Nice thread and very to the point! But what suppliers need to supply is
compliant parts, and the required declarations and analyses are market
driven, isn't that correct? The RoHS Directive doesn't spell out this
analysis requirement. So if you don't believe your supplier, or just
want to be certain, you request it down to the level of a poorly defined
homogeneous substance. A customer can ask for whatever they want to and
as a supplier, I try to provide whatever we can within reason. Testing
silicon die for PBB and PBDE's tries my patience and budget, however.
We're doing our best in Colorado, but the interpretations have certainly
changed in the lead-up (reverse pun intended) to RoHS implementation.
Best regards,
Tom Davenport
[log in to unmask]
VP QRA
Ramtron International Corporation
www.ramtron.com
-----Original Message-----
From: Leadfree [mailto:[log in to unmask]] On Behalf Of John Burke
Sent: Tuesday, January 24, 2006 10:02 AM
To: [log in to unmask]
Subject: Re: [LF] Declaration of compliance with material analysis
You have my sympathy on that one.
Your interpretation of the homogenous is correct, and do not let your
management tell you differently!!
I also spent many a trip to the Far East in a recent employment
explaining at length why a lab analysis of a complete ground up unit was
useless.
Many companies simply have no clue or do not have the money/bandwidth to
get down to the homogenous level, so sending it out to a lab is their
idea of getting the job done quickly!!
John
John Burke
Senior Manager - Operations , Optichron
[log in to unmask]
W: 510 249 5233
M: 408 515 4992
http://www.optichron.com
Profile: https://www.linkedin.com/e/fps/2665502/
-----Original Message-----
From: Leadfree [mailto:[log in to unmask]] On Behalf Of Denis Ryskamp
Sent: Tuesday, January 24, 2006 7:20 AM
To: [log in to unmask]
Subject: Re: [LF] Declaration of compliance with material analysis
Hello all
I used to have dark brown hair but now I am gray!
Am I the only one or are others experiencing companys that provide a
declaration of compliance for their product and also send a material
analysis of the sub-components which is not performed to the Homogeneous
level just the whole sub-component ground up and tested?
Management here is asking if we are misinterpreting the Homogeneous
level
compliance requirement for a product incorporated into our product.
Seems
that some products (OEM and non-OEM) purchased are tested this way. When
reviewing the sub-component analysis, for example lead may be 129 ppm.
Figuring 10% (high)of the total weight of a connector is plating where
the
lead would be found, then one could assume that at the homogeneous level
(plating) lead would be 1290 ppm which is over the limit.
Comments?
Thanks,
Denis
-----Original Message-----
From: Leadfree [mailto:[log in to unmask]]On Behalf Of MA/NY DDave
Sent: Friday, January 20, 2006 3:13 PM
To: [log in to unmask]
Subject: Re: [LF] Exemption of OEM products.
Hi Again David, BrianE, Genny, IPC LF Listservers,
David, Lots of good notes and thinking were posted that will hopefully
help
you with your customer and will help us think through the many
situations.
Following BrianE's logic which is good, and that crazy, to me, teddy
bear
example in the Guidance documents, I thought about Large Household
Appliances and other similar future complications.
Now most of us know that the EU hopes to recover, reuse large household
appliances to reduce them going in the dump. (80% goal). YET if I have a
Gas fired range/stove, clothes washer, clothes dryer, or other major
appliance are the electrical/electronics that part of these appliances
enough to make them EEE or is the electronics/electrical portion of
these
appliances just a tag along to their prime function. I.E. the teddy bear
example used for other products. The full gas stove, with minimial
electronics except for sensing/control is probably a weaker EEE than a
talking, winking, human interacting, solar powered teddy bear.
Yours in Engineering, Dave
YiEngr, MA/NY DDave
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