Southern Compliance Association Newsletter

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UK authorities get tough over RoHS

RoHS enforcer NWML has been directed to take a tough stance over the new hazardous materials rules from day one as it starts to police the European Directive.......MORE

RoHS test technique comes under scrutiny

The National Physical Laboratory (NPL) is to study X-ray fluorescence (XRF) testing.....MORE

Warning: RoHS compliance not yet universal

Although 1st July passed off without much of the expected panic, RS is concerned that many UK companies need to do more to achieve compliance with RoHS legislation........MORE

83% of manufacturers’ systems risk failing RoHS compliance

A staggering 83% of manufacturers are at severe risk of not being able to demonstrate compliance for the now active European RoHS Directive........MORE

Meeting RoHS/WEEE/ELV compliance for Aluminium parts

Eliminating chrome from the workplace is part of a massive undertaking which will benefit both the environment and worker safety.........MORE

Chinese RoHS law differs from EU counterpart

China's RoHS law may be based on the EU RoHS Directive, but there are many differences between the now-current EU legislation and its Chinese counterpart.........MORE

UK authorities get tough over RoHS

RoHS enforcer NWML has been directed to take a tough stance over the new hazardous materials rules from day one as it starts to police the European Directive which came into law in the UK on July 1.

According to the enforcement authority, its policy will be to try and “help those that are aiming to comply, and pursue vigorously those that intend to flout compliance with the regulations”.

“The NWML has already been working closely with trade associations, quality systems organisations and individual companies providing advice and support on the interpretation of the regulations,” said the head of NWML’s RoHS department Chris Smith

Any non-complaint RoHS-affected product still on the way to Europe cannot be sold. “There is a particular threat for importers of electrical equipment whose product has not cleared customs,” said RoHS consultancy Eco3. “They will not be able to sell this product as it is the date of arrival that is key.”

Most firms are not yet fully-compliant, said Eco3’s Mark Shayler: “Our experience of training more than 400 businesses and 1,000 individuals across Britain has shown us that very few companies have really got to grips with what RoHS will mean to them.

(Electronics Weekly)

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RoHS test technique comes under scrutiny

The National Physical Laboratory (NPL) is to study X-ray fluorescence (XRF) testing, the front line technique for testing for and spotting RoHS non-compliance.

“The reason behind this is lack of confidence when using this technique for RoHS,” project head Dr Chris Hunt told us.

XRF testing determines which elements are present in a sample and involves firing a beam of X-rays at a sample and examining the returning electromagnetic spectrum. Handheld and more sophisticated benchtop testers are available.

What motivated the project was concern among a group of organisations that not enough experience exists in the industry to know if consistent and accurate results are being achieved.

“0.1 per cent is quite demanding for these machines,” said Hunt. “They can do it under certain circumstances. Some things can be difficult to see.”

The project, funded jointly by the DTI and the ten industrial partners, comes in two parts.

“We will get a range of samples, and the partners will measure them with the different XRF instruments they own,” said Hunt. “Then we will use chemical analysis to see accurately what is in the samples.”

Correlating the results should indicate when XRF can be used reliably and how the machines compare with each other. It will also allow the partners to remove errors in their systems.

In the second part of the project, said Hunt, NPL will make up standard samples with known quantities of contaminants to allow firms to calibrate their own XRF test set-ups.

The project starts now and will continue for six months, after which a detailed report will be produced for the project partners, including all data collected.

The work will be presented to the SSTC (NPL Soldering Science and Technology Club) and disseminated in an NPL Report.

(Electronics Weekly.)

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Warning: RoHS compliance not yet universal

Although 1st July passed off without much of the expected panic, RS is concerned that many UK companies need to do more to achieve compliance with RoHS legislation. The company also welcomes the NWML's moves to ensure that RoHS standards should be enforced equally throughout the region to increase compliance and confidence in products and components. RS is in an excellent position to comment on the RoHS act, as it is the primary supplier to the design community in the UK.

The company has found that although most UK companies have either complied or are close to completion, there are still a significant minority that have adopted a wait-and-see attitude and are either totally unprepared, or are slowly implementing the regulations while watching what is happening elsewhere.

Many of these companies may believe that enforcement officers are not active at the moment and want to see what happens to the first company punished, while praying that it's not them.

Surely it's only a matter of time?

Ignoring the regulations could be far more painful than implementing them.

There is a vast amount of help available, for example, RS has a whole section of its website dedicated to the legislation.

The first step an unsure company should take is to seek advice and determine if compliance is actually necessary, if it is believed that it does not impact the business, the reasoning should be carefully documented for explanation to the NWML.

If the company decides there is a need to comply, it should at first focus on inventory management and lead-free production.

Components should be purchased from trusted suppliers, especially those with the BSI 'RoHS Trusted' kitemark, and then staff should be trained in their own responsibilities.

These steps should also be carefully documented for the NWML as evidence of the company's attempt to comply.

RS' second concern is the lack of a unified approach to enforcement throughout the EU; every member state is responsible for its own enforcement.

This has led to confusion as to which agency is responsible for advice and enforcement in each country.

