Third Party Certification, How It Works
Third party certification helped bring standardization and market growth to the organic food industry. I believe the electronics industry can use this model in the same way to standardize RoHS compliance activities. One result will be testing at the appropriate level. That level is the homogeneous material, as close to its raw form as possible. Here's how it would work.
When a food processor wants to label a processed food product as 100% organic, they must complete two tasks. The first is to become certified as an organic food processor. The second is to demonstrate organic certification for all the ingredients and processing aids used in their product, all the way back to the farm.
A processor certification means the food processor uses organic food handling and process methods. Organic and conventional ingredients must be kept separate at all times. This is exactly analogous to keeping Pb out of RoHS compliant products. Machines that handle Pb-bearing parts must not be used on Pb-free parts to prevent cross-contamination. For both industries, the choice is 100% conversion or maintain two separate sets of processes and machines.
For product certification, an organic processor must obtain organic certificates, for each ingredient, from each supplier and processor. This requirement expands as each processed ingredient is broken down into its ingredients. Ultimately, the processor will have in hand certificates from each farmer who grew the raw ingredient, and from each business that handled or processed that item as it worked up the chain.
One of the great advantages of this system is that the certification steps for farmers are different from those for processors and handlers. While processors and handlers must obtain their process certification, they do not have to test the ingredients for organic integrity at each step. The original certificate from the farmer serves that purpose. The only testing is done on the farm. Soil and water tests supplement the process requirements to prove organic integrity at the bottom of the chain. As long as each business in the chain adds their own certificate to the pile, the ingredient retains its organic status all the way up.
The electronics industry has exactly the same needs. It is costly and wasteful to test complex components and assemblies for RoHS compliance. Despite a few efforts to develop testing standards, difficult problems remain. Grinding up even apparently simple components like chip capacitors can produce misleading results. Testing plastics for flame-retardants is quite difficult. X-Ray fluorescence is a great screening technique, but has limitations that prohibit its use as a definitive, quantitative method of material content discovery.
Testing a homogeneous material when it is the only material in the test sample is the only sensible approach. Consider a lowly, SOT transistor. The body, lead-frame, lead finish, die attach, die and bond wires can all, arguably, be considered homogeneous materials. In the model I propose, the supplier of each material does chemically appropriate batch testing and certifies the results for each shipment of material. The plastic resin maker tests the inputs and finished resin, in addition to maintaining process control that keeps banned flame retardants out. A copy of test results and compliance certificates go along with each shipment. The lead-frame maker also tests and certifies that the copper lead-frame does not contain more than the allowed amount of Pb. The plating processor demonstrates compliance in the same way as the others. The assembler collects all the raw materials certificates and attaches their own certificate that proves the part was assembled and molded using approved, compliant processes.
Finally, the OEM receives the transistors along with a stack of certificates. The paper trail is complete and the OEM can state with complete confidence that a product made from certified parts is fully RoHS compliant. No testing of the purchased components is needed. The certifications are sufficient. If the newly released declaration standard, IPC-175X is applied, the paper trail is actually just a collection of electronic documents.
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This can happen. But it will first take recognition that a systematic approach, using third party certifiers, is ultimately less expensive than what we have now. With recognition comes the opportunity to build consensus on what constitutes compliance. The stakeholders will be industry and regulators. This is how it was done with the US National Organic Program. It can be done again for RoHS, China RoHS, and each new set of regulations to come along.
The most important point is that a defined process always produces better results than an ad hoc process. Anyone who has spent time in manufacturing will understand this.
Additional Resources
IPC has announced a Pb-free certification program. A great start.
IPC 175X Enables Uniform RoHS Declarations
Part One: Reduce Testing With Third Party Certification
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