Re: [PSES] RoHS on Hardware

[Nick Williams]

Lauren,

Are you able to point to anything published by the Commission on this?

Nick. 

On 20 May 2014, at 18:15, Crane, Lauren lauren.cr...@kla-tencor.com wrote:

 
 It has recently been interpreted (by Commission and other authorities) as 
 prohibiting the resale of any in-scope but out-of-compliance EEE after July 
 2019 because of an awkward wording in Article 2(2) -- i.e., no 
 grandfathering even for items already on the market.  There is a project 
 afoot to possibly amend this concern (a public consultation recently closed 
 about this, I believe). 
 
 Regards,
 Lauren Crane
 KLA-Tencor
 
 

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Re: [PSES] RoHS on Hardware

[Crane, Lauren]

Nick, 

Not the Commission per se. The point was mentioned in a public consultation 
document put out by Oeko Institut (I assume at the direction of the 
Commission), link provided below, and offending paragraph as follows

 As a consequence of the current wording, non-compliant products that have 
been placed on the market3 between January 2013 and July 2019, are not allowed 
any secondary market operations after 22 July 2019.

http://rohs.exemptions.oeko.info/fileadmin/user_upload/RoHS_IA_2_2/Products_newly_in_scope/Questionnaire_Products_newly_in_scope_final.pdf


There is a broader interpretation of this that has been expressed by UK NMO. 
Ref the slide deck posted at http://www.aham.org/ht/a/GetDocumentAction/i/61298

Which includes Article 2.2 uses the term make available and not place on 
the market. Non-compliant EEE on the market cannot continue to be distributed 
after 22 July 2019.

Hope that helps 

Regards,
Lauren Crane
KLA-Tencor


-Original Message-
From: Nick Williams [mailto:nick.willi...@conformance.co.uk] 
Sent: Friday, May 23, 2014 6:53 AM
To: Crane, Lauren
Cc: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] RoHS on Hardware

Lauren,

Are you able to point to anything published by the Commission on this?

Nick. 

On 20 May 2014, at 18:15, Crane, Lauren lauren.cr...@kla-tencor.com wrote:

 
 It has recently been interpreted (by Commission and other authorities) as 
 prohibiting the resale of any in-scope but out-of-compliance EEE after July 
 2019 because of an awkward wording in Article 2(2) -- i.e., no 
 grandfathering even for items already on the market.  There is a project 
 afoot to possibly amend this concern (a public consultation recently closed 
 about this, I believe). 
 
 Regards,
 Lauren Crane
 KLA-Tencor
 
 

-

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Re: [PSES] RoHS on Hardware

[John Woodgate]

In message 003301cf73df$89a38510$9cea8f30$@cs.com, dated Mon, 19 May 
2014, Pete Perkins 0061f3f32d0c-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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Re: [PSES] RoHS on Hardware

[John Woodgate]

In message d22e43ccd5394f3d829c9f5b5764a...@thhste15d1be4.hs20.net, 
dated Tue, 20 May 2014, Charlie Blackham char...@sulisconsultants.com 
writes:


Compliance requirements are discussed on 
https://www.gov.uk/rohs-compliance-and-guidance


 

?Due diligence? is the name of the game.

 

And from 
https://www.gov.uk/government/uploads/system/uploads/attachment_data/fil

e/236285/bis-13-1142-restriction-of-hazardous-substances-regulations-gui
dance-2.pdf


But these are valid in Britain only, not Europe-wide. Also, what really 
doesn't make sense is the principle:


For the purposes of the RoHS Regulations, a maximum concentration
value of up to X% by weight in homogeneous materials for [toxic 
substances] will be permitted in EEE.


It's NOT the percentage that matters; it's the actual mass of toxin. As 
it is, (1.1*X)% in a 1 g part is not allowed but X% of a 10 kg part IS 
allowed.

--
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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Re: [PSES] RoHS on Hardware

[Charlie Blackham]

 But these are valid in Britain only, not Europe-wide

Yes, but there is (meant to be) co-ordination between enforcement bodies.

