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
      
  





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