Agency Certification, RoHS--Question for the Pros

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nickt
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Re: Agency Certification, RoHS--Question for the Pros

Post by nickt »

jjman wrote:I’m a skeptic and a cynic. (Thus the fart comment alluding to the fear about the affect of cow farts on the world.) However, I think the y2k thing is a true success story. The fact that almost nothing bad happened showed that the world recognized and took the problem seriously. The goal was to avoid chaos involving a simple math dilemma, and it worked. Go geeks!
Not to rain on your parade but we're still paying the price of Y2K. The utter crapulance of the people bulk hired and overpaid to track down a non-existent problem came back to bite with the current outsourcing mania - the justification is basically "if IT is always crap well it better be cheap crap!"

The soviets and chinese (who did nothing) had nothing bad happen. Y2K ugh don't get me started...

Idiot: "how many DATE fields do you have in your DATA DIVISION?"
Me: "it's C++ and we already have data out to 2045!"
Idiot: "hmmm... that's not on the checklist... could you add a DATA DIVISION?"

YMMV.
muchxs
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Re: Agency Certification, RoHS--Question for the Pros

Post by muchxs »

nickt wrote:Not to rain on your parade but we're still paying the price of Y2K. The utter crapulance of the people bulk hired and overpaid to track down a non-existent problem came back to bite with the current outsourcing mania - the justification is basically "if IT is always crap well it better be cheap crap!"

The soviets and chinese (who did nothing) had nothing bad happen. Y2K ugh don't get me started...
Civilization had lived without computers for what, 10,000 years or more? Then suddenly every ass crack teenager "needs" to spend four hours a day in chat rooms and "needs" to have a cel phone to stay in touch with their friends. It doesn't seem to make them any more intelligent, does it?!

As the volume of information increases it becomes increasingly difficult to differentiate useful information from noise. Hint: Most of it is noise.

While the Chinese and the Russians may have their weaknesses confusion over the difference between "reality" and "virtual reality" isn't one of them.
paulster
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Re: Agency Certification, RoHS--Question for the Pros

Post by paulster »

nickt wrote:Not to rain on your parade but we're still paying the price of Y2K. The utter crapulance of the people bulk hired and overpaid to track down a non-existent problem came back to bite with the current outsourcing mania - the justification is basically "if IT is always crap well it better be cheap crap!"

The soviets and chinese (who did nothing) had nothing bad happen. Y2K ugh don't get me started...
Nick

This is going well off topic, but the Y2K problem was never necessarily going to happen at Y2K anyway; it's most likely to happen at arbitrary times for different systems over the next 80 years!

Systems using 2-digit years mostly, in my experience, catered for year 2000 as a likely happening by picking a point in time and saying that numbers greater than that represented 1900+something and numbers below that would be 2000+something. For systems developed in the 80s and 90s that didn't have to store historic data this threshold point could well be the number 80 or 90, but could have been something like 50 depending on the mood and the foresightedness of the programmer on any given day.

So there are loads of systems which passed Y2K testing (and in my opinion shouldn't have passed without a a caveat detailing their effective useful lifespan) that will still fail at some point in time, and quite a few people are aware of that. They also know that they had to get the Y2K tick in the box because of the media maelstrom and then would worry about the other problem later, hoping that the systems had been replaced before that point. It's fairly likely that will be the case anyway as I can't imagine many programmers who'd have thought we'd need to store information dating back to 1910, but would only want to go forward as far as 2009, but you never know...! Mortgage systems in particular tend to cater for loans of 25-35 years and run on mainframe platforms so they have a decent lifespan and could present some problems.

But, you're right. It didn't do the industry a whole lot of favours.

Now back to our regularly scheduled topic...
klingo
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Re: Agency Certification, RoHS--Question for the Pros

Post by klingo »

get your 60/40 now!
we will see NOS solder for big bucks soon! :lol:
d2camero
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Re: Agency Certification, RoHS--Question for the Pros

Post by d2camero »

So back to reality - does anyone **know** what the requirements for RoHS are for the US? Does anyone **know** of the exemption process?
d2camero
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Re: Agency Certification, RoHS--Question for the Pros

Post by d2camero »

OK a little googling:

What is covered by RoHS? Not just lead.

