Brain,
Dan is right that that is up to your legal department and your management. If your company is big, your customers are expecting you to do it in greater depth. In the contrast, the small company is unable to effort doing too much. How can they survive? This principle is not only applied to RoHS but also the REACH Directive. Should we have a session to discuss the minimum requirements and share the practical experience in execution. For example, lots of people are talking about a piece of DoC. My past experience indicated that in the morning, our suppliers asked for what is RoHS Directive and the contents and in the afternoon, they sent you a piece of DoC. Should we accept it in such scenario?? I believe that is more useful discussion in this forum and help each other to implement the Directive in a practical approach. Regards, Scott From: [email protected] [mailto:[email protected]] On Behalf Of Daniel Roman Sent: 2009年1月10日 03:31 AM To: Kunde, Brian; [email protected] Subject: RE: How is your company doing RoHS? Brian, RoHS compliance is primarily a procurement requirement and IMHO that is where the responsibility should lie. Your compliance lab can consult on the Directive, but the heavy lifting needs to be done by those that control the supply chain. How should you control the supply chain? That is up to your legal department and your management. It is a liability and customer service issue. What are your customers going to expect or demand from you? Whatever your legal and management team is willing to live with is what your company would need to do. It could be simply taking the word of a supplier’s datasheet or statement on their web page; it could be demanding a DoC; or you could go crazy and send every component to a lab for testing (not practical if you have 18K components). For keeping track of it all, some PDM systems like Matrix or Agile have RoHS modules (for an extra fee). They can even track exemptions for you, which is very useful if an exemption goes away like Deca-BDE did recently. Of course if you have a lot of components and you are starting from scratch, that is a lot of research and data entry that needs to be done. When RoHS hit a few years ago we hired temps to help out the Component Engineers, Buyers, and Purchasing staff and still needed to farm out some of our database to external consulting firms to get it all done. Compliance Engineers help interpret Directive and scope out the work but were not involved in the component qualification effort. Every vendor and part number needs to be checked and how much work that will be depends on what level of verification you want to do. Some vendors are great and have detailed info and DoCs on their web sites. The easiest are the ones that have purged all non-RoHS and have a blanket statement that covers their entire product line. Some vendors are horrible and you need to make phone calls and request the info for each individual part. If you are going lead-free as well you need to worry about process compatibility as well because of high temperatures! In my company, Component Engineers have the primary RoHS responsibility. Dan From: Kunde, Brian [mailto:[email protected]] Sent: Friday, January 09, 2009 1:45 PM To: [email protected] Subject: [PSES] How is your company doing RoHS? Because it is proposed to have RoHS fall under the CE Marking scheme, the big boss people here want to throw the whole mess over the wall to the Compliance Lab (that’s me). Please don’t beat me up too much for being a RoHS Newbie, but can those who know help me with a few questions? How do you keep track or document that the parts you buy and used to build your products meet the RoHS requirements? For example: * Is a Statement on your part print good enough? * Do you have to keep a data sheet or letter from each manufacturer stating their part(s) meet RoHS? If so, how do you store this information and how often do you have to check to see if it is still current? If and when the new proposals to the RoHS Directive is complete, best guess, how much time will we have to comply to any new requirements? 2 years? Currently some of our products fall under one of the Exemptions but we are trying very hard to be RoHS anyway. If our exemption goes away in the future, how much time would we have to comply? 2 years? Answers to this question will determine if you have to hire one person or 10. We have something like 18,000 parts that have to be gone over. Thanks for you help. The Other Brian _________________________ LECO Corporation Notice: This communication may contain confidential information intended for the named recipient(s) only. If you received this by mistake, please destroy it and notify us of the error. Thank you. - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to <[email protected]> All emc-pstc postings are archived and searchable on the web at http://www.ieeecommunities.org/emc-pstc Graphics (in well-used formats), large files, etc. can be posted to that URL. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/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: Jim Bacher <[email protected]> David Heald <[email protected]> - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to <[email protected]> All emc-pstc postings are archived and searchable on the web at http://www.ieeecommunities.org/emc-pstc Graphics (in well-used formats), large files, etc. can be posted to that URL. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/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: Jim Bacher <[email protected]> David Heald <[email protected]> - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to <[email protected]> All emc-pstc postings are archived and searchable on the web at http://www.ieeecommunities.org/emc-pstc Graphics (in well-used formats), large files, etc. can be posted to that URL. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/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: Jim Bacher <[email protected]> David Heald <[email protected]>
