RoHS Compliance - Steel - Customer wants additional samples tested

Jim Wynne

Staff member
Admin
#11
Re: RoHS compliance

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.
 
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J

juliov

#12
Re: RoHS compliance

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.
 
J

juliov

#14
Re: RoHS compliance

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.
 

harry

Super Moderator
#15
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.
 

Al Rosen

Staff member
Super Moderator
#16
Re: RoHS compliance

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.
 
T

tyker

#17
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?
 
C

chergh - 2008

#18
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.
 
J

juliov

#19
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.
 
T

tyker

#20
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:
 
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