Currently many of the resistors we have in our WPA database are failing REACH (compliance status on manufacturer part information page) because the manufacturer lists Lead Monoxide and Diboron Trioxide, two frits that go into the glass passivation, in the substance data they have submitted. While we have pressured them to change their data by replacing the reactants with the products, they are reluctant as there is no CAS# that correctly fits their case. So the parts comply with REACH in that there is no Lead Monoxide in the part, just leaded glass, but the data we have on file indicates a failure to comply. We have other parts that have similar issues, for instance plastics that use Phthalates as a polymerization agent that is consumed in the reaction, or places where the vendor lists solvents that are volatilized once the material is applied.
We do not want to edit our supplier's data because we view it as a legal document, and many of our suppliers do not want to alter the substance data they get from their suppliers because of the legal liabilities involved. But we do want to be able to run BOM’s and demonstrate compliance. So there are instances where we need to adjust the compliance calculation result. Our enhancement suggestion is for PTC to design in the ability (restricted to appropriate roles) to edit specific compliance status results and document the logic in a text note or document that is attached to the part. In essence change the compliance status "Fail" to "Pass with Exemptions", or something similar, for a part or group of parts. The edit would have to be specific to individual substance/part(s)/regulation combinations so that if a part(s) failed Reach for one SVHC and was edited to pass, it would not interfere with generating a “fail” result when another SVHC came along that was in the same part and reported to the same regulation or specification.
Hello Jeffrey, all,
Would like to understand from the WPA user community on the above topic, what would be a work around or a permanent solution the as this is applicable for all the WPA users.
Most of the passive component manufacturers do report related to Diboron trioxide and lead monoxide and claim the final product do not contain this substance . However REACH verdict appears as FAIL according to the chemical validation wheras all the manufacturers do have a justification document which is well accepted by the industry. Feedback from IPC also on this topic is that the software system used should be tweaked to cater to the requirement.
There are a few places where vendors basically give bad data (report pre-cursor substances instead of the reaction product that actually exists in the part). PTC's policy is that the WPA user should force their vendor to correct their IPC1752 and resubmit. Several times I have mentioned in the CAB meetings that this is not practical as we do not always have enough leverage with our vendors to force them to invest the labor to correct their forms. In the past I have recommended an alternate path where select users (restricted to qualified engineers) can modify the verdict and document their reasons, a bit like a deviation. To date I am not aware of such a solution in WPA, several of our suppliers have resorted to declaring the passivation glass "Proprietary" since there are no regulatory implications to this.
Thanks for your feedback. I would like to hear from users from other organisations as well on this topic on any current work around being used.Our attempts with the supplier base to remove the substance not present in final product was not successful and they want to stick to it.
We have a similar use case that should be supported, in cases where there are documented and approved reasons to modify the compliance verdict calculated from supplier data. This would be a more general use case, not restricted to the substances in glass mentioned in the original enhancement. It could be called an authorized over-ride or expert assessment.