One of our readers posed an interesting question. What do you do when you use one of the banned RoHS chemicals in a non-electronics application nad your customer asks if it’s RoHS compliant? Here’s the reader’s question:
"My sales group is pushing me hard to zinc plate with gold chromate conversion (Cr 6, hexavalent chrome is there in some form) some valve bodies and discs we make to replace a simple enamel paint job we hand-apply to the valve body.
"The question is — in the gold chromate conversion process or application, the hexavalent chrome is not emanating off, or I think, not leaching off the valve as it sits in a pipeline, possibly for many years, until disposal is necessary due to changes or obsolescence. Even then, upon disposal, does it become a possible hazard issue? If people handle coated valves, do they face hazards?
"Millions of components are currently zinc plated with chromate conversion coating added to brackets and fixtures. Do these components violate the RoHS directive and therefore, are they restricted from exportation? Do they pose disposal issues?
"I have customers asking for declarations that certify that we do not ship valve assemblies in violation of RoHS, even when there are no electrical components involved. But when a coated valve with the chromate conversion process is added, we cannot determine if we have a product that may violate the RoHS directive. Some customers just want an "across the board" declaration that we do not have components that contain any of the banned substances."
Anyone out there have any comments on this?