Agency Certification, RoHS--Question for the Pros

[dre95060]

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.

[LOUDthud]

RoHS is one thing, I don't think it applies in the US. But does it mean that Tin-Lead solder will be hard to get one day?

UL, CSA, CE et al is another matter. Have you seen how many fuses and other protection crap they've added to most Fender schematics? All it takes is one back woods Fire Marshall to point a finger and say " I think it was that there geetar ampliwhatchamacallit that started the fire" and you have to prove to a jury in a civil trial that you amp didn't start the fire. And don't forget about Wrongfull Death claims. Something to think about.

[dre95060]

RoHS applies only in the EU (right now, anyway). It may very well be that Sn-Pb solder will be hard to get one day. SnAg or SnAgCu solder are the substitutes, but they have a number of disadvantages. First, they melt about 25-30degreesC higher than Sn-Pb so the components have to be able to withstand the higher soldering temperatures. Second, the joints are less reliable. And third, the joints look like "cold" joints (i.e. ugly) so it is hard to tell if you've got a good solder joint or not.

Another problem is that if you use both types of solder you have to segregate your tools and rework stations (separate soldering irons, etc.) so that you don't pollute the RoHS stuff with lead. If you get accidentally get lead into a RoHS wave soldering machine, for example, it costs about $8K to fix it. (Not a problem for most of you, but a fact.)

Frankly, automobile batteries contribute far more lead to the environment than all the electronics combined. But I don't see them banning those.

Regards,

Dave E.

[kec]

RoHS applies only in the EU (right now, anyway).

Yes, but if U.S. companies want business in the EU they're going to have to comply.

I work for Panasonic Avionics Corporation. We manufacture IFE (In-Flight Entertainment) systems to the airline industry. We started our RoHS program in 2005. Since our parent company is MEI (Matsushita), they had already started RoHS compliancy of all of their electronic components. Needless to say, any subdivision of Panasonic also had to comply.

The solder issue has been a problem and I'm not sure how we handled that.

[LOUDthud]

I worked a year in the oil well service industry (not Haliburton). The stuff we made had to survive 400 degrees fahrenheit. There were two types of solder. One was 98% lead and the other was 98% tin. If you mixed the two types it melted at a lower temperature.

A friend of mine had trouble with Peavey Mace amps melting the solder in the pcb mount power tube sockets. I suggested he try the no-lead solder from Radio Shack and he never had any more problems. It aint pretty but I think it's stronger than the 60-40 I've used since forever.

[paulster]

There is a good chance you're going to get RoHS in the US, whether directly or indirectly.

It's been implemented in Europe and in variant form in China and Japan (and California, apparently).

This means that manufacturers can't even sell components to these regions unless they are compliant, so the manufacturers are going to retool rather than lose a huge market. Sprague Atom discontinuation rumour, anybody? This was while they were re-tooling for RoHS.

I think CE compliance is the more difficult piece as, again, it's illegal to sell any product in Europe which isn't CE compliant. This means that most of the boutiques (I'll exclude Fuchs as he's compliant and it'll be interesting to hear his thoughts on the whole issue) that are being sold anywhere in Europe are being done so illegally. No ifs, no buts; if there's no CE marking on it then that /13, Komet, Bruno, whatever, cannot be legally sold in Europe.

I think if one of the distributors were to get raided or a shipment to be seized then we'd suddenly see more of an interest in what CE actually means from the North American side of the pond (not to mention a whole load of very upset musicians)!

[David Root]

This month's Tonequest magazine has an interview with Randall Aiken in which he discusses RoHS compliance, amongst other things. He is going to do it and he believes it's coming here soon too.

He also uses OrCad PSpice circuit simulation software to do basic design of the entire amp. I looked it up on the web, $8,995! Too rich for me. There must be something cheaper out there that's analog only.

This whole liability thing also bothers me. All my backplates have a warning with lightning bolts either side of it, whether or not I intend to sell it, not that that would stop any lawyer from bankrupting me.

[d2camero]

Check out duncan amps on SPICE modelling.

http://www.duncanamps.com/spice.html

You can also download the free: LTSpice/SwitcherCAD III simulator. You don't have to be rich to model.

d2

[jjman]

If I travel to Europe do I have to document that I won't fart? This could be a problem for me.

[Fredaxis]

If I travel to Europe do I have to document that I won't fart? This could be a problem for me.

YES

Anyway, with he difference in food you may have problems

Seriously speaking, interesting that I can order any type of non RoHS from big suppliers in the US and get them delivered to France with no questions or problems.

[David Root]

Thanx d2, I have played a little with the duncan stuff, but not the other one. I'll check it out.

[paulster]

Seriously speaking, interesting that I can order any type of non RoHS from big suppliers in the US and get them delivered to France with no questions or problems.

That's perfectly okay as you're allowed to import and use non-RoHS parts. You're just not allowed to sell anything you build with non-RoHS compliant parts unless it has an exemption. Repairs are allowed to be done with non-RoHS parts where the product pre-dates RoHS and it is only a 'repair'.

[Fredaxis]

Good to know,
Thanks Paul

[muchxs]

I'm not worried about RoHS. Maybe with the Euro close to $1.50 U.S. I should be....

Think about all the "next big thing" scares. Remember Y2k? It was supposed to be the end of the world. It went off without a hiccup.

Remember "digital ready" hi-fi? People trashed lots of great gear because it wasn't "digital ready". It turns out that old stuff was better than a lot of the new stuff, we knew that already...

California smog requirements were perceived as being the death of the enthusiast automobile. Turns out that the rat rodder can get on eBay and buy the parts to build a perfect clone of a late '40s lakes car. Smog exempt. Kinda like building tweed Fender clones...

In '94 we had the "assault rifle ban". It was supposed to "take a bite outta crime", all it did was make military style rifles and high capacity magazines sell like there was no tomorrow. Prices skyrocketed, too. The big secret was that the law would eventually "sunset", now you can buy a semi-auto AK47 with high capacity magazine, flash hider, bayonet lug and pistol grip again... unless you live in New York, California and a couple other backwards states. It still doesn't keep the locals from poppin' holes in each other out on the freeway.

Apparently there's a clause in the Kyoto Accord where participating nations agree not to dump their non-conforming electronics or electronics salvage in or on other nations. The U.S. is a non-participant and a substantial exporter of electronics salvage.

Like Frank Zappa's "Central Scrutinizer", the law sometimes makes ordinary everyday activities illegal. What bureaucrats ignore about the law is that simply writing it doesn't make it so. Without enforcement and more to the point appropriations to support enforcement the law is just that, writing on a piece of paper.

Perhaps we the boutique amp industry should bomard our representatives with letters to the effect that vintage reproduction and hobbyist electronics should be exempt from U.S. version of RoHS. If it's o.k. for IBM it's o.k. for us, right?

I'll give up my soldering iron and my vintage style tin/lead solder when they pry it out of my cold dead fingers!

[jjman]

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!