Hello Quality partners, need your wise advice and opinion:

Our steel suppliers are RoHS compliant and have provided to us each a letter of Certificate of Conformance stating "this letter is intended to be a certificate of compliance for material that is supplied meeting standards for RoHS compliance. Based on information from the producing mill in the MSDS reports and the chemical composition of the material, there is a 0% concentration of the following elements: Cr+6, Pb, Hg, Cd."

Now we have a customer that still wants our company to send samples of our steel for testing to a laboratory for further analysis which is very expensive. I believe this is redundand and not needed because our steel suppliers are already ensuring to us with their COC's about RoHS compliance, any issues of nonconpliance could be traced back to the steel suppliers.

Our customers are really pushing for this extra testing, I am trying to find a persuasive argument to convince them to change their mind and accept our COC's. What are your opinions?

Thanks in advance you quality partners..:agree:

Now we have a customer that still wants our company to send samples of our steel for testing to a laboratory for further analysis which is very expensive. I believe this is redundand and not needed because our steel suppliers are already ensuring to us with their COC's about RoHS compliance, any issues of nonconpliance could be traced back to the steel suppliers.




I'd offer your customer a price qoute for the extra testing.

Mike

Hello Quality partners, need your wise advice and opinion:

Our steel suppliers are RoHS compliant and have provided to us each a letter of Certificate of Conformance stating "this letter is intended to be a certificate of compliance for material that is supplied meeting standards for RoHS compliance. Based on information from the producing mill in the MSDS reports and the chemical composition of the material, there is a 0% concentration of the following elements: Cr+6, Pb, Hg, Cd."

Now we have a customer that still wants our company to send samples of our steel for testing to a laboratory for further analysis which is very expensive. I believe this is redundand and not needed because our steel suppliers are already ensuring to us with their COC's about RoHS compliance, any issues of nonconpliance could be traced back to the steel suppliers.

Our customers are really pushing for this extra testing, I am trying to find a persuasive argument to convince them to change their mind and accept our COC's. What are your opinions?

Thanks in advance you quality partners..:agree:A C of C is not enough. Where is the data to back it up? Get the data from you supplier.

Our steel suppliers are RoHS compliant and have provided to us each a letter of Certificate of Conformance stating "this letter is intended to be a certificate of compliance for material that is supplied meeting standards for RoHS compliance. Based on information from the producing mill in the MSDS reports and the chemical composition of the material, there is a 0% concentration of the following elements: Cr+6, Pb, Hg, Cd."

Your suppliers are allegedly RoHS (Restriction of Hazardous Substances (http://en.wikipedia.org/wiki/RoHS)) compliant. What objective evidence do you have?

Now we have a customer that still wants our company to send samples of our steel for testing to a laboratory for further analysis which is very expensive. I believe this is redundand and not needed because our steel suppliers are already ensuring to us with their COC's about RoHS compliance, any issues of nonconpliance could be traced back to the steel suppliers.

In general, CoC's are worthless in terms of providing objective evidence of anything. Suppose your company wanted to become ISO-registered. Do you suppose that you could send the registrar a Certificate of Compliance and thus avoid an actual audit?
...I am trying to find a persuasive argument to convince them to change their mind and accept our COC's. What are your opinions?

I don't think that what your customers are asking is unreasonable. They specify that the materials you use must be RoHS compliant. They want objective evidence to substantiate your claim of compliance. In a case such as this, objective evidence comes from independent testing.

This is a matter of contract review. You may be able to work up the cost of testing and negotiate sharing it with the customer(s), but don't count on it.

Do you get material certs from you supplier?
A C of C and Material Certs should be enough.

If they still insist on the testing tell them you'll have to work the testing costs into the price.

I'd offer your customer a price qoute for the extra testing.

MikeNot acceptable. If you are making a claim, you need data to back it up.

In general, CoC's are worthless in terms of providing objective evidence of anything. Suppose your company wanted to become ISO-registered. Do you suppose that you could send the registrar a Certificate of Compliance and thus avoid an actual audit?



