RoHS war stories
components
1. During one audit we had suspicions
on a lock mechanism—in fact it is the
mechanism from the above example
where the CoC mentioned the seven
RoHS substances, so we obtained a
physical part to visually check. Low
and behold, the tongue of the lock ap-
peared to be chromated. We checked it
with a spot test of diphenylcarbizide so-
lution that we had handy and it proved
to be hexavalent chromate. We phoned
the supplier from the audit “Hot
Room” and the supplier said “Yes, we
know it’s not compliant, you’ve caught
us now haven’t you.” Needless to say
they are now an ex-supplier.
2. We had found Pb contaminated PCBs
delivered by our sub-contractors.
They questioned our XRF results &
commissioned their own, but their lab
didn’t use the correct equipment (XRF
“Michael, please pass the failing area. I have collimator, which is far too big). We
decided to claim the lead in copper alloy
finally exposed the non-compliance by
identifying enough affected boards &
exemption for the PVC sheathing that failed.”
scraping off a sufficient amount of sol-
der for AAS testing which confirmed
—anonymous lab customer
the XRF results. A subsequent audit
found operators using spatulas from
Sn/Pb solder pots in Pb-free solder
number. However, moving to the by a test report that clearly indicated
pots and uncleaned squeegees swapped
second page one sees that the part of that the part had been ground into a
between Sn/Pb & Pb-free jobs.
that designation is actually not RoHS single powder, destroying any chance at
3. A stacked die component was tested
compliant and contains lead in a non- obtaining homogeneous data.
for RoHS compliance. Everything was
exempted form. Another component 7. “This part is RoHS 5 of 6 compliant”—
fine when the overmold and BGA
with additional letters added to the The declaration was a metal fastener
balls were tested. However, once the
part number is the actual lead-free that contained hexavalent chromium
top IC of the stacked part was tested,
version! If one ordered as per the first plating. “5 of 6 compliance” relates to
the balls were found to be eutectic tin/
page thinking one was getting a compli- lead solder allowed for network infra-
lead. The supplier’s representative was
ant part, they would be in for a shock structure devices.
very surprised. These parts were from
when it arrived—assuming the labeling 8. A material testing report was received
a very large company, a company from
was correct and/or incoming testing from a well-known lab proving the
which one would not expect this sort
was carried out. compliance of a connector. However
of mistake to occur, let alone escape.
1. “This part is lead-free, there is no lead the description of a material contained
And then it happened again.
in the part, all the lead is in the balls in the report was “Red liquid.”
4. Virgin chip components from a very
under the part.”—CoC shipped with 9. A client of ours sent a small box made
large supplier of these components
a BGA of seven separate pieces of steel to a
were tested using an XRF. Lead was
2. “This part is RoHS compliant. We well-known test lab. The metal pieces
found. Cross-sectioning and subse-
have done no testing to prove this and for the box were sourced from overseas
quent SEM/EDX testing showed that
do not intend to.” and not all from the same place. Seven
the lead was present in the plating
3. “This part does not contain any of the reports were duly returned from the
SnPb 63/37. The supplier was con-
7 [SIC] RoHS substances.” lab, three pieces being compliant and
tacted. They insisted that the compo-
4. “The hexavalent chromium plating on four non-compliant. However the
nents were compliant. Eventually it was
the below parts is RoHS compliant.”— description on each report was “Shiny
determined that the manager of the
CoC shipped with a plated steel Metal part.” There was no way of
plant that manufactured the compo-
bracket knowing or tracking which parts of the
nents had read the RoHS directive in
5. “The parts listed are lead free, except box were compliant and which were
English, not his native language and
for the plating on the lead frame”— not.—We now ensure that all our test
misinterpreted it. His understand-
CoC shipped with an IC package requests to Labs contain .jpgs of the
ing was that because his component
6. “All RoHS substances are below the part to be tested and ensure the report
contained lead in an exempt form (a
allowable thresholds on a homoge- from the lab also contains the .jpg.
lead containing ceramic) the whole
neous level.”—This was accompanied
component was therefore exempt and
he had his plant go ahead and use
12 – Global SMT & Packaging – June 2009
www.globalsmt.net
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