Of the steps leading up to compliance declaration, data collection has stood out as a major bottleneck for most companies in the compliance management process. Most tend to underestimate the amount of effort that is required to collect the necessary component data for compliance analysis and validation. The lack of preparation before undertaking data collection further complicates the problem and extends the time lag in the cycle. There are, however, critical steps that can alleviate data collection grief.

Step 1: BOM scrubbing/parts cleansing

Starting a compliance management program with a clean slate is something that makes sense to everyone, and yet, is often overlooked. Dirty data from ERP/PLM systems can lead to unnecessary overhead going into compliance management. Problems such as duplicate part numbers and inconsistent manufacturer naming will increase both time and resource costs during the data collection stage. In some cases, these issues can also lead to error.

Investing internal resources to clean up parts data is one way of resolving the issue. However, this option might not be very realistic under certain circumstances. Small and medium-sized companies often will not have ready resources to spare on this time-intensive task. Even larger manufacturers will have problems with insufficient resources where a quick data turnaround is expected. In these types of situations, companies can consider external data service providers. With focused expertise, these services are usually able to clean up dirty data in a comparatively shorter amount of time as it would take internal resources.

Step 2: collect data on commodity parts

After the parts data is cleaned and ready to go, data collection can be initialized. While some may immediately rush to suppliers or distributors with data collection requests, it is important to realize that a good portion of the data you're seeking might already be available online. More and more component manufacturers are beginning to publish not only RoHS status information but also full material composition disclosure through company web sites. Heading to these sources for compliance information on commodity parts will give your data collection process a jump start.

In practice, many issues arise, most stemming out of the question of whom to assign this task to. In some cases, the data collection task is given to the procurement team since they're most familiar with current suppliers or distributors. Unfortunately, procurement, more often than not, lacks the knowledge or expertise to correctly identify the information they're seeking. For example, procurement will usually use manufacturers' part numbers to look for part material composition data. However, many parts only have their material composition information listed based on package type, without part number associations. Circumstances like these can significantly stall the data collection process. At times, engineering resources are employed to complete the task of data collection. Though domain knowledge is no longer a concern, this choice carries an obvious cost to product development.

Utilizing RoHS database solutions may resolve these issues while providing additional advantages. Two key benefits of database solutions are that they provide fast results and relieve the user of maintenance concerns. These systems not only provide the user with instant download of material composition data but will also automatically update when the compliance status changes, parts become obsolete, etc. The decision between choosing to commit internal resources and using a database solution should be based on a thorough cost analysis. Steps 3 and 4
Step 3: collect data from suppliers

Unfortunately, data collection cannot be completed solely using online sources. Compliance data will still need to be collected from suppliers for custom parts and some commodity parts. This is the single step in the entire compliance management cycle where things can really come to a halt. Data collection requests will often travel through several tiers in the supply chain. The communication lag back and forth can be tremendous. Even when supplier documents are collected, a simple review will often find them to be invalid or incomplete. Suppliers may submit data that is lacking required information, or for instance, missing one or more of the six substances required for EU RoHS. In other cases, suppliers may provide only a certificate of compliance and nothing else.

Setting up a supplier portal is an efficient method to automate consistent communication with suppliers. Companies with existing ERP systems can customize these for compliance document exchange and control. Smaller companies can consider third-party portal solutions that not only centralize document storage but can also manage all e-mail communications. With built-in document approval flow, these solutions will always keep track of document status and allow for approval collaboration across different internal teams.

Step 4: compliance validation and declaration

With data collection hiccups out of the way, we come to the end goal of compliance management — compliance validation. While smaller companies might be able to manage compliance reviews using spreadsheet programs, this is not very realistic for anyone with a decent amount of data. An option for larger manufacturers might be to customize existing PLM software. However, as PLM systems are already laden with product design information, sourcing information, and much more, adding in chemical substance information may have a serious impact on performance. In addition, since compliance regulations are constantly changing, companies should evaluate the availability of IT resources for future maintenance before plunging into PLM customization projects.

An alternative to PLM customization would be to select an appropriate compliance software solution. The accompanying Software Comparison Matrix provides a highlight of specific advantages compliance management software have over PLM solutions.

Click the link for the compliance management and PLM software comparison matrix .

The 4-step process described in this article summarizes insights gained from over thirty industry case studies. In our experience, while there may be no magic formula for compliance management, you will find that employing efficient data collection strategies and process automation can provide shortcuts along the way. Furthermore, instead of looking for piecemeal solutions that might target only one step of these best practices, you should look for a solution suite that creates synergy by providing seamless integration of RoHS data and management software.

About the company: Pacific Oaks Technology's Green Information Management Solution (GIMS) combines RoHS data services and software tools to return maximum results under time-critical conditions. For more information on compliance management best practices and GIMS, visit www.pacific-oaks.com.

Emily Wang can be reached at ewang@pacific-oaks.com.