Hi Jerome/Fern
I think there will be some sort of unofficial Commission guidance issued
with the definition when it is finalised by the EU. Could be in june?
or september?
Kay
-----Original Message-----
From: Leadfree [mailto:[log in to unmask]] On Behalf Of Jerome Wagner
Sent: 11 May 2004 20:39
To: [log in to unmask]
Subject: Re: [LF] Lead in resistors
Fern: If technical issues such as the one discussed in your note are not
defined by the regulators, it would be helpful if "standard
interpretations" were issued by someone, as we could be living with
these
regs for some time before court-issued clarifications emerge. I don't
want
to be out there all alone on the interpretations I make!
Could IPC issue standard interpretations? If not, will some other
industry
group? Perhaps the Joint Industry Group?
Thanks! jw
Jerry Wagner Dept 0056 Environmental Engineering B096-1
x56275 pg 58888-0658 (607)755-6275 fax: (607)755-6282
Huron Real Estate Associates, LLC and Endicott Interconnect
Technologies,
Inc.
Via the Internet: [log in to unmask] [NOTES: Jerome
Wagner/Huron/EIT]
----- Forwarded by Jerome Wagner/Huron/EIT on 05/11/2004 03:35 PM -----
Fern Abrams
<[log in to unmask]> To:
[log in to unmask]
Sent by: Leadfree cc:
<[log in to unmask] Subject: Re: [LF] Lead
in resistors
>
05/06/2004 10:15
AM
Please respond to
"(Leadfree
Electronics
Assembly Forum)";
Please respond to
Fern Abrams
Just to clarify, IPC filed comments with the EU Technical Adaption
Committee regarding the need for clarification proposed definition of
LF:
"A maximum concentration value of 0.1% by weight in homogeneous
materials
for lead, mercury, hexavalent chromium, polybrominated biphenyls (PBB)
and
polybrominated diphenyl ethers (PBDE) and of 0.01% weight in homogeneous
materials for cadmium shall be tolerated. Homogeneous material means a
unit
that can not be mechanically disjointed in single materials".
While I have had no formal response, we have heard informally that this
is unlikely to be further clarified and may end up being settled in
court.
Fern Abrams
Director of Environmental Policy
IPC - The Association Connecting Electronics Industries
1333 H Street, NW, 11th Floor West
Washington, DC 20005
(202) 962-0460
fax (202) 962-0464
www.ipc.org
-----Original Message-----
From: Bev Christian [mailto:[log in to unmask]]
Sent: Wednesday, May 05, 2004 4:49 PM
To: [log in to unmask]
Subject: Re: [LF] Lead in resistors
Gordon,
No, not very comforting.
The IPC Materials Declaration Team has sent a letter to the appropriate
EU personnel asking for clarification of some of these issues, but to
the best of my knowledge Fern has still not received an answer. This is
probably because they (EU) had not thought that far ahead when they
drafted the dreadful thing in the first place. As more than one wag has
stated, we will probably have to wait for clarification when that first
unfortunate company is dragged into court. Then we MIGHT get definitive
answers.
regards,
Bev Christian
Research in Motion
-----Original Message-----
From: Davy, Gordon [mailto:[log in to unmask]]
Sent: May 5, 2004 4:26 PM
To: [log in to unmask]
Subject: Re: [LF] Lead in resistors
Bill Haas has noted that 0402 surface-mount "lead-free" resistors were
found to contain more than 1000 ppm Pb, and that the suppliers assured
him that this is OK per the RoHS legislation. Bill wanted to know where
it says in the directive that what the resistor manufacturers told him
is so. Annex item 7 exempts Pb in "electronic ceramic parts (e.g.
piezoelectronic devices)", so it looks as if this is what they are
referring to.
What the Directive doesn't say anywhere, of course, is that for
components not exempted by the Annex the maximum allowable level is 1000
ppm, or how the limit (whatever it turns out to be) is to be calculated
- i.e., what is to be used as the fraction denominator: termination
finish, component as a whole, assembly as a whole, equipment as a whole.
Article 4 paragraphs 1 and 2 say that there can't be any Pb at all
except per the Annex, and paragraph 3 puts manufacturers on notice that
they may have to eliminate other stuff later.
Also not spelled out is how users of components - such as Bill - are
expected to document that the equipment items that they are selling are
Pb-free: will the envirocops be satisfied if the equipment manufacturer
can produce upon demand a certificate of compliance from the
manufacturers of each component? If not, how diligent does the original
equipment manufacturer have to be to ensure that no Pb above the
to-be-determined limit (except as permitted by the Annex) has crept into
his product?
As an analogy, hardware destined for space has long had a prohibition
against pure tin plating. Yet every time a satellite has been audited,
cases of pure tin plating have been found, due simply to human error.
Can you imagine the jeopardy of the manufacturer of an electronic
system, wondering if a particular item will be randomly selected to find
out if it contains Pb? (X-ray fluorescence will be useless for levels of
1000 ppm, so if that's the level that is finally chosen, we're talking
serious chemical analysis.)
Article 8 specifies that the penalties are to be "effective,
proportionate, and dissuasive." I don't see any language describing how
disagreements are to be resolved, or what happens to the equipment while
the matter is being settled. Not very comforting.
Gordon Davy
Baltimore, MD
[log in to unmask]
410-993-7399
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