You are exactly correct.
-----Original Message-----
From: Leadfree [mailto:[log in to unmask]] On Behalf Of Genny Gibbard
Sent: 08 September 2005 22:04
To: [log in to unmask]
Subject: Re: [LF] RoHS: Proof of Supplier Component Compliance
Homogeneous materials is still the superceding consideration. If each
homogeneous material within each component is compliant, then the
assembly is compliant. If one homogeneous material in one part is not
compliant, the total volume doesn't dilute it to a compliant level, as I
understand it. The entire assembly is simply not compliant.
-----Original Message-----
From: Leadfree [mailto:[log in to unmask]] On Behalf Of jeff collins
Sent: 8-Sep-05 2:57 PM
To: [log in to unmask]
Subject: Re: [LF] RoHS: Proof of Supplier Component Compliance
Ok.....That is making a lot more sense except when I think of something
like a cable assembly that is made of several individual parts and put
together by my CM. How would you address the levels in this scenerio? As
individual components or the sum of the assembly?
Jeff C
"James, Chris" <[log in to unmask]> wrote:
because the levels are per homgenous parts of each part and not as a %
of the total of the unit. If each homegenous part is within spec then so
is the unit.
You are also assuming that there is some level of banned substance in
all parts whereas the banned substances will in many cases be removed
altogether.
---------------------------------
From: jeff collins [mailto:[log in to unmask]]
Sent: 08 September 2005 20:59
To: JEFF WHITMIRE; Gordon,Ian; James, Chris
Cc: [log in to unmask]; [log in to unmask]
Subject: RE: RoHS: Proof of Supplier Component Compliance
Group,
So I'm "partially" in agreement with everybody it seems which is why I
raised this issue.
For the group that believes you do not need a CoC showing the Mass and %
of Content of the banned substances, how do you determine ( Without
testing ) that your equipment does not contain more than the maximum
allowable levels of the banned substances?
My point here is, spot checking is great but if I can calculate this
while I'm selecting my components, I think I'm way ahead of the game
compared to the guys who won't find this out until after they test.
Also, there are certain materials under the RoHS ANNEX which are
exempted from the requirements based on their mass and content. Again, I
would rather know this sooner by having it in on my CoC rather than
later by testing.
I do agree that testing is ALWAYS the best way to ensure conformance
however there are a lot of proactive / front end things that you can do
to reduce the amount of testing.
For example, I also do reliability MTBF calculations and frequently try
to use the vendor data whenever possible. However there are vendors that
provide great MTBF numbers with little supporting data and there are
other vendors that also provide great MTBF numbers with a lot of
supporting data. So it easy to guess in this scenario which vendor I
will invest the time to re-run and verify their calculations? And
.....normally, the vendor that provided the least amount of supporting
data number's are usually incorrect or flawed. So I focus my
testing/calculating efforts on those vendors that provide little data
and spot check the others.
So I still ask, since those vendors must know the Mass and % of Content
of the banned substances, what's the harm in putting this info on the
CoC.
Thanks for all the replies.........
Jeff C
JEFF WHITMIRE <[log in to unmask]> wrote:
Since I am discussing particular vendors, I have taken my discussion off
of the list server.
I agree with Ian and Chris. You gain nothing by tracking all the
detailed data on each part. You are no further ahead of the game than
with a D of C. You are still trusting that the vendor is providing
accurate data. That is where spot tests are valuable.
There are several vendors out there offering databases. No vendor that I
have seen so far has a complete database. I2 software has partnered with
UL and they are trying to sell everyone the service of testing all of
these components and putting them in a database that they can then
resell to others. Other vendors such as IHS and PartMiner have databases
have similar capabilities. Entry level into these types of programs is
around $200K. Once you have the software, you have to invest in another
dozen people internally to the company to maintain the data and keep it
accurate with your BOM and keep after the vendors whose data is not in
the database. Most of these databases have data that is provided by the
vendor, with no actual verification testing. UL is supposed to add the
test capability for RoHS in China and are lowering the cost for these
tests.
My personal opinion in all of this.
Regards,
Jeff Whitmire
-----Original Message-----
From: [log in to unmask] [mailto:[log in to unmask]] On
Behalf Of Gordon,Ian
Sent: Thursday, September 08, 2005 4:53 AM
To: 'James, Chris'; jeff collins; [log in to unmask]
Subject: RE: RoHS: Proof of Supplier Component Compliance
Jeff
I agree with Chris in that we accept D of C's for other directives
without insisting on seeing every report for every item. However I also
agree with you that the question arises "how do they know its compliant
if they cant give me the data that shows it?". I have found that some
electronic component manufacturers do provide this data but many
"ancillary component"
(e.g. crimp terminals, DIN rails etc) manufacturers do not.
Some of our customers like to see the chemical composition of our
products.
If you find a database which people can use easily then please let me
know - the only way I have been able to get RoHS data is by contacting
individual suppliers and giving them a list of parts I would like data
on.
Ian Gordon
-----Original Message-----
From: James, Chris [mailto:[log in to unmask]]
Sent: 08 September 2005 10:23
To: jeff collins; [log in to unmask]; [log in to unmask]
Subject: RE: RoHS: Proof of Supplier Component Compliance
Have you 100% self test for every other operation or claim that vendors
make for their products on existing D of C's - I doubt it. So why get
paranoid now? Accepting D of C's is permissible but ought if practicable
be backed up by spot testing.
Getting details of the composition is not a requirement of RoHS and
would add significant burden to do so. Why push for more than is
required - if too many people push then it will become a defacto
requirement and then a mandatory requirement.
Do you take your car home after a smog check and then take it to a lab
to have it checked again or do you accept the smog station certificate?
Regards,
Chris
____________
From: [log in to unmask] [mailto:[log in to unmask]] On Behalf Of jeff
collins
Sent: 08 September 2005 09:55
To: [log in to unmask]; [log in to unmask]
Subject: RoHS: Proof of Supplier Component Compliance
Group,
I am finding several component suppliers ( many who are major mfr's )
that will issue a COC or letter of conformity to RoHS but with no
Evidence of compliance or even a breakdown of the weights or percentages
of the hazardous substances.
Is anyone else having this issue? This puts us in a position where we
either have to:
* Blindly accept their COC/Letter of conformance and HOPE they really
are compliant and do not exceed the hazardous threshold limits.
* Have their components tested. ( An expensive option )
* Change suppliers to one that can provide this info ( A very very
painful and expensive option at this point )
So I know this is a rhetorical question but how can they claim
compliance for their components and not know the Mass and % of Content
of the banned substances?
Thanks,
Jeff Collins
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