I dunno - we satisfy our customers with a blanket RoHS statement and material certs provided by brass and steel suppliers.

And our customer are pretty compliance savvy (large medical device companies).

I dunno - we satisfy our customers with a blanket RoHS statement and material certs provided by brass and steel suppliers.

And our customer are pretty compliance savvy (large medical device companies).

Companies are free, in general, to set the bar as high or low as they please, notwithstanding regulatory requirements. Juliov's customers are (understandably) asking for objective evidence. I should also point out that if PPAP (a la AIAG) is involved, the manual specifically states that "the organization" is responsible for testing.

From the AIAG PPAP manual, Fourth Edition, page 6:
The organization shall perform tests for all parts and product materials when chemical, physical, or metallurgical requirements are specified by the design record or Control Plan.

If your supplier has given you the certificate, then they must have done the testing using an outside certification lab. They should provide this evidence to you. If they cannot, then the burden of proof lies with your organization.

When I had to do a RoHS project for an electronics software firm that bought the computer chips and just programmed them, I made certain that the manufacturer of the chips provided me with verifiable test reports against the limits set out in the RoHS legislation.

--QG

Jim, thanks. I am also considering that the purchasing mgr should have been more aware and had anticipated this issue before it got this far, after all the purchasing dept is dealing with the suppliers in the early stages of the process, now in my QA Mgr function at this stage it appears that there is not much I can make happen, and the info is bouncing back and forth, the parties that can make this issue be solved are the branch mgr and the purchasing mgr.

Jim, thanks. I am also considering that the purchasing mgr should have been more aware and had anticipated this issue before it got this far, after all the purchasing dept is dealing with the suppliers in the early stages of the process, now in my QA Mgr function at this stage it appears that there is not much I can make happen, and the info is bouncing back and forth, the parties that can make this issue be solved are the branch mgr and the purchasing mgr.

You're right that it should have been anticipated, but not all purchasing people have the technical knowledge and expertise that quality managers have (or should have). That's why it's always a good idea to get as much interdisciplinary input as possible at the RFQ stage.

True. Jim, not many companies involve the QA Mgr in the RFQ's process, at least not in mine, however, involving the QA Mgr and other functions withing the process will play an important role in mitigating compliance risks later on.
RoHS compliance is catching many companies unprepared, compliance is even being regulated here in the US, I believe Califorania will be enforcing RoHS by Jan 2007, thus, Europe is not the only place.

True. Jim, not many companies involve the QA Mgr in the RFQ's process, at least not in mine.

If you were going to rob a bank, you wouldn't ask the police department to send a representative to the planning meeting. :cool: :D

Yes, oh, I see. The "QA cop mentality", well, many noncompliances' root causes can be traced back to it. I do know that RoHS will be more strictly enforced. I would welcome info from some of our partners that have gone through the preparation phase and successful implementation of RoHS.

First we have to understand that most 'certificate of analysis' are issued by in-house or contracted labs which for economic and traditional requirements are using equipments deemed not precise or sensitive enough to deal with the kind of precision that RoHS required.

RoHS requirement specifically mandate that tests need to be carried out using only certain types of equipment/method such as ICP-MS (inductively coupled plasma mass spectrometry) or XRF (X-ray fluorescence spectrometers). Which is also the reason why its so expensive.

Over here, I know that companies like Matsushita only require you to submit such test reports once in 6 months. One company that I know of negotiated with their resin supplier for a copy of such test once in a year - which means they themselves need to carry out such an analysis once in a year also so that there are 2 sets of test report for submission per year.

Meanwhile, they also require these suppliers to submit the traditional 'COA' for every batch of materials supplied for monitoring and record purpose.

Regards.

I dunno - we satisfy our customers with a blanket RoHS statement and material certs provided by brass and steel suppliers.

And our customer are pretty compliance savvy (large medical device companies).Medical devices are exempt from the RoHS requirements right now. So, they shouldn't have much concern.