The substances banned under RoHS are lead (Pb), mercury (Hg), cadmium (Cd), hexavalent chromium (CrVI), polybrominated biphenyls (PBB) and polybrominated diphenyl ethers (PBDE).

What is subject to ROHS?

The following product categories are impacted under the RoHS Directive:
1. Large household appliances: refrigerators, washers, stoves, air conditioners
2. Small household appliances: vacuum cleaners, hair dryers, coffee makers, irons
3. Computing & communications equipment: computers, printers, copiers, phones
4. Consumer electronics: TVs, DVD players, stereos, video cameras
5. Lighting: lamps, lighting fixtures, light bulbs
6. Power tools: drills, saws, nail guns, sprayers, lathes, trimmers, blowers
7. Toys and sports equipment: videogames, electric trains, treadmills
8. Automatic dispensers: vending machines, ATM machines

The following products are currently exempted from RoHS compliance:
1. Large stationary industrial tools
2. Control and monitoring equipment
3. National security use and military equipment
4. Medical devices
5. Some light bulbs and some batteries
6. Spare parts for electronic equipment in the market before July 1, 2006.


How Does RoHS apply to the US? From wikipedia:

California has passed SB 20: Electronic Waste Recycling Act of 2003, or EWRA. This law prohibits the sale of electronic devices after January 1, 2007, that are prohibited from being sold under the EU RoHS directive, but across a much narrower scope that includes LCDs, CRTs, and the like and only covers the four heavy metals restricted by RoHS. EWRA also has a restricted material disclosure requirement.

Other US states and cities are debating whether to adopt similar laws, and there are several states that have mercury and PBDE bans already. Federal RoHS-like regulation in the US is unlikely in the near to medium term.


WHat does this all mean?

Build you amps with whatever you want. If you want to sell them in the EU, then build with RoHS compliance and get them certified.
dre95060
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Re: Agency Certification, RoHS--Question for the Pros

Post by dre95060 »

Here is a copy of the RoHS directive:

http://europa.eu/eur-lex/pri/en/oj/dat/ ... 190023.pdf

It specifically exempts lead in glass of CRTs or other electronic components. Barium and strontium are not on the list, so it looks like vacuum tubes would be compliant as long as they use hi-temp solder (>85% Pb) in their construction. Ironically, tube manufacturers might have to increase the lead content of their products in order to comply!

Another EU regulation to be aware of is WEEE (Waste Electrical and Electronic Equipment directive). Unlike RoHS, there is no uniform way of complying with WEEE. Dealers have to have a country-specific plan for recycling equipment they sell in the EU.

I sympathize with the guy who said we would have to pry his soldering iron from his "cold, dead hands". I can see it now--pistol in one hand, soldering iron in the other. You gotta love it...

Dave E.
muchxs
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Re: Agency Certification, RoHS--Question for the Pros

Post by muchxs »

So pick a loophole. Here are my favorites:

Large stationary industrial tools

Build it BIG! Call your stack a "large stationary industrial tool". Use 15" speakers and bolt the sonofabitch to the floor! I can see it now, to play a European club date you'll need the standard mounting plate to bolt your amp to the floor and qualify as a "stationary industrial tool". How big does it have to be to qualify as "large"? Your P.A. system probably qualifies. Remember, RoHS is meant to promote recycling and recycle-ability of consumer electronics primarily computers and computer CRTs.


National security use and military equipment

Olive drab tolex and expanded steel speaker grilles maybe?! :lol:


Spare parts for electronic equipment in the market before July 1, 2006.