 It's NOT the percentage that matters; it's the actual mass of toxin. As it 
 is, (1.1*X)% in a 1 g part is not allowed but X% of a 10 kg part IS allowed.

Most EEE isn't going to have 10kg of homogenous material

Charlie


-Original Message-
From: John Woodgate [mailto:j...@jmwa.demon.co.uk] 
Sent: 20 May 2014 12:53
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] RoHS on Hardware

In message d22e43ccd5394f3d829c9f5b5764a...@thhste15d1be4.hs20.net,
dated Tue, 20 May 2014, Charlie Blackham char...@sulisconsultants.com
writes:

Compliance requirements are discussed on 
https://www.gov.uk/rohs-compliance-and-guidance

 

?Due diligence? is the name of the game.

 

And from
https://www.gov.uk/government/uploads/system/uploads/attachment_data/fi
l 
e/236285/bis-13-1142-restriction-of-hazardous-substances-regulations-gu
i
dance-2.pdf

But these are valid in Britain only, not Europe-wide. Also, what really doesn't 
make sense is the principle:

For the purposes of the RoHS Regulations, a maximum concentration value of up 
to X% by weight in homogeneous materials for [toxic substances] will be 
permitted in EEE.

It's NOT the percentage that matters; it's the actual mass of toxin. As it is, 
(1.1*X)% in a 1 g part is not allowed but X% of a 10 kg part IS allowed.--
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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Re: [PSES] RoHS on Hardware

[John Woodgate]

In message 57e1de017da548f694a6d03394b38...@thhste15d1be4.hs20.net, 
dated Tue, 20 May 2014, Charlie Blackham char...@sulisconsultants.com 
writes:



But these are valid in Britain only, not Europe-wide


Yes, but there is (meant to be) co-ordination between enforcement 
bodies.



It's NOT the percentage that matters; it's the actual mass of toxin. As it is, 
(1.1*X)% in a 1 g part is not allowed but X% of a 10 kg part
IS allowed.


Most EEE isn't going to have 10kg of homogenous material


I don't really think that's the point. Make it 1 kg or 100 g, it's still 
not sensible.

--
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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Re: [PSES] RoHS on Hardware

[John Cotman]

What makes even less sense is that RoHS has gone the % per homogeneous material 
route, whereas REACH limits are the %age by weight of the complete product.

John C



On 20 May 2014, at 14:08, John Woodgate j...@jmwa.demon.co.uk wrote:

 In message 57e1de017da548f694a6d03394b38...@thhste15d1be4.hs20.net, dated 
 Tue, 20 May 2014, Charlie Blackham char...@sulisconsultants.com writes:
 
 But these are valid in Britain only, not Europe-wide
 
 Yes, but there is (meant to be) co-ordination between enforcement bodies.
 
 It's NOT the percentage that matters; it's the actual mass of toxin. As it 
 is, (1.1*X)% in a 1 g part is not allowed but X% of a 10 kg part
 IS allowed.
 
 Most EEE isn't going to have 10kg of homogenous material
 
 I don't really think that's the point. Make it 1 kg or 100 g, it's still not 
 sensible.
 -- 
 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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Re: [PSES] RoHS on Hardware

[John Woodgate]

In message c7ef2973-9b5b-45cd-b580-f46862671...@conformance.co.uk, 
dated Tue, 20 May 2014, John Cotman john.cot...@conformance.co.uk 
writes:


What makes even less sense is that RoHS has gone the % per homogeneous 
material route, whereas REACH limits are the %age by weight of the 
complete product.


Yes. Probably the REACH people saw the RoHS approach and then saw the 
light.

