ul rohs 2007 vincent sylvester na, regional business manager rohs solutions (603) 370-7162...
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UL RoHS 2007
Vincent SylvesterNA, Regional Business ManagerRoHS Solutions(603) [email protected]
Partners Working For A Green Planet!
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Restricted Substances Regulations Stretch Across the Globe
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RoHS Directive Restricted Substances and Limits
Restricted Substances RoHS Limits*
Lead 1000 ppm
Hex. Chromium 1000 ppm
Mercury 1000 ppm
Cadmium 100 ppm
PBB 1000 ppm
PBDE 1000 ppm
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Mechanically Disjointed Material
• Mechanically Disjointed– Refers to materials that, in principle, can be separated by mechanical actions such as
unscrewing, cutting, crushing, grinding and abrasive processes
• Semiconductor package containing six different homogeneous materials
• Insulated wires comprised of metal wire inside plastic insulating material
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“Green” Products –Restriction of 29 Total Substances
Annex A (includes RoHS material which are not shown below)
• Asbestos• Certain azocolourants and azodyes• Ozone depleting • PCBs• Polychlorinated naphthalenes (>3 Cl)
• Radioactive substances• Certain shortchain
polychlorinated paraffins• Tributyl/triphenyl tin• Tributyl tin oxide
Annex B
• Antimony/Antimony Compounds• Arsenic/Arsenic Compounds• Beryllium/Beryllium Compounds• Bismuth/Bismuth Compounds• Certain Phthalates
• Brominated Flame Retardants(other than PBBs or PBDEs)
• Nickel/Nickel Compounds• Selenium/Selenium Compounds• Polyvinyl Chloride (PVC)
Found in Annex A and B of Joint Industry Guide “JIG” (also called IPC 1065) developed by the EIA, JGPSSI and EICTA
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Three Steps to RoHS Compliance
• Understand It
• Implement It
• Prove It
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RoHS Enforcement
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Keys of “RoHS Enforcement Guidance Document”
• Testing
• Enforcement Process
• Compliance Assurance System (CAS)
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XRF Testing
• EU will carry out X-Ray Fluorescence (XRF) analysis of products to detect infringements
• XRF is a Screening Tool Capable of Detecting:– Pb, Cd, Hg– Cr (VI), Hexavalent Chrome
• (for Cr total presence)
– PBB’s and PBDE’s (Br compounds)• (for Br total presence only)
• Note: Products must be submitted to China laboratories for testing
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Enforcement Process
• Market surveillance activities– Market intelligence– Random selection– Products known to contain materials of high concern– High volume products– Short life products– Consumer products unlikely to be recycled– Notification of concern from external parties– Notification of concern from other Member States
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Requirements for a Compliance Assurance System (CAS)
• Testing
• Component Documentation
• Procedure Documentation
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Testing Requirements
• Demonstrate that your finished products pass XRF screening
• Demonstrate that your suppliers’ components pass XRF screening
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Component Documentation Requirements
• Provide all converted Bill of Materials for RoHS compliance
• Provide Build to Print documentation for RoHS compliance for the following high risk parts and assemblies
• Printed circuit boards• Cable assemblies• Metals• Metal Finishes• Plastics• Hardware
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Levels of Preferred Component Documentation
• Provide material declarations at homogeneous levels for all components
• Where material declarations are not available, provide test verification that no restricted substances are present at the homogeneous level
• Where material declarations or test results are not available, provide certificates of conformance or producers’ warranties for evidence of compliance
Preferred
Least Preferred
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Procedure Documentation Requirements
• Demonstrate that Management has provided RoHS compliance objectives, and resources to ensure progress toward RoHS compliant products and production
• Provide evidence that RoHS compliance assurance is included in Management Review.
• Provide training records for all employees for RoHS compliance
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Procedure Documentation
• Demonstrate the design process contains RoHS compliance
• Demonstrate your internal data and records system reflects RoHS compliance data
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Procedure Documentation
• Supply Chain Management– Provide evidence that you have communicated RoHS
requirements to your Suppliers
– Demonstrate new part numbering system to distinguish between RoHS compliant and non-compliant
– Demonstrate verification of incoming material procedures have been revised to address RoHS compliance
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Procedure Documentation
• Demonstrate material and equipment segregation to prevent contamination by a restricted substance
• Demonstrate revised internal procedures and work instructions for RoHS compliance for the following areas:
• Stockroom Segregation• Material Handling• Production Processes• Non-conforming Product• Corrective Action and Continual Improvement
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Procedure Documentation
• Provide internal audit data for RoHS compliance.• Provide supplier audits and assessments for RoHS
compliance• Demonstrate that a supplier corrective action process is in
place to address RoHS non-conformances.• Demonstrate traceability and containment procedures in
the event of contamination.
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RoHS Compliance Assurance System (CAS) Solution
Step 1: Gap Analysis / Planning (2-day onsite program) • Lead Assessor Training • Gap Analysis• Management Overview
Step 2: Implementation / Final Assessment (9-weeks) • Works with specific groups within the organization to address the
specific RoHS requirements that impact them. • Modules include:
Step 1:Gap Analysis/
Planning
Step 2:Implementation/
Assessment
RoHS Compliance Assurance System (CAS) Solution – 10 weeks
2-days 9-weeks
1. Quality Management
2. Management Responsibility and Resources
3. Design and Development
4. Purchasing
5. Production Process
6. Measurement and Analysis
7. Internal Training
8. Final Process Assessment
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Restricted Substance Bill of Material (BOM) Conversion
• For each submitted BoM and build-to-print drawing, UL will analyze and provide information on the following:– RoHS and Green compliance information for each
component or material– Compliant replacements, if necessary and/or available– MSL rating– Peak reflow temperatures– Lead finish– Part identification markings– All supporting vendor documentation– XRF testing for components and materials where there is no
data to confirm compliance
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Thank You!
• Questions and Answers