Environmental compliance: Putting it all together (or have it all fall apart: )

A fast overview of the things you need to check from a project management perspective.

(Friday …… at last…………..)

This week we have looked at a number of areas.

The first is that of the environmental compliance actions arising out of the MRD (Marketing Requirements Doc).

Everything related to environmental compliance hinges on this document and the geographic areas into which the equipment is going to be shipped. Lack of attention to detail in the Marketing Requirements Document can result in the equipment being re-designed at a later stage (best case) OR being impounded by a country for environmental non compliance : : : ..expensive: ..8-)

From a project management perspective there are two main areas that will come out of this document and dictate the complexity or otherwise of the checklists for the various project phase gates following project phase zero.

The two main areas of compliance break down into two areas which are:

1                   Reporting and labeling requirements
2                   Hazardous substance compliance requirements

In the case of Reporting and labeling requirements this is normally associated with areas such as the EU (European Union) which requires records of types and quantity of equipment shipped into the various EU countries.

From a project perspective it is a matter of ensuring that there is a process in place for the product to maintain a shipping log – broken down by SKU and destination by date and that there is also a system I place to report and where required pay recycling fees to the various government authorities.

In the case of the labeling, a check list will contain a number of marking requirements for the product depending on where it is shipping to. In practice most companies are actually applying multiple labels to their products in order to comply with different labeling standards. It is quite common for instance to see an EU “wheelie bin” logo for WEEE sitting next to a hazardous substance declaration label required in order to comply with the China MIL requirements.

On item 2: Hazardous substances there will be many areas of the project phases that are impacted.

Most of these appear in stages 1 and 2 of a project which gates FCS through a pilot run success during phase 3.

During these phases there will be many check points regarding the BOM content which will look at the actual component compliance from a substance threshold limit. The checklists will also contain check points items for compliance certification and also check points for engineering sign off of things such as board materials and circuit board finishes as being compatible with the process both in terms of metallurgy as well as being able to withstand the increased temperature of lead free soldering without damage or reliability implications.

On the actual proto and pilot runs there will be process sign off check points, generally for the manufacturing engineers as having approved reflow profiles. The quality department will sign off on the quality of the products pre pilot which will be used to “tune up” the manufacturing process to ensure a smooth pilot run.

The checklists will also contain items related to reliability of the product and which may be related to the DVT (Design Verification Testing). This is generally in the form of 4 corners testing, while the equipment is undergoing simultaneous vibration levels. It is these tests which will give a very good guide to the integrity of the manufacturing process (but NOT NECESSARILY long term reliability).

Part of the long term reliability testing might appear as a checkpoint for the result of JEDEC thermal cycling to ensure long term reliability of the product through multiple thermal cycles. It will also contain items such as drop tests results.

There will also be check points to ensure that both the materials used in the construction of the product have been received and the documentation filed for 4 years in an accessible fashion. At a different point in the project during the pilot run there will also be documentation produced that will ship with the unit to declare it’s compliance to your customer (Probably an IPC1752-1 declaration)

All of this should get you through a successful FCS: providing that you have a successful pilot run (with a high yield!) which will prove out all of the manufacturing process, and the resulting DVT testing will prove (or not) that the design has achieved what the system architects set out to do.

Project Management: through the use of appropriate check lists which map to the PLC phases and review points are critical to the timely launch of an environmentally friendly product.

Cut corners on any of this, and the downsides are really very predictable: here are a few examples:

The product fails in the field at unacceptably high levels.

The product gets impounded in the EU or China for a labeling infringement.

The product gets impounded due to a spot check revealing non compliance on threshold levels.

The company gets fined through inability to produce compliance documentation.

The CEO gets a free trip to Europe to answer to non compliance charges in a European court: : .

Like I said: really important stuff. But what is REALLY important is that we comply because it is benefiting the planet. The legislation coming after the RoHS et al laws are actually a lot more useful from a planetary environmental viewpoint. The EuP (Energy Using Product) laws will eventually dictate the amount of power that electronics consumes both in use and in standby mode: these laws will make a significant difference to the way we design and manage our electronics product designs.

Like I said in a previous blog, I will be blogging very late on Saturday and Sunday: I am going to break some clay birds down at the range: : :
Santa Clara CA, 11/16/07 email john@RoHSUSA.com

PULL: : : : : : : 😎


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