--
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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Re: [PSES] RoHS on Hardware

[Crane, Lauren]

One nuance of the RoHS challenge, is its potential impact to the used equipment 
market. As recent discussions here have shown, it's hard enough to 'prove' 
conformance for products currently in production. Even more so for used 
products that will be newly on the EU market (imported). Since it seems 
entirely impractical to test a complicated product, much less defend it via 
data about components (the component data owners won't share, threw it away 
long ago, or are out of business), the door is closing on used in-scope 
equipment entering Europe. 

On a related note, I attended a seminar including a presentation by the UK RoHS 
enforcement officer from NMO. He pointed out some oddities in the Blue Guide 
that impact the understanding of when something is placed on the market. 
Particularly, it's not when the item is imported, but only when it is supplied 
to a distributor or user by the importer. And even more odd is that placing on 
the market does not occur if a company imports something for their own use. 
This is not much relief for directives that also impose requirements when 
something is put in to service (like the Machinery Directive), but RoHS does 
not have this. 

Here is the blue guide section upon which this argument hinges. (page 17)
 A product is placed on the market when it is made available for the first 
time on the Union market. The operation is reserved
either for a manufacturer or an importer i.e. the manufacturer and the importer 
are the only economic operators who place
products on the market [46]. When a manufacturer or an importer supplies a 
product to a distributor [47] or an end-user for the first
time, the operation is always labelled in legal terms as placing on the 
market. Any subsequent operation, for instance, from a
distributor to distributor or from a distributor to an end-user is defined as 
making available.  

Of course, a revision of the Blue Guide could quickly close any opportunity 
this odd wording might represent. 



Regards,
Lauren Crane
KLA-Tencor

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Re: [PSES] RoHS on Hardware

[John Cotman]

Yes, equipment imported for own use does not need to be RoHS compliant as you 
say.  What happens when the importer no longer needs it is an interesting 
question, though.  It would seem that it can't legally be sold, but it can be 
thrown away.  This is rather perverse, given that environmental legislation 
generally would favour reuse.

RoHS a really daftly structured directive.

John C.


On 20 May 2014, at 16:01, Crane, Lauren lauren.cr...@kla-tencor.com wrote:

 One nuance of the RoHS challenge, is its potential impact to the used 
 equipment market. As recent discussions here have shown, it's hard enough to 
 'prove' conformance for products currently in production. Even more so for 
 used products that will be newly on the EU market (imported). Since it seems 
 entirely impractical to test a complicated product, much less defend it via 
 data about components (the component data owners won't share, threw it away 
 long ago, or are out of business), the door is closing on used in-scope 
 equipment entering Europe. 
 
 On a related note, I attended a seminar including a presentation by the UK 
 RoHS enforcement officer from NMO. He pointed out some oddities in the Blue 
 Guide that impact the understanding of when something is placed on the 
 market. Particularly, it's not when the item is imported, but only when it 
 is supplied to a distributor or user by the importer. And even more odd is 
 that placing on the market does not occur if a company imports something for 
 their own use. This is not much relief for directives that also impose 
 requirements when something is put in to service (like the Machinery 
 Directive), but RoHS does not have this. 
 
 Here is the blue guide section upon which this argument hinges. (page 17)
  A product is placed on the market when it is made available for the first 
 time on the Union market. The operation is reserved
 either for a manufacturer or an importer i.e. the manufacturer and the 
 importer are the only economic operators who place
 products on the market [46]. When a manufacturer or an importer supplies a 
 product to a distributor [47] or an end-user for the first
 time, the operation is always labelled in legal terms as placing on the 
 market. Any subsequent operation, for instance, from a
 distributor to distributor or from a distributor to an end-user is defined as 
 making available.  
 
 Of course, a revision of the Blue Guide could quickly close any opportunity 
 this odd wording might represent. 
 
 
 
 Regards,
 Lauren Crane
 KLA-Tencor
 
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Re: [PSES] RoHS on Hardware

[John Woodgate]

In message fc549dd1-1f68-46e1-baf5-463482b34...@conformance.co.uk, 
dated Tue, 20 May 2014, John Cotman john.cot...@conformance.co.uk 
writes:


Yes, equipment imported for own use does not need to be RoHS compliant 
as you say.  What happens when the importer no longer needs it is an 
interesting question, though.  It would seem that it can't legally be 
sold, but it can be thrown away.  This is rather perverse, given that 
environmental legislation generally would favour reuse.


