It would be totally impracticable to collect all the PPM data on every
component - even then how do you verify it. A suitable audit trail of
compliance certs should be sufficient with possible spot checks on a
periodic basis - see the UK guidance.
The problem is there are a lot of over paranoid people out there and
others who wittingly or unwittingly generate mis information about what
is and is not required. I have had to question two people on comments
they have either made at conferences or in the press, both from
respectable organisations and both I'm sure genuine in their intent -
yet both agreed they were not correct in what they put out once they
double checked it.
If people forge ahead on the basis of such information they are in all
probability wasting time and effort but if lots of people go about doing
it then it becomes a defacto standard which gets adopted and takes the
requirements beyond what was ever envisaged by those who produced the
legislation. That of course of detriment to us all.
Regards,
Chris
____________
-----Original Message-----
From: Leadfree [mailto:[log in to unmask]] On Behalf Of Blair K. Hogg
Sent: 19 May 2005 13:23
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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