At my company we only use two grades of steel both of which, if manufactured to specification, comply with RoHS requirements.

So here's the stupid question. Are there any common grades of steel available which do not comply with RoHS?

When lead is is used as an alloying element in steel you may get upto 0.35% as weight but this is covered in the annex of RoHS.

Tyker, according to one of our steel suppliers these are noncompliant steels:
1. passivated/chem treated hot dipped galvanized, electro-galvanized and galvalume steel sheet.
2. hot dipped galvanized and galvalume steel sheet which get paintable passivation sold for post painting applications.
3. painted hot dipped galvanized and galvalume steel sheet which are toll-painted at coil coaters under single bill that have not been qualified to an alternative pretreat system.
4. acrylic coated galvalume or acrylic coated hot dipped galvanized steel sheet.

COMPLIANT ITEMS ARE:
A. Hot rolled steel sheet (dry or oiled)
B. Cold rolled steel sheet (dry or oiled
C. Hot dipped galvanized (dry or oiled, but not passivated/chem treated)
D. Galvalume (dry or oiled, but not passivated/chem treated)
E. Electro-galvanized steel sheet (liled, but not passivated/chem treated)
F. Black plate (Dry or oiled)
G. Tinplate and tin-free steel (TFS also known as ECS) both contain very light coatings of trivalent chromium compounds and metallic chromium but no detectable level of Cr(VI).

I hope this helps.

Many thanks for the replies and the effort that went into getting the information.
I'm fortunate that I don't have to worry about leaded or coated grades.


:thanks:

Hello Quality partners, need your wise advice and opinion:

Now we have a customer that still wants our company to send samples of our steel for testing to a laboratory for further analysis which is very expensive. I believe this is redundand and not needed because our steel suppliers are already ensuring to us with their COC's about RoHS compliance, any issues of nonconpliance could be traced back to the steel suppliers.

Our customers are really pushing for this extra testing, I am trying to find a persuasive argument to convince them to change their mind and accept our COC's. What are your opinions?

There are 2 issues here - one is on RoHS and you are completely compliant and there are no issues attached.

However, the additional Customer Specific requiremements also need to be absent. There is a standard called as IECQ 080000 addressing "Hazardous Substance Process Management System Requirements (HSPM)" which combines RoHS plus customer dictated requirements.

This std can be obtained from IEC Webstore. I am attaching a very good presentation for your info.

I am little curious about methods such as ICP MS and XRF are being required.

First thing is I doubt ICPMS can tell what the oxidation state of chromium in a sample is. From what I remember of my training as an analytical chemist a method such as AES (Auger Electron Spectroscopy) or a more traditional wet chemistry method, reacting the compound and then using a colourimetric method, would need to be used.

XRF has always been in my experience at best a semi-quantitative technique and certainly not one to be used where an accurate measurement is required.

These methods also have very low limits of detection (certainly in the parts per billion range) where as RoHS seems to be using percentage impurity which even when as low as 0.01% is still equivalent to 100 ppm which can be easily, cheaply and accuratley measured using methods such as flame AAS (Atomic Absorption Spectroscopy) or AES (Atomic Emission Spectroscopy).

Are these really the requirements?

Medical devices are exempt from the RoHS requirements right now. So, they shouldn't have much concern.


even so - some are asking for it.
And other customers are not exempt and are happy with what we've sent them as long as the material certs from our suppliers are in order.

of course it makes no financial sense whatsoever for a customer to require us to provide our own testing because our parts are, in general, not expensive.

This is not an uncommon request. In cases where a customer considers the material to be of high risk of non-compliance, by their standards, they feel that they need to show they have done due diligence on their data requests. What I suggest is that you provide XRF qualitative data to show a screening of the data for the absence of the substances. This is much less costly compared to a lab analysis and should meet their verification needs.