Does the Directive apply to second-hand products, including those made 
before the Directive came into effect?


RoHS a really daftly structured directive.


Indeed, but of course the authorities will not admit it. But after ten 
years or so, something is changed. Look at what happened with 
after-market product EMC and the Automotive Directive.


Now, if 'hi-fi' separates come back into fashion, everything except the 
tuner will be under the EMC Directive, but the tuner will be under the 
RTED, which apparently means that CISPR 32 and 35 won't apply, despite 
having full EMC requirements for tuners.

--
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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Re: [PSES] RoHS on Hardware

[Crane, Lauren]

Of course, RoHS applies to all otherwise-in-scope second-hand products made at 
any time that are newly placed on the EU market (from a per-unit perspective, 
not a per-model line perspective). 

It has recently been interpreted (by Commission and other authorities) as 
prohibiting the resale of any in-scope but out-of-compliance EEE after July 
2019 because of an awkward wording in Article 2(2) -- i.e., no grandfathering 
even for items already on the market.  There is a project afoot to possibly 
amend this concern (a public consultation recently closed about this, I 
believe). 

Regards,
Lauren Crane
KLA-Tencor


-Original Message-
From: John Woodgate [mailto:j...@jmwa.demon.co.uk] 
Sent: Tuesday, May 20, 2014 10:48 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] RoHS on Hardware

In message fc549dd1-1f68-46e1-baf5-463482b34...@conformance.co.uk,
dated Tue, 20 May 2014, John Cotman john.cot...@conformance.co.uk
writes:

Yes, equipment imported for own use does not need to be RoHS compliant 
as you say.  What happens when the importer no longer needs it is an 
interesting question, though.  It would seem that it can't legally be 
sold, but it can be thrown away.  This is rather perverse, given that 
environmental legislation generally would favour reuse.

Does the Directive apply to second-hand products, including those made before 
the Directive came into effect?

RoHS a really daftly structured directive.

Indeed, but of course the authorities will not admit it. But after ten years or 
so, something is changed. Look at what happened with after-market product EMC 
and the Automotive Directive.

Now, if 'hi-fi' separates come back into fashion, everything except the tuner 
will be under the EMC Directive, but the tuner will be under the RTED, which 
apparently means that CISPR 32 and 35 won't apply, despite having full EMC 
requirements for tuners.
--
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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Re: [PSES] RoHS on Hardware

[John Woodgate]

In message 
e758c0fcde4a41f2b615646852fab...@blupr03mb119.namprd03.prod.outlook.com
, dated Tue, 20 May 2014, Crane, Lauren lauren.cr...@kla-tencor.com 
writes:


Of course, RoHS applies to all otherwise-in-scope second-hand products 
made at any time that are newly placed on the EU market (from a 
per-unit perspective, not a per-model line perspective).


Of course 'newly placed' applies only to non-compliant products 
initially imported for 'own use' and subsequently offered for disposal 
sale. Not a frequent event, and practically impossible to police.


It has recently been interpreted (by Commission and other authorities) 
as prohibiting the resale of any in-scope but out-of-compliance EEE 
after July 2019 because of an awkward wording in Article 2(2) -- i.e., 
no grandfathering even for items already on the market.  There is a 
project afoot to possibly amend this concern (a public consultation 
recently closed about this, I believe).


Does anyone not understand why people in Britain are exasperated with 
this sort of nonsense from Brussels? I understand it's even worse 
outside the electronics industry. Mango (fly-free), anyone?


At least it seems that the requirement to discard (dead) fish that 
shouldn't have been caught is being changed. Maybe someone, thinking no 
further than line fishing in a river, thought that if thrown back they 
would come alive again.

