Hi Bev,
I respectfully disagree with your last point. From a supplier
management standpoint, if lead 'intentionally' exist in a product, then
you have to validate it doesn't exceed established threshold on a
periodic basis. Otherwise, how do you know they are actively keeping
their process in control and don't accidentally exceed the thresholds?
Like Todd said, "We're not going there". I'll buy my parts from someone
else so I don't have to spend money just to validate incoming product is
compliant.
If lead exist 'accidentally', and in the event it 'accidentally' exceeds
established thresholds, periodic sampling would never find it anyways so
there is no need to even look for it. Determining 'intent' can be found
from a chemical declaration. If lead is on a chemical declaration, it's
not because it accidentally fell out of someone's pocket. If its not on
a chemical declaration, its existence in purely the result of
contamination somewhere, which can't always be controlled.
By the way, I want to point out that lead has some exemptions and
managing lead thresholds in the exemptions isn't necessary.
Ryan Grant
-----Original Message-----
From: Leadfree [mailto:[log in to unmask]] On Behalf Of Bev Christian
Sent: Friday, September 30, 2005 9:27 AM
To: [log in to unmask]
Subject: Re: [LF] Lead: Intentionally added but below 1000 ppm?
Todd,
You are not entirely correct.
1) Yes you are correct that adding, for instance, lead is risky.
2) Yes you are correct that if they say it is under the limit and they
are actually over that is a violation.
3) NO, intentionally adding non-exempted substances is a NOT a
misinterpretation. If you are under, you are under. Intent has nothing
to do with it.
If, as you say: "we simply will not accept this as a valid compliance
approach", what is you limit - 1 ppt, one atom? THIS is not a valid
compliance approach.
Bev
RIM
-----Original Message-----
From: Leadfree [mailto:[log in to unmask]] On Behalf Of MacFadden, Todd
Sent: September 30, 2005 7:52 AM
To: [log in to unmask]
Subject: Re: [LF] Lead: Intentionally added but below 1000 ppm?
Hi Ken,
We have heard this as well from several of our suppliers who have
claimed to be below the thresholds with intentionally added materials
and we simply will not accept this as a valid compliance approach. While
the Directive does not specifically use the words "intentionally added,"
the intent of RoHS to ensure EEE products do not contain the 6
restricted substances is abundantly clear. The MCV thresholds are simply
an acknowledgement of the inevitable, unavoidable presence of
impurities. This is precisely the reason for defining the thresholds at
the homogeneous level rather than at the component or assembly level,
for instance, because I have yet to see an intentional use that would
pass this definition.
Remember, too, that the burden of proof is on the producer, not the
supplier. In at least one case where a supplier of ours sought our
approval for intentional use of Cr+6 where they claimed to be below the
threshold, we found that they tested incorrectly. When properly measured
at the homogeneous level, they were an order of magnitude over the
threshold. We don't want to conduct that level of scrutiny throughout
our supply chain.
We believe that intentionally adding non-exempted substances is a
misinterpretation or a nuancing of the Directive that could be risky.
We're not going there.
Todd
-------------------------------
Todd MacFadden
Component Engineer
Bose Corporation
508.766.6259
-------------------------------
-----Original Message-----
From: Leadfree [mailto:[log in to unmask]] On Behalf Of Kanaiyalal Patel
Sent: Thursday, September 29, 2005 8:32 PM
To: [log in to unmask]
Subject: [LF] Lead: Intentionally added but below 1000 ppm?
All,
What is your take - if my supplier is saying the lead content is well
below 1000 ppm threshold but it was intentionally added? Will it be
considered RoHS compliant or non-compliant?
Any clarification will be highly appreciated.
Re,
Ken Patel
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