In the UK the NWML has been given responsibility, and the rules and standards are clear and stated, but this is not the case in most other member states.

That could be the source of the problem for UK companies.

Companies sourcing components manufactured outside of the UK may not have the necessary confidence that they have been subject to the same rigorous examination as those manufactured within the UK, and this could impact the status of the final product.

RS were so concerned about this aspect that the company have invested in an ED-XRF machine so it can independently verify offerings and give customers a 'double-assurance' of compatibility, which includes the RoHS kitemark.

'RS still receives daily requests for information on RoHS issues, and the FAQ section of our site shows higher than expected usage, revealing that the subject is still causing concern after the deadline has passed', states Mick Parker, RS' RoHS Project Manager.

He continues: 'One of the main issues we are hearing about is component availability, the situation remaining critical'.

'RS are helping to address this situation with web flags and notification emails to ensure customers are alerted whenever compliant components become available'.

'Other initiatives we have implemented include an 'ask an expert' service and in-house screening of components'.

'Even if your company has not started an RoHS compliance programme, it's not too late, and the help is here too ensure it is not too painful'.

(RS Components UK - Electronicstalk)

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83% of manufacturers’ systems risk failing RoHS compliance

A staggering 83% of manufacturers are at severe or very high risk of not being able to demonstrate compliance or due diligence for the now active European RoHS (Restriction of Hazardous Substance) regulations based on their documentation management capabilities.

That is the top finding of a survey among hundreds of manufacturers by on-demand PLM (product lifecycle management) service provider Arena Solutions. Its RoHS Readiness Survey assesses risk based on 16 key capabilities around tracking, documenting and reporting.

While its study found most respondents had implemented an RoHS transition plan, 69% did not have a centralised management system accessible to employees and suppliers – critical to ensuring any company can produce complete and accurate reports when required to do so, and to facilitating ‘design for compliance’.

Which is not good news. The EU isn’t being very flexible with RoHS: already Apple and Palm, for example, two companies respected for their manufacturing approaches, have felt its teeth – with products like the Treo 650 Smartphone being disallowed in Europe.

Current regulations require a complete compliance record – from certificates of compliance to supplier audit reports and component risk evaluation procedures – to demonstrate due diligence. They also require that the record is kept for four years after a product has been launched. A spreadsheet is not deemed adequate.

“The EU is not just looking for a list of parts and materials,” insists Eric Larkin, CTO and co-founder of Arena Solutions. “Companies need to have built compliance into their business systems, and be able to show record keeping and the process controls involved all the way from design, through procurement, materials handling, receiving and inspection.”

Arena’s research also found that 60% of companies are not confident they can track all parts and materials in their products: they don’t have complete associated compliance records and can’t verify compliance independently. Further, 73% don’t have sufficient controls and documentation around change management, compliance verification of incoming parts, and closed-loop processes for non-conforming materials.

Just as worrying, 63% of manufacturers say that their current systems to track compliance will not scale for multiple regulations, and that compliance for history revisions is not well kept.

“Converting products to become RoHS compliant by the July 1st deadline was only half the battle,” says Larkin. “Manufacturers need to be prepared to report and ‘live’ with compliance – meaning they need to have a robust compliance management solution in place that allows them to track, document and report compliance as well as demonstrate due diligence when required.”

He claims that PLM is essential to making the change, and unsurprisingly suggests that Arena’s hosted offering presents one of the lowest cost, lowest risk ways of getting what they need.

“They need something that’s quick to start up, carries a low risk of adoption and then scales up as they need it to. And they also need a solution that’s being developed as the requirements change… We have users that started in 2001, long before RoHS became a significant challenge. They are now using the latest version of Arena with 46 upgrades. 100% of our customers can take full advantage of our updated software.”

Certainly Arena’s customers fare far better than the rest. Jerry Jacobus, director of quality and manufacturing engineering at networking systems maker SilverStorm Technologies, says: “Arena PLM enables SilverStorm and our global supply chain to share – in real time – a single version of the product record, which massively simplifies our product design and manufacturing collaboration, and ensures accountability when designing for compliance. We can properly track, document, and report on RoHS compliance, and are confident we will be well prepared for the next wave of regulations.”

Says Larkin: “PLM is not the be all and end all – companies need good manufacturing and business processes too. But the core value of PLM is its ability to track compliance information and to document that due diligence has occurred. In the eyes of the regulators, if it’s not documented it didn’t happen. And if there’s a reporting problem, the relevant agency can stop a shipment.”

Author: Brian Tinham Editor-Manufacturing Computer Solutions

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Meeting RoHS/WEEE/ELV compliance for Aluminium parts

Totally inorganic, non-chrome passivate, using the same application methods and parameters as the traditional yellow chromates, meets ROHS, WEEE and ELV directives.

Eliminating chrome from the workplace is part of a massive undertaking which will benefit both the environment and worker safety, and if done correctly should not increase the overall cost of your product. Developed in 2002, Iridite NCP is a totally inorganic, non-chrome passivate (NCP) using the same application methods and parameters as the traditional yellow chromates. The bath and resulting coating does not contain any banned components found within the ROHS, WEEE and ELV directives.

