Bev
That is one possible reading. I would read it slightly differently, based on
the context of the UK Government approach at the time.
I would say what they said goes/meant something like this.
We don't know what the Courts will do, they will look for a reasonable
standard of proof.
What is a reasonable standard of proof? We don't know till someone has gone
to court and established precedent. That is how English and similar legal
systems (including I think yours and US works). In conversations with them
at that time and with the UK Weights and Measures people here, who will be
enforcing the Law. They made it clear that they were not going to go after
companies - they thought that would be most - who had done their best to
comply, but got caught out. They would work in a non-adversary way with
them, but to go after the cowboys who were just ignoring the system or
blatantly not adhering. The alternative would be a complex mess of
regulations specifying every small detail of everything, something which
would be even more of an anathema.
.
I think since then things have moved on and it's the Company's
responsibility to go all the way through to CE marking.
Cautions:
Other Governments in EU will not necessarily be so pragmatic.
Fortunately I am no longer a student of Compliance regulations so might be
out of date.[Mike] [It used to drive me nuts.]
Mike
-----Original Message-----
From: TechNet [mailto:[log in to unmask]] On Behalf Of Bev Christian
Sent: Tuesday, January 29, 2013 1:34 AM
To: [log in to unmask]
Subject: Re: [TN] RoHS question
Jerry,
Short answer: get new suppliers.
Longer answer: you pay to have the RoHS testing done
Even longer answer: you get them to pay for the testing on threat of not
doing business with them any more
Oh and by the way, according to what was the British department of trade and
industry told me (I think they changed the name to something with the new
initials BER), collecting CoCs is NOT enough to show "due diligence" (a term
I HATE). When I asked them how much testing was required to show "due
diligence" the answer I got, wait for it (and this is a direct quote): "The
courts will decide." Yeah, right. I want my company to be the guinea pig to
find out the answer to THAT question! So, our suppliers are either
providing the lab tests to back up their CoCs or we are doing it ourselves
in-house. If you are a little company the latter is not realistic of
course.
Bev
RIM
-----Original Message-----
From: TechNet [mailto:[log in to unmask]] On Behalf Of Jerry Dengler
Sent: Monday, January 28, 2013 12:22 PM
To: [log in to unmask]
Subject: [TN] RoHS question
Hello Everyone,
For RoHS compliant PCB assemblies we collect and store RoHS C of C's for all
of the components and bare PCB's. We have now been asked to do a Finish
Goods build that will include a plastic housing and labels. The suppliers
of these are not going to issue a RoHS statement.
Has anyone else had this issue? If so what steps were taken to satisfy your
requirements?
Thanks,
Jerry Dengler
Production Manager
Pergamon Corporation
380 Crooked Lane, Unit# 3
King of Prussia, PA 19406-2567
U.S.A.
(610) 239-0721 Phone
(610) 239-0720 Fax
______________________________________________________________________
This email has been scanned by the Symantec Email Security.cloud service.
For more information please contact helpdesk at x2960 or [log in to unmask]
______________________________________________________________________
______________________________________________________________________
This email has been scanned by the Symantec Email Security.cloud service.
For more information please contact helpdesk at x2960 or [log in to unmask]
______________________________________________________________________
______________________________________________________________________
This email has been scanned by the Symantec Email Security.cloud service.
For more information please contact helpdesk at x2960 or [log in to unmask]
______________________________________________________________________
|