--
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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Re: [PSES] RoHS on Hardware

[Dan Roman, N.C.E.]

On 05/20/14, John Woodgatejmw@JMWA.DEMON.CO.UK wrote:At least it seems that the requirement to discard (dead) fish that  shouldn't have been caught is being changed. Maybe someone, thinking no  further than line fishing in a river, thought that if thrown back they  would come alive again.I believe the reasoning for the fish is if they allowed fisherman to keep theby-catch they would have no incentive to avoid catching what they were notfishing for in the first place.Perhaps the same sort of logic is being applied in the area of RoHS andother Directives in respect to "previously owned" equipment whether ornot it was already on the market. Give manufacturers an "out" and theymight find ways to use it too often.I do not know if any of this is based on actual surveillance and statistics orby study of human nature.--Dan Roman, N.C.E.Senior Member, IEEEVP Communications ServicesIEEE Product Safety Engineering Societymailto:dan.roman@ieee.orghttp://www.ieee-pses.org
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Re: [PSES] RoHS on Hardware

[John Woodgate]

In message 29772537.1146244.1400616153990.JavaMail.root@vms170027, 
dated Tue, 20 May 2014, Dan Roman, N.C.E. danp...@verizon.net 
writes:


I believe the reasoning for the fish is if they allowed fisherman to 
keep the
by-catch they would have no incentive to avoid catching what they were 
not

fishing for in the first place.
 
Well, this is very OT, but do you really think that they WANT to catch 
unsaleable fish? The incentive not to is that you don't get any money 
for catching it.


The effect of the policy is to reduce the stocks of prey fish that the 
saleable fish feed on.

--
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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Re: [PSES] RoHS on Hardware

[John Cotman]

It's a shockingly bad piece of standard writing.  Requirements in standards 
must be objective and measurable, such that suitably qualified people 
exercising reasonable skill would form the same view as to whether something 
complies or not.

The trustworthiness bit is not appropriate for a standard, particularly one 
that is supposed to provide a presumption of conformity, and I don't understand 
how it has been allowed to be published.  Quite what would happen if somebody 
relied on it in an enforcement action is anybody's guess.

Just my personal opinion!

John Cotman
Senior Consultant
Direct line: +44 1298 873841
Mobile: +44 7793 770730
email: john.cot...@conformance.co.uk

-

Conformance Ltd - Product safety, approvals and CE-marking consultants
The Old Methodist Chapel, Great Hucklow, Buxton, SK17 8RG England
Tel. +44 1298 873800, Fax. +44 1298 873801, www.conformance.co.uk
Registered in England, Company No. 3478646



On 14 May 2014, at 21:19, Knighten, Jim L jim.knigh...@teradata.com wrote:

 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
 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
 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

Re: [PSES] RoHS on Hardware

[John Woodgate]

In message 554dbd57-d1f3-4c4a-bade-09fedbcfe...@conformance.co.uk, 
dated Mon, 19 May 2014, John Cotman john.cot...@conformance.co.uk 
writes:



It's a shockingly bad piece of standard writing.


There may be a reason.

 Requirements in standards must be objective and measurable, such that 
suitably qualified people exercising reasonable skill would form the 
same view as to whether something complies or not.


In an ideal world, that would always be possible.


The trustworthiness bit is not appropriate for a standard, 
particularly one that is supposed to provide a presumption of 
conformity, and I don't understand how it has been allowed to be 
published.


Consider the people who are told to write the Directive (it's not a 
standard; Directives and standards are as different as sharks and lions.


They are told to regulate so that a long list of supposedly noxious 
substances are not present in excess of some 'parts per billion' figure, 
probably not based on toxicity but upon detection thresholds, which are 
continually being lowered. Looking over their shoulders are zealots who 
are not satisfied with anything, just grudgingly concede as an interim 
measure when assured of continual tightening of requirements.


