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August 2014

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Subject:
From:
Bev Christian <[log in to unmask]>
Reply To:
TechNet E-Mail Forum <[log in to unmask]>, Bev Christian <[log in to unmask]>
Date:
Sat, 30 Aug 2014 20:05:17 -0400
Content-Type:
text/plain
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text/plain (130 lines)
Phil,
Well our lawyers said that if we out a leather holster in a box with a smart
phone, then, yes, the leather holster must meet RoHS.  

I can't imagine virgin processed hydrocarbon oil having any of the six
substances covered by RoHS.  A good XRF should be able to tell you quick
enough, if you need confirmation.

However, I should warn you about BNST, which the Canadian government is
banning. See the material below, which I copied from the ECD page and thus
why the link to a company. I have no monetary connection myself to ECD.

"BNST Substances Restricted in Canada – July 2014
The substance group BNST was added to the Canadian Regulation “Prohibition
of Certain Toxic Substances Regulations, 2012 (the Prohibition Regulations)”
under the Canadian Environmental Protection Act, 1999, and these regulations
came into force on March 14, 2013. BNST is an abbreviation for “Benzenamine,
N-phenyl-, Reaction Products with Styrene and 2,4,4-Trimethylpentene”. Risk
assessment under the Canadian chemical management plan led to the
identification of risk management measures that were necessary and the
subsequent restriction of BNST.

BNST may be found in lubricants that are sometimes used for high-speed
electrical motors in electronic products such as DVD players.

The Prohibition Regulations prohibit the manufacture, use, sale, offer for
sale or import of BNST and is also applicable to products containing BNST
with a limited number of exemptions. The restriction takes effect starting
March 14, 2015. Permits to continue using the substance for up to three
years after the 2015 prohibition date are also possible. An application for
a permit must be submitted to the Minister of the Environment and it must
contain the information specified in Schedule 4 of the Prohibition
Regulations.

The Prohibition Regulation is available for download from the Canada
Gazette.

ECD Compliance can assist manufacturers with this regulation."
http://web.ecdcompliance.com/contact-us


Here is also a Canadian government page.
http://www.ec.gc.ca/ee-ue/default.asp?lang=en&n=4FB2776F-1



Regards,
Bev
-----Original Message-----
From: TechNet [mailto:[log in to unmask]] On Behalf Of GABRIELE SALA
Sent: Thursday, August 28, 2014 4:18 PM
To: [log in to unmask]
Subject: [TN] R: [TN] fluids covered by RoHS?

Hi Phil,

Is oil or coolant essential part of your EEE? I mean does your EEE needs
such oil to run? If yes it is in the scope of RoHS.
Probably oil does not contain any of the  6 substances controlled by RoHS
(Lead (Pb), Mercury (Hg), Hexavalent chromium (Cr(VI)), Cadmium (Cd),
Polybrominated Biphenyl flame retardants (PBB), and Polybrominated Diphenyl
Ether flame retardants (PBDE)
By the way, you need to check with your supplier or by reading Data Sheet
and MSDS as well. It could be contained flame retardant like: PBB or PBDE? 

If oil is used as part of the process you run on such EEE, in that case oil
is considered as a consumables and out of the scope of RoHS II (2011/65/EU).

Gabriele

-----Messaggio originale-----
Da: TechNet [mailto:[log in to unmask]] Per conto di Nutting, Phil
Inviato: giovedì 28 agosto 2014 21:40
A: [log in to unmask]
Oggetto: [TN] fluids covered by RoHS?

We have a unit that is being requested by the customer to be RoHS compliant.
This unit uses Diala dielectric oil and ethylene glycol as coolant.  To date
we have coded RoHS compliant parts by adding a G prefix to our letter
revision of the assembly.  Therefor when reviewing a Bill of Materials we
can quickly see what is and is not RoHS compliant.  Our internal process
calls for all revisions of all parts to have a G prefix to call the top
level (finished [product) RoHS compliant.

We have batteries in these and I know they are not covered by the RoHS
directive.

Should I be concerned with the oil or coolant?

Phil Nutting  |  HVP Development Engineer   |  Excelitas Technologies Corp

Lab: +1 978.224.4332   |  Office: +1 978.224.4152
35 Congress St, Salem, MA  01970 USA
[log in to unmask]<mailto:[log in to unmask]>
www.excelitas.com<http://www.excelitas.com/>


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