Short answer
CoCs from a trusted vendor are considered by many as adequate for our industry.
Due Diligence is different depending upon who you are, what the risks are, and the difficulty of doing the test.
Due Diligence is also not defined legally anywhere (I have a vague feeling that it only has any use inside the UK).
You must decide and be able to defend your choice of Due Diligence.
Rex
-----Original Message-----
From: TechNet [mailto:[log in to unmask]] On Behalf Of Bev Christian
Sent: 25 May 2010 13:25
To: [log in to unmask]
Subject: Re: [TN] RoHS compliance of stainless stell
Rex,
CoCs only are not enough to satisfy the EU's definition of "due diligence" (I hate that term). When I asked what more I need to do, the answer I received (from the UK Department of Trade & Industry - now changed to BER, whatever that stands for) was "the courts will decide". Yeah, sure, like I want to go to court to find out!
So, working for a company with some deep pockets, we do a LOT of testing. I have no clue how they expect little companies to do more than collect CoCs.
Bev
RIM
-----Original Message-----
From: TechNet [mailto:[log in to unmask]] On Behalf Of Rex Waygood
Sent: Tuesday, May 25, 2010 8:20 AM
To: [log in to unmask]
Subject: Re: [TN] RoHS compliance of stainless stell
Approved vendor/Trusted source + CoC
Rex Waygood
Technical Manager
Hansatech EMS provides value manufacturing through engineering and quality
Hansatech EMS Limited
Benson Road
Nuffield Industrial Estate
Poole
Dorset
BH17 0RY
+44 (0)1202 338200
-----Original Message-----
From: TechNet [mailto:[log in to unmask]] On Behalf Of Ioan Tempea
Sent: 25 May 2010 13:14
To: [log in to unmask]
Subject: Re: [TN] RoHS compliance of stainless stell
Thanks Bev!
So after a tough week-end with the Habs being cut off this year's Stanley Cup final I find out one of my front runners, Bacardi, could be lead poisoning. Despicable! But, luckily, I only purchase liquors in glass bottles, so this one is taken care of, or at least I hope the Pb in glass is stable!
To summarize to date:
SS has no issue with Pb and CrVI
Cd as an alloying element for SS has not been mentioned and can't find any related texts on Internet either, so I guess I will consider no Cd in SS Because of austenitic vs martensitic nature of SS, magnets are not exactly the best way to validate RoHS compliance
Now, I think you've seen it coming: how do you assess the compliance of the SS parts you're using? CofC only?
Thanks,
Ioan Tempea, ing.
Ingénieur Principal de Fabrication / Senior Manufacturing Engineer T | 450.967.7100 ext.244 E | [log in to unmask] W | www.digico.cc
N'imprimer que si nécessaire - Print only if you must
-----Message d'origine-----
De : Bev Christian [mailto:[log in to unmask]] Envoyé : May-21-10 4:15 PM À : [log in to unmask] Objet : Re: [TN] RoHS compliance of stainless stell
Ioan,
Here are my answers to your questions below.
1) Can Stainless Steel be blindly considered RoHS compliant? Otherwise said, is there any SS hardware that could have any of the buggers (mainly Cd or Cr6)?
All stainless steels (assuming they are not coated - no reason why they would be, since they are inherently not prone to rust) would pass for Cr(VI) content.
BULK stainless steel does not contain lead and even if it did it could use the 0.3% by weight Pb exemption. However, see what I pulled off of the Health Canada website.
"Health Canada warns Canadians about potential lead exposure from stainless steel rum flasksWarning
2003-18
April 10, 2003
OTTAWA - Health Canada is warning Canadians that use of certain stainless steel liquor flasks may pose a lead exposure risk. The seams and the spout of the flasks in question were fastened together with solder that contains a high proportion of lead. Tests carried out by the Société des alcools du Québec (SAQ) on one brand of flask showed that, within 24 hours, hazardous levels of lead may leach out of the solder into liquid contained in the flasks. Therefore, anyone who drinks liquor or other liquids stored in the flasks for even short periods of time may be at risk of ingesting lead, particularly if the liquid is acidic.
Health Canada has information that gift sets containing these stainless steel flasks which may pose a lead exposure hazard were sold from 1999 to 2003 in provincial or territorial retail liquor outlets across Canada. Flasks sold in the gift sets were approximately 6 oz in size and may be wrapped with leather. Provincial and territorial liquor control boards have issued recalls for two Appleton Estate gift sets, each containing a 375-ml bottle of rum, a Bacardi White Rum gift set, and the Wiser's De Luxe Canadian Whisky gift set. Consumers are advised to contact their local retail liquor outlet for specific product recall, return and reimbursement information.
There is no lead exposure risk associated with drinking the bottled rum, whisky or other liquor included in the gift sets, provided that the liquors were not stored in the accompanying metal flask.
Although no incidents of lead poisoning following use of these flasks have been reported to date, Health Canada is advising Canadians who may have one of these flasks in their possession to stop using it immediately.
Lead is a toxic heavy metal. It can produce harmful effects on human health even at low levels of exposure. If you suspect lead poisoning from use of one of these flasks, contact your family physician who can order a blood test to measure your blood lead level.
Health Canada is investigating the import and sale of this type of liquor flask on the Canadian marketplace and will issue an update to this warning if necessary."
2) Also, could some SS fall under the Pb exemption for machining?
See my answer above
3) And finally, some SS alloys are magnetic, some other aren't. Can SS hardware used in our industry be magnetic?
No clue about this one.
Bev
RIM
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