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					Green Process
The Role of Laboratory and
Analytical Testing for RoHS
Introduction



    Larry Somrack, President
   NSL Analytical Services, Inc.
    Introduction
   Why do you need Lab Testing?
   3 Different Ways to Prove Compliance
   Lab Choices
   Selection Criteria
   Techniques
   Laboratory Responsibilities
   Homogeneity Issues
   Exemptions
   FAQ‘s
Why do you need Laboratory
Testing for RoHS?
   Third Party Verification of Compliance
     Unbiased information
     Trustworthy information



   Proof of Compliance
Why do you need Laboratory Testing
            for RoHS?
          Process Controls
                 In-house laboratory


          ―Spot Checks‖ of Supplies

          Strategic Testing Plan
 3 Different Ways to Prove Compliance

1.   Vendor Certification
         Materials Declaration Form
2.   On-Site Testing
         Screening Instrument ie Handheld XRF
             High concentration items
3.   Comprehensive Testing
         In-house Laboratory
         3rd Party Laboratory Analysis
             Accurate Quantification of Results
Why do you need to test?



    Proof of Compliance
Proof of Compliance
from 3rd Party Laboratory
Lab Choices

   Captive Laboratory
   Electronic Testing Laboratories
   Product Testing Laboratories
   Environmental Laboratories
   Materials Testing Laboratories

RoHS Testing = Materials Testing
         Selection Criteria
   Extensive Expertise in Materials Composition
   Standardized Quality Systems
       Good Laboratory Practice (GLP)
       ISO/IEC 17025 required for QC 080000 IECQ – ISO 9000
            Use Standard Reference Materials
   Turnaround Times to Meet Your Needs
   Thorough Knowledge of RoHS Requirements
       Involvement with governing bodies that determine RoHS
        methods and procedures
   Using Best Available Methods for Materials Testing
         Handheld X-Ray For Screening
   XRF has important role in RoHS testing
       Screening tool to identify high concentrations of
        restricted substances
            PVC – Cd and Pb
            Polystyrene ABS – PBDE
            Plastics (red, orange, yellow) Cd, Cr6, Pb
            Plating Cr6
            Others
       Quick indication of substance‘s presence
   Alternative test methods required for accurate
    determinations
    Methods Used for Accurate RoHS Analysis
   X-Ray Fluorescence (XRF)
   Inductively Coupled Plasma /Atomic
    Emission Spectroscopy (ICP/AES)
   Inductively Coupled Plasma/ Mass
    Spectroscopy (ICP/MS)
   Atomic Absorption (AA)
   Cold Vapor Atomic Absorption (CVAA)
   Gas Chromatography Mass Spectroscopy
    (GCMS)
   FTIR
Verification Test Procedures
                                            Test Methods
                                                           Homogeneous
   Test       Substance                                      Electronic
Techniques        s       Polymers          Metals          Components
Mechanical       All        Direct         Direct            Grinding
Preparation                Measure        Measure
                           Grinding       Machining
 Chemical        All      Solvent Ex.        Acid         Acid Digestion
Preparation                  Acid          Digestion     Solvent Extraction
                           Digestion
 Analytical   PBB/PBDE      GC/MS             —               GC/MS
 Methods                     LC                                LC
                Cr(VI)    Colorimietry    Colorimietry      Colorimietry
                 Hg           ICP/AES, ICP/MS, Cold Vapor AAS, AAS
                Pb/Cd                 XRF, ICP/AES, ICP/MS, AAS
        Laboratory‘s Responsibilities
   Evaluation of Materials for RoHS Testing
     Identify Homogeneous Materials
     Assess Effective Material Preparation for
      Analysis
Laboratory‘s Responsibilities

    Recommend Testing Based on
     Material Composition
        Sample Size, Methodologies, Etc.
    Selection of the most accurate and
     appropriate Methodologies and
     Procedures
             Such as the American Society for Testing and
              Materials (ASTM) standard methods.
Laboratory‘s Quality System
   Comprehensive Quality Systems
       Documentation Controls
       Review of Data by Experienced Technical Staff
       Reference Standards Recoveries
       Instrument Calibration using NIST traceable
        standards
       Spike Recoveries
       Blanks