Against this, we have the real world. Upwards of 50 million 3 mm screws 
are made each day, and the zealots will settle for nothing less than 
that EACH ONE is guaranteed not to contain more than 0.1 parts per 
billion of unobtainium. How do we apply 'objective and measurable' to 
these screws? Destroy each one in a mass spectrometer?


The only practical solution is to require the original batches of steel 
and brass to be analysed and certified. Then they are made into screws. 
Can each one be accompanied by its personalized DoC? At some point along 
the distribution chain, there has to be trust.


 Quite what would happen if somebody relied on it in an enforcement 
action is anybody's guess.


One would hope that a submission along the above lines might inject some 
sanity into the court, but it's a forlorn hope.


Just my personal opinion!


Of course.

Now, please tell us how you would solve the problem. Use no more that 
100 A4 sides.

--
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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[PSES] RoHS on Hardware

[Kunde, Brian]

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.

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Re: [PSES] RoHS on Hardware

[John Woodgate]

In message 
64D32EE8B9CBDD44963ACB076A5F6ABB026954D2@Mailbox-Tech.lecotech.local, 
dated Wed, 14 May 2014, Kunde, Brian brian_ku...@lecotc.com writes:


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.


No doubt those two scenarios apply to different parts. For parts you can 
get from the hardware store, you can probably get them from Mouser or 
so, with RoHS. For other parts, there may be no alternative to switch to 
a local jobbing supplier who can certify RoHS.

 

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?


There is a lot of advice to SMEs about this available in Europe, but I 
don't know about elsewhere.


 

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?


Option of last resort, probably, unless the part can be analysed by one 
of the clever new rapid methods, which may not be prohibitively costly.

--
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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Re: [PSES] RoHS on Hardware

[Doug Powell]

I have heard of mfgs using XRF guns to inspect their incoming stock. However 
this is generally not accepted as a initial qualification, only to validate 
incoming material as an A / B comparison. RoHS still requires a ppm assessment 
after breaking down to homogeneous ‎levels.  

Here in the USA, I suggest eliminating the trips to the local hardware store 
and buy from a distributor such as Grainger, McMaster, Hardware Specialty or 
others. They are all beginning ear marking parts for their RoHS compliance and 
sell in affordable quantites.

This will require a little discipline in a small business. I know how it is, 
trying to keep minimum stocking quantities low and having those days where you 
suddenly realize you are about to run out of a certain item that normally costs 
pennies.  ‎Establishing an inventory system may be required where you track 
usage, ordering lead time by supplier, identify minimum order quantities, 
calculate ordering points,  etc. I know more than a few who do this solely in 
spreadsheets. 



Thanks, - doug

Douglas Powell
http://www.linkedin.com/in/dougp01  
  Original Message  
From: John Woodgate
Sent: Wednesday, May 14, 2014 7:29 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Reply To: John Woodgate
Subject: Re: [PSES] RoHS on Hardware

In message 
64D32EE8B9CBDD44963ACB076A5F6ABB026954D2@Mailbox-Tech.lecotech.local, 
dated Wed, 14 May 2014, Kunde, Brian brian_ku...@lecotc.com writes:

 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.

No doubt those two scenarios apply to different parts. For parts you can 
get from the hardware store, you can probably get them from Mouser or 
so, with RoHS. For other parts, there may be no alternative to switch to 
a local jobbing supplier who can certify RoHS.
 

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?

There is a lot of advice to SMEs about this available in Europe, but I 
don't know about elsewhere.

 

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?

Option of last resort, probably, unless the part can be analysed by one 
of the clever new rapid methods, which may not be prohibitively costly.
-- 
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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Re: [PSES] RoHS on Hardware

[Anthony Thomson]

Could you purchase parts from the UK or Europe? RoHS is pretty much the 'norm' 
in Europe and the small volume distribution companies like RS, Farnell and 
many, many others now sell only (well, mostly) RoHS compliant product, while 
declaring the RoHS status of products in their catalogues/web sites.

Drop me an email if your need supplier suggestions for specific parts.

Just a thought.