The chemistry is truly reactive, unlike the polymer based 'chrome free' paint pretreatments, so it can be completely rinsed after application thus extending bath life and performance.

Like the yellow chromate the Iridite NCP exhibits bare corrosion resistance without painting and also excellent paint adhesion characteristics.

As the Iridite NCP application procedure is practically identical to the yellow hexavalent chromate, we have tested it head to head using a standard conversion coating process sequence.

* Corrosion resistance

using a standard ASTM B117 salt spray test on conversion coated panels, Iridite NCP gave in excess of 1000h on most 1000, 3000, 5000 and 6000 series alloys, giving a better overall performance than that obtained from the traditional yellow chromate.

The main cause of poor salt spray resistance in aluminium alloys is copper content, and copper levels above 2% greatly reduce salt spray life.

Chromate conversion coatings still outperform Iridite NCP when used on these alloys although even chromate has limited salt spray life on high copper alloys.

Due to their low inherent corrosion resistance high copper alloys are rarely used in applications requiring high corrosion resistance without painting or cladding, in which case Iridite NCP can still out-perform chrome based passivates.

When painted all of the Iridite NCP panels, regardless of alloy, passed >1128h salt spray with neither creep from scribe nor loss of adhesion with a cross hatch and tape pull test.

This confirms Iridite NCP is suitable for all alloys which require painting.

* Electrical resistivity

electrical chassis and enclosures are often made from chromated aluminium to allow electrical grounding whilst still providing corrosion resistance.

Iridite NCP will meet the MIL-C-81706 electrical resistivity test both before and after salt spray ensuring continued performance during service.

* Paintability

in order to accept paint properly the coating must be intrinsically hydrophilic so the surface wets out to allow the paint to flow.

This is measured by the contact angle of a water droplet on the surface.

A freshly applied Iridite NCP coating will have a contact angle of 80 compared to 110 for a new yellow chromate.

After aging the results become rather different, the Iridite NCP still remains hydrophilic measuring 390 where as the chromate becomes distinctly hydrophobic with a measurement of 650.

Other benefits - besides being a 'drop-in' replacement for chromates, Iridite NCP has other benefits, which can be utilised by the manufacturer and subcontractor: * Robustness of coating - a traditional yellow chromate coating forms as a soft gel on the metal surface, which is susceptible to damage and takes 24h to cure to a reasonably hard film.

If left in the tank the chromate will continue to build up, becoming lose, powdery and non adherent.

The Iridite NCP coating on the other hand, is self limiting, producing a hard amorphous coating as formed and does not require any curing time.

* Thermal stability

treatment of a chromated surface after it has formed is important for it to produce a corrosion resistant surface or a good paint bond.

Heating above 700 deg C will dehydrate and crack the chromate film.

Iridite NCP can be heated to 3500 deg C without any significant loss of corrosion protection or paint adhesion.

The coating does not dehydrate or crack.

This allows the use of hot water rinses and higher temperatures in dry off ovens prior to paint application, speeding up drying times and production.

Stability up to 3500 deg C offers the use of Iridite NCP for bare aluminium articles that see high operating temperatures in service, e g, automotive brake and engine components.

(MacDermid plc, 133 Great Hampton Street, Birmingham, B18 6AS)

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Chinese RoHS law differs from EU counterpart

China's RoHS law may be based on the EU RoHS Directive, but there are many differences between the now-current EU legislation and its Chinese counterpart that comes into effect on 1st March 2007.

The China RoHS law was developed as a reaction to the EU RoHS Directive, but there are significant differences between the product categories that fall within the scope of the two. Electronic radar products, electronic telecommunications products, broadcast and TV products, computer products, household electronic products, electronic measuring instruments, special electronic apparatus, electronic components, electronic applications equipment, electronic raw materials etc and packaging materials all fall within the scope of the China RoHS, but toys are not covered. Unlike the EU RoHS Directive, which lists categories of exempted products, the China RoHS law lists those products that are covered.

The covered products have been specified by the Chinese Ministry of Information Industry (MII).

However, the MII has no plans to translate the initial list of electronic information (EI) products into English, nor to establish any formal administrative process for clarifying questions regarding covered products.

Raw materials and components are covered by China Administration Measures, whereas only finished electrical and electronic equipment is covered in EU RoHS.

Furthermore the China RoHS law requires marking standards for all products that are identified in the catalogue.

The marks must be on the products from 1st March 2007.

There are three marks required:

a label defines whether or not the product contains any of the six hazardous substances, but is only required if they are present;

a table in the product documentation must identify which hazardous substances are contained, and in which component(s) they are present;

and packaging materials must be disclosed on the outside package.

A further difference exists in the concept of 'put on the market'; in China from 1st March 2007 all products within the supply chain - from the docks to retail shelves - must be compliant.

Manufacturers and retailers worldwide who have to certify their products against the EU RoHS Directive and/or China's new RoHS law can obtain global support from the SGS Group - a leading provider of RoHS analysis and RoHS certification serices.

The SGS Electrical and Electronics Division has 24 laboratories worldwide and 1000 specialists in this field.

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