In the previous installment of this column, I described the three basic steps to chemical-related environmental compliance:

First, identify and understand the substances in the products you are placing on markets around the world.

Second, understand the regulatory (and market/customer) requirements regarding the substances in the products you are placing on those markets.

Third, make sure that the products placed into and sold in those markets meet or exceed the requirements.

In this column I will start to cover some approaches for, and challenges to, weaving environmental compliance into product lifecycle processes. Future installations will continue the discussion.

1. Identify and Understand Substances

As noted previously, collecting information about the substances used in the items and materials you’re buying from your suppliers is often quite challenging. I want you to think, though, about every other specified requirement you have for your suppliers: how do you get them to produce what you want? Is it as challenging to get them to meet the environmental information/compliance requirements? Generally it’s not – but why not? You may directly, for custom or configurable items, specify parameters like color, quantity, operating temperature range and so on. Likewise, for off-the-shelf items, you specify these and other parameters indirectly by accepting the suppliers’ datasheets. But how do you know you will be getting what you specified?

Because you analyze and assess the supplier’s ability to provide it to you.

Before I turned to the dark side and became a consultant one of my responsibilities (at a couple different large electronics manufacturing companies) was to assess and validate various suppliers’ (both of custom and off-the-shelf items) abilities to produce what we needed at the volumes and quality we desired. To implement such a procedure, my companies had devised (or, more accurately, “borrowed”) an approach – which is now quite standard – consisting of extensive audit and assessment protocols that included pre-audit questionnaires, procedure and data collection, onsite visits and factory walk-throughs, scoring sheets, and eventually, a determination of whether the supplier would be acceptable to us. Levels of acceptability were defined – sometimes there was a weakness or two that we wanted to see improved but otherwise the assessment determined that the supplier would be fully capable of meeting our requirements. And we would work with them on these weaknesses. Sometime a supplier would have too many weaknesses so had to be disapproved or otherwise removed from our Approved Supplier List.

Never did we look at our suppliers’ ability to provide us with material composition information or other environmental – or social – performance data. Back in those days there were no requirements for it in our world.

But today things are different; the supply chain has been placed under regulatory control for substances used in products (e.g., RoHS and REACH) and for sources of certain metals (e.g., “conflict minerals”). Therefore, these are now akin to parametric requirements for your suppliers and the products they sell to you. Therefore, if you have not done so already, you will have to add these requirements to your approach to supply base assessment or vetting.

Evaluating a supplier for their ability to provide you with material or upstream supply-chain information is, superficially, no different from evaluating any other aspect of their quality management system. But, as opposed to asking whether they use statistical process control and to demonstrate that operators can read charts and have authority to stop production if necessary, you have to ask them:

  • how they identify the substances used in their products,
  • what means they use to determine whether a substance is or could be restricted or is otherwise undesirable, and
  • how they control their supply base to ensure that their products do not contain such substances lot-to-lot and over time

I help my clients review their current approach to supply base management and identify what questions they will need to ask in order to be comfortable that their suppliers will be capable of providing the type of product environmental compliance information you need. Often I find that if they don’t assess their supply base for a capability that is necessary, they don’t get what they need.

As with other issues, there are some suppliers out there that you don’t bother assessing. These tend to include big manufacturers that are central to the industry’s success and must have solid systems in place already. With these companies, your ability to get information may be limited to what you can get from their website, from a rep or distributor, or from their sales or applications engineering support people. As some aging rock star once sang (and keeps singing, to this day), “you can’t always get what you want, but if you try sometimes you just might find you get what you need.”

I prefer to get full material disclosure from suppliers; if my clients have that, they don’t have to wonder whether a part contains any substances in the next list of REACH candidate SVHCs or not; furthermore they don’t have to spend the time and effort to go back and ask the supply base about it (and this saves supplier time and energy as well). And if the supplier’s Product Change Notice (PCN) system works properly (this is another subject for supplier assessment, and if it’s already being vetted, ensure that you’re also vetting it for notifying you of any changes to substances, materials, or composition), you won’t have to go back to them to get the information; that saves both you and your supplier time and effort.

Unfortunately, chemical and substance identity – since it was, in most cases, never really considered to be of critical importance to downstream users like the electronics industry – is often considered to be Intellectual Property. Despite being protected by nondisclosure agreements, some suppliers simply will not provide you with a complete list of substances in the item they are selling to you.

Therefore, before you assess your supply base for whether they are able to provide you with the degree of information you want from them, you must first determine what you want, and then you must define what the minimum amount of information you are willing to accept is, and – more generally - what format you are willing to accept it in. Define what you want, define what you need and will – at a minimum – accept.

Some key aspects of this process are:

  • Define how you will vet your suppliers. It almost always helps to have a standard to point suppliers (and your engineering team; we will address this in a future installment) toward. The standard can be internally developed and defined or external, such as IEC 62474; but use care to assess the applicability and veracity of an external standard to meet your needs.
  • Identify the suppliers that you will have to vet through either a desktop or onsite assessment process, as well as the characteristics of new and proposed suppliers that will require such an assessment in the future
  • Put those current suppliers through the process and see how they do. Some may need education, guidance, or process development help. Some may be beyond hope and may have to be terminated and replaced; you must be prepared for this as a possible outcome.
  • Expand your supplier scorecard process to include compliance requirements; track how your suppliers do in the same manner you do for on-time delivery, quality and other metrics

Next time I’ll address the second topic, understand the regulatory and customer requirements for your products in your markets. This is a pre-requisite to knowing what it is that you actually need.

Mike Kirschner

Mike Kirschner

Mike Kirschner is a product environmental compliance and performance expert who provides advice and expertise to manufacturers in a variety of industries. His primary areas of focus include EU RoHS, the impact of EU's REACH regulation on article manufacturers, California’s Safer Consumer Products regulation, and performance standards like IEEE-1680.x for electronics. Mike helps manufacturers define, implement and troubleshoot internal management systems that result in compliant products, and assesses and monitors environmental regulations around the world on their behalf.

He contributed two chapters to the Governance, Risk, and Compliance Handbook, published by Wiley in 2008, and is featured in the critically acclaimed book, Exposed: The Toxic Chemistry of Everyday Products and What's at Stake for American Power. In 2009 he was appointed to the California EPA Department of Toxic Substance Control's Green Ribbon Science Panel. Prior to joining ENVIRON, Mike founded product lifecycle and environmental consultancy Design Chain Associates, LLC (DCA), where he serves as president. Before founding DCA in 2001, Mike spent 20 years in engineering and engineering management roles within the electronics industry with manufacturers including Intel and Compaq. He holds a BS in electrical engineering from Worcester Polytechnic Institute.

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