaration of the substance existence, because if the mfr.
know they didn't add it intentionally, their product shall comply with
RoHS requirement as long as they didn't buy the material from a highly
polluted sources.
Accordingly, the six substances are toxic, but they are not definitely
so-called the most "toxic" material in the world (nor in the top 10!!),
they are listed just because they are toxic AND they are used by a lot of
electrical equipment "intentionally." RoHS is a very specific directive,
only cover electrical and electronic industries. Yes, there are other
more toxic materials like cyanides or dioxins, and there are other toxic
substances existing in other applications like wrapping materials or toys,
but they are not in the scope of RoHS and not the intention of RoHS. That
can also explain why RoHS didn't control dioxin since dioxin have no
functional demands in electrical and electronic equipment so no one would
really add dioxin into their product for performance requirement and
though dioxin is thousand times more toxic than those six substances...
RoHS also allows exemption once it is found not total eco-cost efficient
to remove certain substance from certain application, just like mercury
lamps.
EU had other directives for other applications, for example, packaging
directive (for packaging materials, with less banned substances but more
stringent concentration requirement,) toys, and ELV (end of life
vehicles.)
The most important directive and with real huge impact for the world would
be REACH, Registration, Evaluation, and Authorization of CHemicals, which
may start its impact from 2008. Unlike RoHS only for electronic and
electrical equipment, REACH will affect the using of chemicals whatever
the end use application. So far as we known, there are already about
hundreds of substances on the list, and it is expected to grow up to at
least two thousands substances in 2010 (and will keep growing once
evidence supports), and it will really cover most of toxic material
(whatever we've heard or not.) and whatever purpose of the existence.
Unlike RoHS, REACH won't accept self declaration without data, and REACH
Authorities is not obligated for examination to prove compliance, i.e.,
users need to present data to show compliance once questioned in about ten
days.
REACH is really something to worry about, at least a lot more than RoHS.
You might be able to afford testing of six substances for RoHS on each of
your product, but how about 2000 substances? It had to be realized by
control of process and supply chain control since substance won't appear
without reason, i.e., if there is no hazardous substance in the process,
raw material, and environment storage or manufacturing, there shouldn't be
any left in the product.
I've been involved with environment related legislation in the past few
years, and I was also the responsible personnel in UL Taiwan to develop
RoHS testing business and capacity in Taiwan. I delivered open
presentations and wrote some articles in paper or electronically.
It is a little be long, but hope the information is clear, comprehensive,
and helpful a little more, but please always feel free to let us know if
any information can be further assistance. Thank you very much!!
Sincerely,
xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx
Benjamin Chen
Regional Technical Coordinator, Asia-Pacific
Consulting and Training
Underwriters Laboratories Taiwan Co., Ltd.
Tel: 886-2-2896-7790 ext. 62267, Fax: 886-2-2896-6140
[log in to unmask]
- Know by test, and state the facts. -
Web site: http://www.UL.com.tw
Ziyi Li <[log in to unmask]>
Sent by: TGAsia <[log in to unmask]>
01/03/2008 08:37 AM
Please respond to
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Subject
[TGA] 答复: Re: [TGA] RoHS管制+6价的Cr，为何是离子 态的管制？
Hi Benjamin：
可以用反正法验证你的观点，好似难以成立！
即：
假设你的观点成立，那氰化物是否同样有存在残留的可能？答案也是会存在！如
此它的毒性比6价的铬要高呢~所以我们的假设还是不能成立！
期望各位给予比较合理的解释！
谢谢！
Best Regards
************************************************
支架事业处 工程&品管 课长 李子祎
扬州华夏集成光电有限公司
地址：江苏扬州经济开发区扬子江南路518号(邮编：225009)
网址：http://www.darewinchip.com
邮箱：[log in to unmask]
电话：0514-87849588ext:8086
传真：0514-87849312
Skype:liziyi_jhks
************************************************
[log in to unmask]
2008-01-03 08:08
收件人
Asia Committe Task Group Forum <[log in to unmask]>, [log in to unmask]
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Re: [TGA] RoHS管制+6价的Cr，为何是离子态的管制？
Hi Ziyi,
As the supplementary information for other's answers.
It is because the Cr6+ is more toxic than Cr or Cr3+, but its existence in
nature is by chemical compound in solid state with other ions or ionic
groups. The analysis is to measure how much of chromium existed as the
state of Cr6+ in the chemical compounds of the product. Though existed in
chemical compound state (solid), when inhaled or other ways into human
bodies, it will be then decomposed into Cr6+ in human body (as the salt
dissolved in blood or water) to cause toxic reaction. How we verify the
existence of Cr6+ is usually by X-Ray Fluorescence (nondestructive),
UV-Visible Spectroscopy (destructive) quantitatively, or other known
chemical reactions quantitatively or qualitatively.
Hope this helps, and please feel free to let me know if any further
information necessary, thank you very much!!
xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx
Benjamin Chen
Regional Technical Coordinator, Asia-Pacific
Consulting and Training
Underwriters Laboratories Taiwan Co., Ltd.
Tel: 886-2-2896-7790 ext. 62267, Fax: 886-2-2896-6140
[log in to unmask]
- Know by test, and state the facts. -
Web site: http://www.UL.com.tw
Ziyi Li <[log in to unmask]>
Sent by: TGAsia <[log in to unmask]>
01/02/2008 04:59 PM
Please respond to
Asia Committe Task Group Forum <[log in to unmask]>; Please respond to
[log in to unmask]
To
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Subject
[TGA] RoHS管制+6价的Cr，为何是离子态的管制？
Dear All：
为什么RoHS管制+6价的Cr?在我认为：固态的产品（电镀层）如何出现离子态，很
另人困惑~,恳请各位支招!
谢谢!
Best Regards
************************************************
支架事业处 工程&品管 课长 李子祎
扬州华夏集成光电有限公司
地址：江苏扬州经济开发区扬子江南路518号(邮编：225009)
网址：http://www.darewinchip.com
邮箱：[log in to unmask]
电话：0514-87849588ext:8086
传真：0514-87849312
************************************************
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