Mike, I believe our customer is going the extra mile to ensure their compliance to RoHS. Can you expand a bit about the XRF qualitative data screening, would this really comply to RoHS? interesting.
Thanks,

The approach using XRF is not to provide a full analysis, but to confirm the resonability of the lab data that was provided by your metal supplier. There is no real value added in repeating lab tests unless there is a reason for concern at your end. An XRF scan to determine the presence of a substance, or confirm that a substance is there provides a proof of "due diligence" (see http://www.rohs.gov.uk/content.aspx?id=7 ). the verification scan with XRF is the suggested approach to have taken all reasonable steps or precautions and have exercised all due diligence to avoid committing the offence. I have an explanation of due diligence posted at http://www.rsjtechnical.com/WhatisDueDiligence.htm . Proving you have verified the data should be what they are looking for, not full retest.

With the reported numbers of incorrect submission data possibly still being as high as 20-30%, it is not surprising that this is being requested. Depending on who the material is processed at your facility, you may want to do the scan post processing to verify that no contaminents were introduced during processing.
Hope this helps.

Absolutely. Thanks Mike for the advice. I'll review the two links you provide in order to get more info.

[QUOTE=Jim Wynne;169885]

In general, CoC's are worthless in terms of providing objective evidence of anything. Suppose your company wanted to become ISO-registered. Do you suppose that you could send the registrar a Certificate of Compliance and thus avoid an actual audit?


QUOTE]

I agree with Jim completely.
CoC's can't provide objective evidence. IMHO even Chemical and Physical certs are not enough.
What we have been doing: Collect 2 random coupons from each material supplier per year, send to our independant lab for testing. This works as part of our auditing our supplier, and as objective evidence.

The approach using XRF is not to provide a full analysis, but to confirm the resonability of the lab data that was provided by your metal supplier. There is no real value added in repeating lab tests unless there is a reason for concern at your end. An XRF scan to determine the presence of a substance, or confirm that a substance is there provides a proof of "due diligence" (see http://www.rohs.gov.uk/content.aspx?id=7 ). the verification scan with XRF is the suggested approach to have taken all reasonable steps or precautions and have exercised all due diligence to avoid committing the offence. I have an explanation of due diligence posted at http://www.rsjtechnical.com/WhatisDueDiligence.htm . Proving you have verified the data should be what they are looking for, not full retest.

Mike, thanks for your input. That kind of wrap up the whole discussion on this topic. With regards to methods of analysis, many others such as AAS, ICP-OES, ICP-AES are used also. Check with your client (especially Sony) if they have any required/preferred methods or even labs.

Regards.

Harry,
I'm glad you pointed out that XRF isn't the only verification approach. Any that your customer accepts will work. The key, especially for European RoHS compliance is that, like all areas of quality, it has to be part of a an ongoing process. When REACH hits us, those processes will be even more critical.

JulioV,

We manufacture springs, and so far we have never had a request to send material out to make sure it was RoHS compliant. Our customers either supply us with their standard certification form to fill out or ask us to supply a Certificate of Conformance on our letterhead stating our compliance to RoHS.

Most of our customers already require us to send material (steel) out for testing on their PAPP’s. They want to make sure that it meets the requirements of either the ASTM or customer specification for the steel shown on the blueprint. The cost of the testing is always included in our pricing. The quote may not say "outside testing" but its hidden in there somewhere. If we start getting requests for RoHS compliance, it would work the same way.

Kim

Thanks for the info Kimmy, it appears that we will be reviewing this issue in order to implement a new procedure that will factor in the cost of lab analysis in the price quotes.

Thanks for the info Kimmy, it appears that we will be reviewing this issue in order to implement a new procedure that will factor in the cost of lab analysis in the price quotes.

Taking Kimmy's suggestion a step further, it's always good, imo, to have detailed cost breakdowns, even if they're never shown to the customer. First, having breakdowns encourages having empirical cost data to work with, rather than guesswork and dartboard estimates, and second, when customers inevitably come looking for cost reductions, it's possible to present them with a "menu" and ask them which part(s) of your processing they want to eliminate. This can often have the salutary affect of making the customer reconsider arbitrary demands.