How the EU RoHS legislation turned engineers into lawyers: : š
From a Project Management perspective it can sometimes be a little frustrating when there are delays due to the BOM verification on an electronics project: particularly when the environmental compliance aspect did not used to be a check list item: …
Just a few years ago the engineering team built some prototypes generally at project phase two, ran pilot at project phase three, ran DVT on the pilot product, ran the results past the reliability team: signed off on the thing and called it good:
Ah those were the days. Unfortunately, RoHS turned every manufacturing and component engineer into a lawyer…….
Ask an engineer in electronic manufacturing industry the levels of lead, cadmium, mercury, hexavalent chromium, PBB’s and PBDE’s in their products, and I would bet you lunch that he can name the substances, the threshold limits, labeling requirements, and probably a great deal of other detail.
The reason for this is that it is LEGISLATED: and while there has never been a case of anyone being harmed by any of the threshold legislated substances by handling a piece of electronics (unlike other products such as toys, jewelry etc etc) electronics hazardous substance threshold levels are now the LAW. Ā Ask an engineer in a non electronics based industry the same question and I can pretty much guarantee you a blank stare and a response of “who want’s to know”?
In the case of environmental RoHS legislation in electronics, the EU, China, Korea, Japan, and California – they ALL want to know. Not only that but if you don’t know, you are liable to incur a (very large) fine for the corporation.
Added to that – if the product is found to be non compliant at a spot check in Europe, you might want to advise your CEO not to travel to Europe for a while as he may find himself in court:
You get the picture: serious stuff: very serious:
So to re-cap from a program management perspective, the component and manufacturing engineers, along with the design team are responsible for ensuring that the components, as well as the materials used in the construction of the product conform to threshold limits for the country to which the product is destined. And this requirement should have been written large in the program scope at project phase one.
This adds a layer of complication to the project schedule that should be addressed from the outset. EVERY component needs to have some kind of declaration by the manufacturer of compliance with the required threshold level (generally but not always those found in the 6 substances highlighted by the RoHS legislation).
From an action plan perspective, this needs to be planned from a very early stage, and if the project FCS gate is at phase 3, then an action plan based on the countries to be shipped to (outlined in the MRD produced at project phase zero) needs to be put together to checklist and control activities of data gathering and verification through stages one, two and three. Data verification of compliance MUST be a gating item for FCS of products being shipped to countries where environmental legislation is in place.
Fortunately, just about every manufacturing and component engineer on a global basis is aware at least of the requirements, if not the implications of non-conformance.
The easiest way to get the data required is to either arrange to download it from the manufacturer site OR should this not be available, request it on the standardized IPC1752-1 environmental declaration forms which can be downloaded from the IPC web site. The data should be verified, component by component, by a trained component engineer, and a sign off certification by that department should form the basis of ticking off the checkpoint to move on. A lot of companies additionally actually test a number of components on the BOM as a due diligence exercise and record those results on the project BOM environmental compliance file.
Note that all of these records should arrange to be stored for 4 years: .and must be produceable on demand within a one month time frame if so desired by the EU.
Be diligent: keep the CEO out of jail: look on RoHS as an environmental Sarbanes-Oxley requirement and you will not go far wrong.
I hope this has been useful, tomorrow we are going to take a look at what the reliability and quality teams are faced with in the changeover to lead free and the challenges for the manufacturing engineers: and how this can impact historic schedule expectations.
Santa Clara CA, 11/14/07 email john@RoHSUSA.com
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