Tony
- Original Message -
From: Kunde, Brian
Sent: 05/14/14 02:09 PM
To: 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 LT; 
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Attachments are not permitted but the IEEE PSES Online Communities site at 
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Website:  http://www.ieee-pses.org/
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Re: [PSES] RoHS on Hardware

[Knighten, Jim L]

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
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.orgmailto: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 
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List rules: http://www.ieee-pses.org/listrules.html

For help, send mail to the list administrators:
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For policy questions, send mail to:
Jim Bacher j.bac...@ieee.orgmailto:j.bac...@ieee.org
David Heald dhe...@gmail.commailto:dhe...@gmail.com

-

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

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)
List rules: http://www.ieee-pses.org/listrules.html

For help, send mail to the list administrators:
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David Heald: dhe...@gmail.com

Re: [PSES] RoHS on Hardware

[Mike Sherman ----- Original Message -----]

Based on a year of spot XRF testing hardware procured from a supplier with a 
pretty good RoHS program in place: 
1. Zinc with clear chromate is low risk. 
2. Yellow chromate traditionally is hexavalent chromium and therefore verboten 
under RoHS. 
3. Black chromate may or may not be RoHS compliant; no simple way to test. 
4. Black oxide is low risk. 
5. Cadmium can be a duller finish and can be easily tested with a drop of (I 
forget the specific chemistry) acid. We found more cadmium plating than we were 
expecting. 


Mike Sherman 
Graco Inc. 
Product Safety and Compliance Engineer 

- Original Message -
From: Anthony Thomson ton...@europe.com 
To: EMC-PSTC@LISTSERV.IEEE.ORG 
Sent: Wednesday, May 14, 2014 9:40:05 AM 
Subject: Re: [PSES] RoHS on Hardware 

Could you purchase parts from the UK or Europe? RoHS is pretty much the 'norm' 
in Europe and the small volume distribution companies like RS, Farnell and 
many, many others now sell only (well, mostly) RoHS compliant product, while 
declaring the RoHS status of products in their catalogues/web sites. 

Drop me an email if your need supplier suggestions for specific parts. 

Just a thought. 

Tony 





- Original Message - 

From: Kunde, Brian 

Sent: 05/14/14 02:09 PM 

To: 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 LT; 
emc-p...@ieee.org GT; 

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) 
List rules: http://www.ieee-pses.org/listrules.html 

For help, send mail to the list administrators: 
Scott Douglas LT; emcp...@radiusnorth.net GT; 
Mike Cantwell LT; mcantw...@ieee.org GT; 

For policy questions, send mail to: 
Jim Bacher LT; j.bac...@ieee.org GT; 
David Heald LT; dhe...@gmail.com GT; 



- 
 


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 LT; 
emc-p...@ieee.org GT; 

All emc-pstc postings are archived and searchable on the web at: 
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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) 
List rules: http://www.ieee-pses.org/listrules.html 

For help, send mail to the list administrators: 
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Mike Cantwell LT; mcantw...@ieee.org GT; 

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Jim Bacher LT; j.bac...@ieee.org GT; 
David Heald LT; dhe...@gmail.com GT;

-

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 
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http://www.ieee-pses.org/emc-pstc.html

Re: [PSES] RoHS on Hardware

[Kunde, Brian]

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
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.ORGmailto: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.orgmailto: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.netmailto:emcp...@radiusnorth.net
Mike Cantwell mcantw...@ieee.orgmailto:mcantw...@ieee.org

For policy questions, send mail to:
Jim Bacher j.bac...@ieee.orgmailto:j.bac...@ieee.org
David Heald dhe...@gmail.commailto:dhe...@gmail.com


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

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

Re: [PSES] RoHS on Hardware

[Mark Schmidt]

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
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.ORGmailto: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.ORGmailto: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.orgmailto: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

Re: [PSES] RoHS on Hardware

[Knighten, Jim L]

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.ORGmailto: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.ORGmailto: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.ORGmailto: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