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ROHS FOR RETAILERS - ROHS FACTORY INSPECTION/AUDIT
Module C is focusing on the production process and the influences of the production process to the end product.
This module is leaving the “Laboratory Approach” towards an ISO 9001/ISO 14001 oriented set-up combined with core safety elements of common CENELEC Factory Inspections.
Module C is to judge the capability of the end assembly line (end production line) to produce products, fully in compliance with the requirement resulting from RoHS Directive 2002/95/EC.
Module C investigates, but is not limited to, the following aspects and criteria of production:
Organisation:
- Influence of the quality control (QA/QC)
- Control of subcontractors; how?
- Factory/end assembly line responsible for product modifications?
- Internal approval system for modifications available?
- Will be the client informed about product modifications?
Incoming Inspection:
- Who performs incoming inspections, QA/QC?
- Location/Work situation?
- Marking of RoHS relevant (critical) components and materials? Related to Constructional Data Format (CDF)?
- How is the inspection status marked? Are separated locations applied for each inspection status?
- How are the inspections performed? Which standard(s) is/are used?
- Checklist for RoHS approved components and materials available?
- Who decides about the checked items?
Warehouse/Stock:
- Locations/Conditions (e.g. inside/outside, secured)
- How are RoHS approved components, materials and sub-assemblies discriminated?
- How is the correct component/material/sub-assemblies flow in production guaranteed?
Component/sub-unit assembly:
- Components/Maker?
- 100% Evidence of RoHS Conformity?
- Documentation available? Kind of documentation, e.g. Test Records …,?
Production:
Identification RoHS relevant production stages?
- Working instruction available at all places?
- Trained personal in production?
- Is a production control (line patrol) performed?
- Which traceability system is used to identify later, each unit?
- Which product identifier (system) is used during the production?
Sample Test before Shipment:
- Is QC/QA performing this test?
- Location / Conditions?
- Which standard(s) is/are used to perform the sample test before shipment?
- Lot size / Sampling rate?
- AQL Level?
- How often occurs a lot out? Reason(s)?
- How is/are rejected lot(s) handled? Repaired and re-tested in total again?
The elements, included, but not limited to, of Module C can also be customized to special needs of the retailer/importer. Module C is not judging the safety relevant or performance aspects of a product leaving the end assembly line. It is purely focused on the important and relevant RoHS criteria.
Module C, combined with the previous modules A and B, are controlling the complete supply chain (line purchase), in order to judge on RoHS compliance of the goods imported by the retailer/importer into the European Union.
Production process and modular RoHS concept:
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