O.k., that's a good one. I think we have a winner here. This is similar to the pre-ban / post ban game the assault rifle guys played. IF you define your amplifier as part of a system then specify in your description that it's intended for use ONLY with "pre-ban guitars" it's o.k.. Yeah it's a play on words but that's exactly what the assault rifle guys did. Certain categories of parts were prohibited but other categories of parts continued to be sold for use on "pre-ban weapons ONLY". Your guitar is nowhere near as menacing as an assault rifle, I don't care how bad-ass you play! :lol:

You're telling me the 60/40 solder police can tell the difference from a Custom Shop relic and a real vintage guitar?! :lol:
dre95060
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Re: Agency Certification, RoHS--Question for the Pros

Post by dre95060 »

How about this:

It is illegal to sell the amp. So don't sell the amp. Sell the transferable right to use a non-compliant research prototype amplifier loaned to the licensee in perpetuity (or 99 years if "perpetuity" causes legal problems).

The licensee would sign a waiver stating that he understands that the amplifier has not been certified for safety or regulatory compliance and holds licensor harmless, etc. etc. The licensor could agree to recycle the amplifier for free in the event the licensee wants to dispose of it.

No sale of non-compliant equipment. Recycle plan in place. Back to making music.

What do you think?

Dave E.
muchxs
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Re: Agency Certification, RoHS--Question for the Pros

Post by muchxs »

dre95060 wrote:How about this:

It is illegal to sell the amp. So don't sell the amp. Sell the transferable right to use a non-compliant research prototype amplifier loaned to the licensee in perpetuity (or 99 years if "perpetuity" causes legal problems).

The licensee would sign a waiver stating that he understands that the amplifier has not been certified for safety or regulatory compliance and holds licensor harmless, etc. etc. The licensor could agree to recycle the amplifier for free in the event the licensee wants to dispose of it.

No sale of non-compliant equipment. Recycle plan in place. Back to making music.

What do you think?

Dave E.
I think it's a mother beautiful plan. For every measure there's a countermeasure, kudos for creating a practical countermeasure.

The point of RoHS is to keep hazardous material out of the waste stream. It's a knee jerk multi-directive from Brussels in response to the alarmingly short service life of the modern computer. We're not building computers. We're building musical instruments. Old Fender and Marshall amps are valuable instruments. You wouldn't throw out a 300-plus year old Stradivarius even if it was broken. You wouldn't throw out an old amp either if you had a kernel of knowledge. If they're not likely to enter the waste stream what difference does it make what they're made of?
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mhuss
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Re: Agency Certification, RoHS--Question for the Pros

Post by mhuss »

muchxs wrote: If they're not likely to enter the waste stream what difference does it make what they're made of?
I beg to differ, we better keep all the low-budget Fenders, Behringers and Peaveys RoHS! :lol:

--mark
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benjoi
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Re: Agency Certification, RoHS--Question for the Pros

Post by benjoi »

AMEN! :D
drz400
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Re: Agency Certification, RoHS--Question for the Pros

Post by drz400 »

dre95060 wrote:I have a lot of experience with mass produced electronics and I rarely see boutique amps marked as compliant with FCC Part 15 (A or B), UL, CSA, RoHS, etc.

I think it is pretty likely that most well-made amps would comply with FCC Part 15, UL and CSA. But the testing is expensive--about $5K to have an independent lab test for emissions, for example. What about RoHS? Compliance with RoHS means more than just lead free solder. You've got to have a manifest of all the components and certificates from all the suppliers showing the hazardous material content of each component. Would your average vacuum tube be able to pass RoHS?

How about exemptions? There are RoHS exemptions for medical equipment, servers and some routers (thanks to the clout of IBM and Cisco). What about musical instruments produced in low volumes?

Regards,

Dave E.
Tubes are exempt
RoHS is self testing, the manufacturer is responsible for certification
What really suprises me is how many amps that are small companies but expensive are not even CE tested. IMO that is irresponsible and opens the builder up to lawsuits with no leg to stand on. My father used to deal with UL and CE, CE is much cheaper and easier than UL.

BTW even though Rhos Solder is a new art to work with it really isnt that bad if you get the right one, I use the same temps about 650 dependig on the tip and part, many audio cork sniffers feel it actually sounds better.
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