Conformity Magazine - December 2007 - (Page 23) numbers, or just those which are part of the RoHS product line?) Procedures must be created to assure that received material is not incorrectly apportioned, and to ensure that the received parts and material inventory stayed “clean” during the transition. Ultimately, the sets of internal regulations and procedures which comprise our own company’s RoHS compliance program encompass a multi-faceted protocol that exceeds industry standards. For example, one of the major changes to our production process has been the incorporation of a leadfree soldering protocol. The implementation of a new solder technique can be a difficult and time consuming process, as many different solder alloy formulations and PCB materials needed to be evaluated. This effort will require months of material research combined with an interactive process profile evaluation. The resulting lead-free soldering process requires a higher soldering temperature, and printed circuit boards need be reconfigured to assure resistance to the stresses generated by exposure to the environment. Also, the possibility of tin whisker growth must also be accounted for in the design of printed circuit board trace spaings. Manufacturers should expect an investment of considerable capital and time when implementing a new lead-free soldering process, and it would be prudent to do this early in the conformity cycle to assure that it will be in-house and under control when it becomes time to switch over. Meeting Due Diligence Hurdles In actuality, the RoHS Directive requires only due diligence on the part of equipment manufacturers, and does not specify the minimum actions that are required to provide a reasonable defense against charges of non-compliance. The major question which could cause stress should the company be subject to legal proceedings over RoHS compliance is exactly what is meant by “due diligence,” and how a manufacturer can prove that they meet this standard. Simply doing nothing, or asserting lack of awareness of the requirements or lack of intent to contravene such requirements, is not a sufficient defense. Instead, manufacturers must ensure that the compliance system that they have established works, and that they posses sufficient documentation to prove that it does. It is clear that the courts will insist that positive action be taken, and that all reasonable steps are also taken to assure compliance. Such steps might include periodic audits of the compliance checks, and a genuine commitment on the part of the company’s executives and managers that the system is followed. It may also be necessary to set up incoming inspection protocols than include hand inspection and 100% x-ray (XRF) scanning of all RoHS required material or chemical analysis. This scanning process will help discover 901 Sheldon Dr., RTP (Cary), NC 27502 USA December 2007 conformity 23 http://www.ProductSafeT.com http://www.ProductSafeT.com
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