Electronic manufacturers have less than eight months left to ensure compliance with the EU's Restrictions on Hazardous Substances (RoHS) directive. Various interpretations of the directive's requirements have exacerbated the significant technological challenges to successful compliance. But these guidelines will go a long way toward helping you reach that goal.
As a global manufacturer of electronic equipment, IBM must ensure all of its equipment sold in the EU complies with RoHS. The directive applies to nearly all electrical and electronic equipment marketed by IBM. The company must take the necessary steps to ensure the constituent parts and materials it procures for use in its products meet the directive's requirements. In many areas of IBM's business, IBM will not be the actual manufacturer of the final product. Regardless of the actual manufacturing source, though, all relevant part numbers IBM and its suppliers release, procure, or designate a design for must comply with the directive. Thus, they must have a statement of compliance.
The first line of defense in ensuring RoHS compliance is a set of clearly written, thorough, and technically astute engineering specifications that direct the product and process decisions made within the internal and external IBM Integrated Supply Chain. IBM specifications that control RoHS compliance exist on multiple levels, with various specifications addressing different facets of compliance. The overarching corporate-level environmental requirements—intended to ensure global product regulatory compliance—are detailed in an IBM handbook available to all employees in hardcopy and on the company's intranet.
Product-level engineering specifications that are intended for use by internal product development organizations establish RoHS compliance requirements and describe acceptable materials and finishes in IBM products. Materials considered acceptable have been identified to satisfy all regulatory requirements and ensure product reliability.
Procurement specifications, intended for use by thousands of IBM's hardware suppliers, many of whom will need to supply RoHS-compliant materials and parts, have been drafted as companion documents to support the product-level specifications. Sharing this documentation and reviewing it with your supply chain is crucial. In addition, procurement specifications for many commodities, such as pc boards, hard-disk drives, CD-ROMs, and tape devices, will require updating. For example, IBM's card assembly specifications require RoHS updates to address the consequences of material changes and elevated processing temperatures.
All RoHS-impacted IBM specifications are still quite dynamic, subject to frequent engineering changes as the state of industry knowledge progresses. The key to effectiveness is being proactive and updating parties in real time.
Product compliance will require a rigorous control process within the supply chain that services all product manufacturing. This process combines both IT and manual checking:
- IBM will obtain materials declarations for all individual components and sub-assemblies, as well as carry out selected compliance analyses. Once submitted to IBM and confirmed, the data gets logged into the IBM i2 eXplore parts database for each part number in the system bill of materials (BOM).
- Using an application from Synopsys, IBM engineers can create an itemized BOM by part and/or supplier that cross references with the parts database to further ensure compliance.
- In addition to IBM's existing product design stage gate process, which determines the products and services that have the greatest market potential and controls the release of products to market, a stage gate process will create a checkpoint to review the BOM to ensure that it is RoHS-compliant.
- Once the product is made generally available, the IBM Materials Laboratory will conduct random-sample tests of materials, components, and assemblies at all of the IBM manufacturing facilities worldwide to assess compliance of procured items.
Don't wait until the last minute. RoHS compliance is a challenge to inventory and technology. But with a strong team and the right methods and strategies, compliance is attainable.
