RESEND as there seemed to be some problem with first transmission.
Regards, Lauren Crane KLA-Tencor [snip] John, A small detail - the term of art for RoHS is 'homogeneous layer' rather than 'separable part'. Scott, REACH strives to control substance use with a couple 'lists'. The so-called 'Candidate List substances' (a.k.a. 'SVHCs') *are* permitted above a 0.1% weight of substance per total weight of article placed on the market (as John described), but the importer/manufacturer must give notice of the substance being present to the recipient. There is another list in REACH, Annex XVII, which contains a list of substances, each one having a special condition of restriction, a couple of which are outright bans for certain sector uses. There is a third list in REACH, Annex XIV, which contains a list of substances for which Authorization is required before they can be used (a defacto ban, perhaps). REACH absolutely *allows* (or rather, does not restrict) the use of "hazardous" substances, and must be read in conjunction with the CLP Regulation (Classification, Labeling and Packaging of chemical substances), to be fully understood. The CLP Regulation is what now defines "hazardous" along the lines of the UN GHS model. There are hundreds of thousands of hazardous substances in routine industrial and consumer use, all completely allowable under REACH (provided certain information accompanies and labels the containers). Some member states are in protest (to ECHA) of the REACH approach to Candidate List substances where the notification threshold is measured against the total weight of the article placed on the market (e.g., John's generator), and have adopted (German & Belgium, I think) or are threatening to adopt a philosophy of "once an article, always an article". This "once an article, always an article" philosophy would present a third measurement method where one must conceptually break the larger article into its constituent articles and then analyze each of these. Regards, Lauren Crane KLA-Tencor From: John Cotman [mailto:[email protected]] Sent: Monday, January 30, 2012 4:00 AM To: [email protected] Subject: Re: [PSES] REACH - a concentration of 0.1% (w/w). Scott, Not quite sure if I understand your question, but RoHS and REACH approach the concentration issue differently. In RoHS, you are not permitted to exceed the concentration of a restricted substance in any separable part. The effect of this, which I've personal experience of, is that a complete electrical product fails because of excess hexavalent chrome in the plating of tiny terminal screws, because the plating can be scraped off the screw and is therefore treated as a "separable part". With REACH, it's a proportion by weight of the complete product; you don't break it into pieces. The effect of this, in theory, is that a large generator, say, weighing several tons, could have a few Kg of something quite nasty in it. However, if it's all in a single component, the manufacturer of that component is also bound by REACH, since it's a product in its own right. Not sure if this helps? John C ________________________________ From: Scott Xe [mailto:[email protected]] Sent: 28 January 2012 09:43 To: [email protected] Subject: [PSES] REACH - a concentration of 0.1% (w/w). Recently, there is a discussion about the permissible concentration of 0.1% for SVHCs. If a component is smaller than 0.1% (w/w), the article is considered acceptable even though the component consists of 100% SVHC. I believe the REACH regulation is to regulate SVHCs not to be used in the product. It does not mean the product is allowed to use small amount of SVHCs. It is similar to RoHS directive. The original directive did not allow any content of hazardous substances. However, other EU member points out that in production, even though it does not use the hazardous substances, it may have pollution into the production units. It is unavoidable and does not mean you can intentionally add the hazardous substances to the permissible level. Can anyone be aware if REACH adopts the same from RoHS directive. Thanks, Scott - - ---------------------------------------------------------------- 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.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. 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]>
