Guenter,
Now look what you've done - I had to go look up what "mnemonic" is in a
dictionary - and it's my language! :)
Seriously, you can't say that "a homogeneous material is a material that
can not mechanically be separated into further homogeneous materials IS
A MNEMONIC" and "It's to ILLUSTRATE (caps my addition) that the
individual layer is addressed not the entire piece which is coated."
The language of the EU RoHS document and the subsequent explanation page
no where say they are using mnemonics and nonbinding illustrations. The
last I heard legislation was to be taken literally, unless specifically
pointed out to be otherwise.
"The problem is to prove that the layer is Cr(VI) if you are not sure."
The problem is NOT to prove the presence of Cr(VI) or not. The test is
very easy to do and only requires some chemical training, a cheap UV-vis
spectrometer and the method in the draft TAC document that is
essentially copied out of known procedures. Our nice spectrometer costs
about $6K and I bet you could get one that would do the test for less
than $2K. The issue is whether one is over the limit or not. Unless I
know the weight or the density and volume (so I can calculate weight) I
do not know if I am over, under or near the limit.
"But forget any analysis on RoHS compatibility on your own. It's
prohibitively expensive and work intensive. One can scratch at the
surface of the analysis but an in-depth analysis is a job for a well
equipped lab and a customer with a big (full) wallet."
I could not let these sentences go unanswered. I have already stated
and shown to a certain extent how easy it is to do the Cr(VI)
presence/absence. Much more can be done with a handheld XRF (~$45K US)
- presence/absence of Pb, Cd, Hg, Cr and Br and certainly the ppm level
of the first three in metals (assuming you have enough sample(s) and can
disassemble to the expletive deleted homogeneous level). And yes it is
a labor intensive job and expensive to do EVERYTHING. I agree on that.
I am a PhD inorganic chemist and have a lab with, among others, a PhD
materials scientist, MSc analytical chemist, BSc chemist, the UV-vis as
already mentioned, a benchtop XRF, SEM/EDX/WDX and an ICP-OES, so we can
do it ourselves. And why wouldn't we? My friend, using an outside lab
is not going to be that cheap - try explaining to an outside lab what a
"homogeneous material" is and watch they eyes light up when they realize
how much money they really are going to be able to suck out of you.
Also, many well equipped analytical labs have never tested electronics
parts before and don't even know the trigger from the barrel, so to
speak. I have also found at least one reputable lab using a very
credible, but not applicable EPA procedure - instead of the required
procedure.
(And even with all the above, I still need the help of an outside lab
for GC-MS for the brominated fire retardant testing - at >$250(US) per
sample!)
It will be interesting in the years to come to see if my company will
let me publicly document the cases (sanitized of course) of good
corporate citizens screwing up and giving us non-RoHS compliant parts.
"... a customer with a big (full) wallet" - if I were to go to Bell
Canada, Verizon or Orange, etc and tell them they were going to directly
pay for RoHS testing, can't you imagine what they really would say to
me?! It is never going to happen.
And finally - Good luck to those of you relying only on compliance
documentation.
Bev
RIM
-----Original Message-----
From: Leadfree [mailto:[log in to unmask]] On Behalf Of Guenter Grossmann
Sent: Monday, May 22, 2006 3:42 AM
To: [log in to unmask]
Subject: [LF] Antw: Re: [LF] Cr(VI) Analysis - I have a question
All
Just forget about separating the CrVI layer from ist surface. The
definition that a homogeneous material is a material that can not
mechanically be separated in further homogeneous materials is a mnemonic
(Joke for Werner: a donkey bridge). It's to illustrate that the
individual layer is addressed not the entire piece which is coated. You
can not weight the CrVI layer but you know there is this layer and it is
CRVI which is banned that's it and you have to use CrIII instead. The
problem is to proof that the layer is CrVI if you are not sure. Also
that's possible. But forget any analysis on RoHS compatibility on your
own. It's prohibitively expensive and work intensive. One can scratch at
the surfe of the analysis but an in depth analysis is a job for a well
equipped lab and a customer with a big (full) wallet.
Best regards
Guenter
EMPA
Swiss Federal Laboratories for Materials Testing and Research
Centre for Reliability
Guenter Grossmann, Senior Engineer
8600 Duebendorf
Switzerland
Phone: xx41 1 823 4279
Fax : xx41 1 823 4054
mail: [log in to unmask]
>>> [log in to unmask] 19.05.2006 21:10 >>>
I realize it is difficult to win battles with pure logic. I've
watched Star Trek in all its permutations.
John
At 02:12 PM 5/19/2006, you wrote:
>John Sieber has asked a logical question about whether a layer that
>cannot be removed without destroying it, thereby rendering it
unsuitable
>for chemical analysis, could be regarded as "homogeneous" by the
>drafters and interpreters of the RoHS directive. The underlying
>assumption is that the drafters and interpreters of the directive are
>logical and will respond to logic. For many obvious reasons people who
>are responsible for putting electronic equipment on the market in
Europe
>cannot afford to make that assumption.
>
>Gordon Davy
>
>
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