Brian, The standard does not require a guarantee that the supplier’s products comply with the Directive. It asks for a good faith, due diligence effort in assessing the trustworthiness of the supplier’s information through procedures you put in place to evaluate the trustworthiness. These procedures may involve some sort of an audit of the supplier’s processes and/or the bases for their declarations.
There is a vagueness here. You must establish procedures and document them so they are clearly defined to all in your company. You must decide if your procedures meet the intent of the standard and can be defended if need be (i.e., are reasonable). Jim __________________________ James L. Knighten, Ph.D. EMC Engineer Teradata Corporation 17095 Via Del Campo San Diego, CA 92127 858-485-2537 – phone 858-485-3788 – fax (unattended) From: Mark Schmidt [mailto:mark.schm...@dornerworks.com] Sent: Wednesday, May 14, 2014 1:04 PM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] RoHS on Hardware Brian, May I be candid here. A local hardware store in the USA is not going to have traceability to RoHS compliance. It is highly likely they won’t even know what it is. Testing is way too expensive and time consuming, I would even go as far to say it’s unreliable as well. Procurement from a larger supplier just means that they have more people to generate Declarations and make claims about RoHS in an attempt to sell more hardware. Maybe if they print a pretty green leaf or some type of RoHS logo next to the part in their catalog it make it even more believable. My point here is until the industry (globally) moves to eliminate the use and no longer support the use of these hazardous substances called out in RoHS, you will never know for sure if it is compliant or not. I do believe that if your internal people try to attain a declaration and possibly a test report that will suffice on the behalf of Due Diligence in the legal sense. The reality is you will never know for sure if it is RoHS compliant from batch to batch or supplier to supplier but having a declaration may allow you to sleep better at night. Regards, Mark From: Kunde, Brian [mailto:brian_ku...@lecotc.com] Sent: Wednesday, May 14, 2014 3:25 PM To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG> Subject: Re: [PSES] RoHS on Hardware Jim, This is exactly the motivation behind my original email. How can the trustworthiness of a supplier be evaluated without testing? In a long supply chain it only takes one buyer to mess up the batch. And the larger distributor companies buy from the largest number of suppliers making the odds of an error along the chain even greater. I think our internal RoHS people get so frustrated at times they think that they must be missing something and feel other companies must know something that we don’t that would make the entire process much easier. Thanks, Brian From: Knighten, Jim L [mailto:jim.knigh...@teradata.com] Sent: Wednesday, May 14, 2014 2:35 PM To: Kunde, Brian; EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG> Subject: RE: RoHS on Hardware Brian, There is a harmonized standard (EN 50581:2012 )now to accompany the RoHS Directive. Complying with the standard provides you with the legal presumption of compliance with the RoHS Directive. The standard requires you to (a) collect information on the RoHS compliance of your nuts, bolts, washers, etc., but also to establish procedures to evaluate the trustworthiness of the information you collect. I think this will be difficult to do if you are purchasing parts from your local hardware store. A larger supplier will probably be able to supply a declaration regarding RoHS and can provide you a path to travel to evaluate the trustworthiness of the declarations. Jim __________________________ James L. Knighten, Ph.D. EMC Engineer Teradata Corporation 17095 Via Del Campo San Diego, CA 92127 858-485-2537 – phone 858-485-3788 – fax (unattended) From: Kunde, Brian [mailto:brian_ku...@lecotc.com] Sent: Wednesday, May 14, 2014 6:10 AM To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG> Subject: [PSES] RoHS on Hardware Our internal people working on and maintaining RoHS compliance are having a very difficult time getting the cooperation we need from our Hardware suppliers (nuts, bolts, washers, etc.). Our company manufacturers a relatively small quantity of products so it is impossible for us to purchase hardware direct from the manufacturer or their distribution. In fact, some of our “specialty hardware” has such a long supply chain in most cases we cannot even find out who made the part. As an example, for some parts, we might go over to our local Ace hardware store and buy a handful of parts which will last us two years worth of production. So here is the problem; with such long supply chains we are having a very difficult time getting RoHS supporting documentation for such hardware. So any advice or options would be most appreciated. What are other companies out there doing in such cases? Being an EMC/Safety guy I really do not have much knowledge in all the procurement stuff, however, would it be a practical option to periodically pull a small sample of all such parts and have them tested for RoHS? Any other suggestions? Thank you, 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 <emc-p...@ieee.org<mailto:emc-p...@ieee.org>> 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://www.ieee-pses.org/list.html (including how to unsubscribe)<http://www.ieee-pses.org/list.html> List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas <emcp...@radiusnorth.net<mailto:emcp...@radiusnorth.net>> Mike Cantwell <mcantw...@ieee.org<mailto:mcantw...@ieee.org>> For policy questions, send mail to: Jim Bacher <j.bac...@ieee.org<mailto:j.bac...@ieee.org>> David Heald <dhe...@gmail.com<mailto:dhe...@gmail.com>> ________________________________ LECO Corporation Notice: This communication may contain confidential information intended for the named recipient(s) only. 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