No - it remains per the levels present in homogeneous parts of each component. Just specify on your fab drawing the assy must be RoHS compliant, check your vendor understands what is required, get a DofC >from your vendor/sub contractor - subcontractors are going to have source rohs compliant parts in their own right, after all it's just another manufacturing process. Much as we would have liked it, NOTHING in RoHS is based on the sum of an assembly, it is ALL based on homogeneous levels of each and every blessed part. C
_____ From: jeff collins [mailto:[email protected]] Sent: 08 September 2005 21:57 To: James, Chris; jeff collins; JEFF WHITMIRE; Gordon,Ian Cc: [email protected]; [email protected] Subject: RE: RoHS: Proof of Supplier Component Compliance Ok.....That is making a lot more sense except when I think of something like a cable assembly that is made of several individual parts and put together by my CM. How would you address the levels in this scenerio? As individual components or the sum of the assembly? Jeff C "James, Chris" <[email protected]> wrote: because the levels are per homgenous parts of each part and not as a % of the total of the unit. If each homegenous part is within spec then so is the unit. You are also assuming that there is some level of banned substance in all parts whereas the banned substances will in many cases be removed altogether. _____ From: jeff collins [mailto:[email protected]] Sent: 08 September 2005 20:59 To: JEFF WHITMIRE; Gordon,Ian; James, Chris Cc: [email protected]; [email protected] Subject: RE: RoHS: Proof of Supplier Component Compliance Group, So I'm "partially" in agreement with everybody it seems which is why I raised this issue. For the group that believes you do not need a CoC showing the Mass and % of Content of the banned substances, how do you determine ( Without testing ) that your equipment does not contain more than the maximum allowable levels of the banned substances? My point here is, spot checking is great but if I can calculate this while I'm selecting my components, I think I'm way ahead of the game compared to the guys who won't find this out until after they test. Also, there are certain materials under the RoHS ANNEX which are exempted from the requirements based on their mass and content. Again, I would rather know this sooner by having it in on my CoC rather than later by testing. I do agree that testing is ALWAYS the best way to ensure conformance however there are a lot of proactive / front end things that you can do to reduce the amount of testing. For example, I also do reliability MTBF calculations and frequently try to use the vendor data whenever possible. However there are vendors that provide great MTBF numbers with little supporting data and there are other vendors that also provide great MTBF numbers with a lot of supporting data. So it easy to guess in this scenario which vendor I will invest the time to re-run and verify their calculations? And .....normally, the vendor that provided the least amount of supporting data number's are usually incorrect or flawed. So I focus my testing/calculating efforts on those vendors that provide little data and spot check the others. So I still ask, since those vendors must know the Mass and % of Content of the banned substances, what's the harm in putting this info on the CoC. Thanks for all the replies......... Jeff C JEFF WHITMIRE <[email protected]> wrote: Since I am discussing particular vendors, I have taken my discussion off of the list server. I agree with Ian and Chris. You gain nothing by tracking all the detailed data on each part. You are no further ahead of the game than with a D of C. You are still trusting that the vendor is providing accurate data. That is where spot tests are valuable. There are several vendors out there offering databases. No vendor that I have seen so far has a complete database. I2 software has partnered with UL and they are trying to sell everyone the service of testing all of these components and putting them in a database that they can then resell to others. Other vendors such as IHS and PartMiner have databases have similar capabilities. Entry level into these types of programs is around $200K. Once you have the software, you have to invest in another dozen people internally to the company to maintain the data and keep it accurate with your BOM and keep after the vendors whose data is not in the database. Most of these databases have data that is provided by the vendor, with no actual verification testing. UL is supposed to add the test capability for RoHS in China and are lowering the cost for these tests. My personal opinion in all of this. Regards, Jeff Whitmire -----Original Message----- From: [email protected] [mailto:[email protected]] On Behalf Of Gordon,Ian Sent: Thursday, September 08, 2005 4:53 AM To: 'James, Chris'; jeff collins; [email protected] Subject: RE: RoHS: Proof of Supplier Component Compliance Jeff I agree with Chris in that we accept D of C's for other directives without insisting on seeing every report for every item. However I also agree with you that the question arises "how do they know its compliant if they cant give me the data that shows it?". I have found that some electronic component manufacturers do provide this data but many "ancillary component" (e.g. crimp terminals, DIN rails etc) manufacturers do not. Some of our customers like to see the chemical composition of our products. If you find a database which people can use easily then please let me know - the only way I have been able to get RoHS data is by contacting individual suppliers and giving them a list of parts I would like data on. Ian Gordon -----Original Message----- From: James, Chris [mailto:[email protected]] Sent: 08 September 2005 10:23 To: jeff collins; [email protected]; [email protected] Subject: RE: RoHS: Proof of Supplier Component Compliance Have you 100% self test for every other operation or claim that vendors make for their products on existing D of C's - I doubt it. So why get paranoid now? Accepting D of C's is permissible but ought if practicable be backed up by spot testing. Getting details of the composition is not a requirement of RoHS and would add significant burden to do so. Why push for more than is required - if too many people push then it will become a defacto requirement and then a mandatory requirement. Do you take your car home after a smog check and then take it to a lab to have it checked again or do you accept the smog station certificate? Regards, Chris ____________ From: [email protected] [mailto:[email protected]] On Behalf Of jeff collins Sent: 08 September 2005 09:55 To: [email protected]; [email protected] Subject: RoHS: Proof of Supplier Component Compliance Group, I am finding several component suppliers ( many who are major mfr's ) that will issue a COC or letter of conformity to RoHS but with no Evidence of compliance or even a breakdown of the weights or percentages of the hazardous substances. Is anyone else having this issue? This puts us in a position where we either have to: * Blindly accept their COC/Letter of conformance and HOPE they really are compliant and do not exceed the hazardous threshold limits. * Have their components tested. ( An expensive option ) * Change suppliers to one that can provide this info ( A very very painful and expensive option at this point ) So I know this is a rhetorical question but how can they claim compliance for their components and not know the Mass and % of Content of the banned substances? Thanks, Jeff Collins _____ This message (including any attachments) may contain confidential information intended for a specific individual and purpose. If you are not the intended recipient, delete this message. If you are not the intended recipient, disclosing, copying, distributing, or taking any action based on this message is strictly prohibited. ---------------------------------------------------------------- This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. Website: http://www.ieee-pses.org/ To post a message to the list, send your e-mail to [email protected] Instructions: http://listserv.ieee.org/listserv/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas [email protected] Mike Cantwell [email protected] For policy questions, send mail to: Richard Nute: [email protected] Jim Bacher: [email protected] All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc ---------------------------------------Leadfee Mail List provided as a service by IPC using LISTSERV 1.8d To unsubscribe, send a message to [email protected] with following text in the BODY (NOT the subject field): SIGNOFF Leadfree To temporarily stop/(start) delivery of Leadree for vacation breaks send: SET Leadfree NOMAIL/(MAIL) Search previous postings at: http://listserv.ipc.org/archives Please visit IPC web site http://www.ipc.org/contentpage.asp?Pageid=4.3.16 for additional information, or contact Keach Sasamori at [email protected] or 847-615-7100 ext.2815
