Jerry,
I have to agree with Chris, unfortunately. (Chris, the "unfortunately"
refers to the situation not you. :) )
My guess is the EUers are getting us ready for the next stage, which
will be complete chemical disclosure. So you either have to get the
information from farther down in the food chain or do your analysis and
hope that your method is good enough (low enough detection limit) that
if it says you have zero chromium VI in your ground up circuit board
that this is correct for all the materials in it. This is likely to be
true, but less so as you go from that to mercury, to cadmium, to banned
brominated fire retardants to lead. We could quibble about the order I
have put these in, but it does not really change the argument.
Bev
RIM
-----Original Message-----
From: Leadfree [mailto:[log in to unmask]] On Behalf Of James, Chris
Sent: December 7, 2005 8:18 AM
To: [log in to unmask]
Subject: Re: [LF] RoHS Homogeneous Materials and PWB's
Jerome,
This area has been widely discussed and sadly the answer which can be
found in the documentation does mean any part which theoretically could
be disjointed, which in your example could be by grinding - maybe not
practical but then the RoHS directive is not practical!!
By the definitions used for RoHS, homogeneous substance means a material
of uniform distribution which a PCB is not.
It is accepted than plating on a steel screw and the like must be
treated as separate from the steel so how much more absurd can you get.
Sorry, like the rest of us you'll have to get on with it as there is no
mileage in debating this anymore. Maybe when enforcing agencies get to
discover the practical impossibilities involved (or expense required to
determine) then maybe the swingometer will move in our favour.
Regards,
Chris
-----Original Message-----
From: Leadfree [mailto:[log in to unmask]] On Behalf Of Jerome Wagner
Sent: 07 December 2005 12:27
To: [log in to unmask]
Subject: [LF] RoHS Homogeneous Materials and PWB's
Folks: I wish to review your thinking on "homogeneous materials" and raw
printed wiring boards (unpopulated) and similar devices, such as organic
chip carriers. As you know, PWB's are made up of a number of materials
which would, ideally, be considered homogeneous materials: fiberglass,
dielectric resins or films, copper, soldermask, individual metal
finishes,
osp... Once fabricated, these materials are intimately combined; while
possible, academically, to separate those materials from finished
product,
that material collection would be impractical on a continuing basis.
Now: the idea of "mechanically disjointed", from the WEEE faq document.
Again, one could argue that a finished pwb can't be mechanically
disjointed
in a manner which would render compliance inspection/analysis
realistically
possible.
Now: the need to validate supplier certifications through lab analysis.
If
I call the whole PWB the homogeneous material, then I grind up same and
submit that for analysis. No problem. Except that I have lost all
relation
to the ideal homogeneous materials in the item. If, on the other hand, I
try to analyze at the ideal homogeneous material level, I am forced to
work
under a scope with small tools, extracting (digging) and separating
minute
amounts of certain materials from many pieces in order to collect enough
material to give reasonable detection limits in the analytical tests.
Impractical.
As customers and as fabricators, are you calling the whole PWB a
homogeneous material or are you applying the definition and MCV to the
glass, dielectric, etc.?
Thanks much! jw
!! God Blesses !!
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]
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