In message <003301cf73df$89a38510$9cea8f30$@cs.com>, dated Mon, 19 May
2014, Pete Perkins <00000061f3f32d0c-dmarc-requ...@ieee.org> writes:
It's one thing to have a Directive which depends upon 'good faith' in
some way - which the RoHS program has been depending upon for some
years now - but to add RoHS into the MDoC which is a legal document
that carries personal criminal penalties for the signator adds
considerably to the discomfort level of proof of conformity. It's
going to take lots of Tums for the tummy antacid pills to work this thru.
I think there is a countervailing aspect here. See below. But keep
taking the tablets.
Large companies can pour lots of money into complex
programs to demonstrate compliance (and moan and complain all the
while) but small companies don't have the same level of resources for
similar work
It might seem distasteful at first, because it wouldn't be at all good
for EMC or, especially, safety, but one has to take into account whether
the presence of 1 ppb of unobtanium is likely to be searched for in a
3 mm screw in a product made in modest quantities by a small company.
This realism is certainly countered by the approach taken by the
authorities on RoHS, where it is assumed that these minute quantities of
toxic material are *bound* to result in harm to people and/or the
environment. The probability of such harm, which is often obviously
vanishingly small, is simply not taken into account.
For about 30 years, the electronics industry, including high-volume
consumer products, used passivated cadmium plating, combining the bête
noirs of cadmium and hexavalent chromium in quite large amounts, not
ppb. How many mass extinctions resulted? I'm not saying we should go
back to using it; it's an avoidable risk, but the RoHS thing has lost
the sense of proportion that it may actually never had.
--
OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk
Nondum ex silvis sumus
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK
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