Managing the Compliance Verdict in Parts with Proprietary Substances

[jcholin]

We are finding that a large portion of the parts that have "full material disclosure" in our database, contain one or more substances that are proprietary, generic or pseudo-substances.  This brings up two fundamental issues:

·        When a new REACh list is published there is nothing to drive us to seek an up to date REACh declaration or updated IPC1752A.

·        There is no interaction between the RoHS and REACh declarations attached to the manufacturer’s part number.

When we receive an IPC1752A that lists a proprietary or pseudo-substance (with a “-“ or “SYSTEM” for the CAS#), there appears to be a tacit assumption in WPA that as of the date of the form there are no REACh SVHC’s in these substances.  If the WPA user is also securing REACh and RoHS declarations at that time, importing the forms into WPA does cover a passing compliance verdict until the REACh candidate list is updated.  Once it is, however, WPA does not flag the part as needing a new REACh declaration even though one of the proprietary or pseudo-substances may contain an SVHC.  PTC has recognized this with Pre-Qualified parts, but not with parts that contain a proprietary or pseudo-substance. 

Further, the only way to update the part is to upload an IPC1752A with all of the content data and the new REACh information.  This is frequently cumbersome for those parts where the vendor supplies info in another format and we have to convert it.  If there were some functional linkage between the RoHS and REACh declarations and the compliance verdict it would reduce the maintenance labor.

[pcarnet]

Hello Jeffrey,
I fully agree with your observation, the "proprietary" or "not to declare" substances are not visible enough, and we can easily forget that the related FMDs have to be updated periodicaly.

However, I'm not sure I understand your suggestion ... could you be more specific ?

Do you suggest to complete the "partial" FMDs with RoHS and REACh declarations ? For example, if a SVHC is not listed in the Class D (FMD), be able to declare it through an additional Class C upload, WPA mixing information from both the Class D and the Class C declarations ?
Pierre.

[jcholin]

Pierre,

Thank you for taking the time to view my suggestion.

My product suggestion really has two parts, first there is a compliance hole where a user could have content data on parts that includes a pseudo-substance and think that they are compliant when they are not.  The second part is one way to deal with this using the documents that are attached.

The potential hole revolves around the pseudo-substances.  Here is an example that I thought of today:  We received an IPC1752A class D in December 2013 that includes in the contents "FLAME RETARDANT, NOT TO DECLARE" with System as the CAS#, for our part number 9000.  This will load with the present OTB CAS library.  Further let’s assume that we got a REACh declaration from the vendor in conjunction with that form that stated that the part was unaffected.  Now go to June 2014 and new SVHC's are added to the Candidate list, one of which happens to be the flame retardant that our vendor has used.  When we load the patch that includes the new substances and check our data base for parts that are affected by the recent additions part number 9000 will not come up because the pseudo-substance is not tied to a group of substances or CAS# that WPA will pick up on.  So a user can have parts that have a green check mark but are non-compliant.  I think that PTC should consider adjusting the code so that when a part has more than 0.1% by mass of pseudo-substances or Proprietary materials the compliance verdict should either require a REACh declaration with a sunset date in the future be attached to the MPN, or provide the user with the ability to extend the sunset of the existing form through a GUI like a simplified pre-qualifying of the part.

The second half of the suggestion has to do with one of two ways of dealing with this.  The first option is to have a built in path like I just described, and the second is a more generic solution as I described in another product suggestion earlier this year.  In some cases it is easier to get an email from a vendor confirming that the part is still REACh unaffected, and in other cases we can get a revised IPC form.  It would be nice for PTC to consider allowing either path so as a user we can quickly and easily resolve the problem.  The overwhelming majority of our parts have more than 0.1% of the mass undefined.  In some cases it is the vendor protecting their intellectual property, in some cases it is that there is no CAS# for the substance in the part, and in some cases it is just laziness.  WPA needs to be flexible in dealing with this so we can efficiently resolve problems.  Imagine having to update 10,000 parts because new SVHC’s are added to REACh, doing so with IPC forms is not practical.