    The key is to make sure the laboratory is providing
        Legally Defensible Data
        Accurate Procedures
   Methods are under Development
       Materials Testing vs Environmental Methods
            Example of poor science and methods listed for inorganic
             materials: Steel, Ceramic and Copper
            PBB and PBDE
                 Lab listed Methods 8081A, 8270C, 3540C and 3550B
                 8081A Organochlorine Pesticides by GC
                     ―Pesticides in extracts from solid and liquid matrices‖
                 8270C Semi-volatile Organic Compounds by GC/MS
                     ―solid waste matrices, soils, air sampling media, water
                 3540C Soxlet Extraction
                     ‗solids such as soils and wastes‖
                 3550 B - Ultrasonic Extraction
                     ‗solids such as soils, sludges and wastes‖
    Accurate Procedures

   International Electrotechnical Commission (IEC)
   To ensure compliance, test lab should use
    approved or standardized procedures and
    certified reference materials.
   Lab should provide full compliance statement
    with test results and QC data
        Keep Those Results in a Safe Place and Keep
         them Readily Available
        ON Line or Electronically
   Send test samples with known materials as a
    Quality Check on the Lab.
Testing Challenges

   Homogeneity– The major issue impacting Due
    Diligence

   Grinding is not the Solution!!!

   Key Requirement of RoHS Directive
       Each Assembly Component MUST Be Tested
        Separately
   Definition: ―Homogeneous material means a
    material that can not be mechanically disjointed
    into different materials.‖*
                *DTI   RoHS Regulations, Govt Guidance Draft August 2005
    Example of Non-Homogenous Material
                                        Silicon Chip            Gold Wire



        Copper Lead Frame




       Chrome Plating                                                          Tin/Lead Solder
                                                       Silver Epoxy or High Lead
                            Plastic Encapsulation      Solder Adhesive




   Populated
    Circuit Board
Testing Challenges

   Definition: ―Homogeneous
    material means a material
    that can not be mechanically
    disjointed into different
    materials.‖*
            *RoHS Enforcement Guidance Document Version 1 – issued May 2006
Example of Homogenous Material

   Bare Board




   Part
Issues with Testing
Non-Homogeneous Materials
   Dilution Factors
     False Compliance
     Lack of Identification of Specific Non-
      Compliant Component


   Example
       Tin Lead Solder at 37% lead (Fail)
            Total lead in a 1lb board 0.081% (Pass)
                 [(0.37 x 1g)/454g] x 100 = 0.081%
        Issues with Testing
        Non-Homogeneous Materials
   Contamination with Exempt Materials
       False Non-Compliance
           Solder and plastic have low melting points
    Exemptions
   Understanding exemptions and proper
    identification is critical in determining true
    compliance.
   Exemptions:
       Up to 4% Pb in Copper Alloys
       Lead in Glass and Ceramics
       Deca-Polybrominated Biphenylethers (Deca-
        BDE)
       Medical & Military Applications
       Etc., etc., etc. . .
   By the Laboratory Knowing Exemptions
    You Can Save Time and $$$.
Exemption Example




   What does that mean to you?
Strategic Testing Plan

   Good and Bad Science
     Methods
     Instruments

     Materials



   Screening
       Reduce costs
           Recommendations

   Get your Testing Done as Soon as Possible
   Choosing the Right Laboratory will Help You
    Succeed With Your Due Diligence Strategy
       Look For:
          Accurate Procedures
          Good Quality Systems
          Defensible Data Available
          RoHS Testing Experience
          Cost Effective Methods
          Ask for Any Available References



         Save your Company Time and Money!
Frequently Asked Questions

   Cost
   Turnaround Time
   Sample Size
   How much testing do you need?
The Role of Laboratory and
Analytical Testing for RoHS




      QUESTIONS?

				
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