While it seems intuitive to collect and combine the total weight of the lead
in the product, Is this really necessary?  Does it add or present any useful
value or data? It is not required by the directives as I read them..
Essentially manufacturers need to be able to prove none of their
"homogeneous materials" exceed the threshold amounts.  If all the parts are
less than threshold the whole cannot be greater than threshold without
breaking laws of physics.  Further, if they are not there they do not need
to be reported to the recyclers.

Any thoughts?
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 Leo Lambert
Sent: Tuesday, October 12, 2004 3:36 PM
To: [log in to unmask]
Subject: Re: [LF] Pb-free definition (and partial response to G
Anderson)


Hi Christopher, just read your message and wanted to comment on the
definition of homogeneous materials. Although as you mentioned impractical
to disjoin the IC, the .1% lead by weight requirements is based upon the
Lead content of the solder on the lead frame. It is not based upon the Lead
content of the lead frame itself but of the solder on the lead frame. You
will have to request this information from your suppliers and manufacturers
of the components. They will have to supply you with Material Declaration
Forms identifying the materials contained in the product down the weight
percentage of each relative to the total weight of the package. Design
engineers will now have to collect all these forms and define the total
weight percentage of Lead in their product and again it is not based upon
the weight of the product but of the weight of the solder within the system
itself.

If it was based upon the weight of the product, then extra weight could be
added to the product to make it meet the requirements of the law. From an
old saying of a long time ago when we were chasing CFC and other cleaning
solvents, dilution was not the cure to pollution. The same applies here,
adding weight is not the cure to solving this issue.

Hope this information is useful.

Check our website for lead free information and links to DCA website for
more information.

Leo Lambert
Technical Director
EPTAC Corp.
Longfellow Square, Bldg. II
8025 So. Willow St., Unite 207
Manchester, NH 03103
P. 800-643-7822 ext 15
F. 603-296-2377
[log in to unmask]
www.eptac.com

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