Environmental Compliance - A Moving Target

Peter Robinson
TPP, Fort Walton Beach, Florida

Companies that have initiated internal resources to obtain compliance data have realized that collecting, and more importantly, maintaining the currency of that data requires more resources than available. For a case in point, one such company utilized 3 component engineers over 3 years to collect compliance data on ~5000 parts only to find out that all the data collected was now out of date. Why was it out of date? Among several reasons: the EU changed the method for reporting exemptions, REACH SVHC's were added (several times) and manufacturers were forced to change and republish their declaration documents to meet these new requirements. Additionally, in North America Conflict Minerals declaration has been introduced demanding yet more documentation collection and maintenance. And, there will be more change.

Compounding the resource need is a lack of standardized data. All manufacturers publish in pdf, Excel, Word docs, etc, where there is no normalized standard. The data needs to be "lifted" from these documents and transferred to a parsed database. Quality and accuracy is at risk both from the supplier (~40% of supplier declaration documents are currently being returned to the manufacturer for correction) and the manual transfer process itself. Additional resources are needed in QA personnel with a specialized expertise in Environmental Compliance.

A centralized, publicly available database would be ideal if there were a method of ensuring quality of data served, however getting the industry to adopt a standard has not been possible. There are opt-in web services that require the manufacturer to normalize and upload data to a portal; however there is no quality control and no guarantee that all suppliers will participate leaving the need, once again for dedicated internal resources to provide specialized QA/CE collection and maintenance personnel.

A study was conducted to determine what internal resources would be needed to accurately collect, QA maintain and produce product level compliance reports on ~5000 components and material. Here is a list of the findings:

•3-5 technicians to find and manually transfer the data from manufacturers published documents
•2 component engineers to review and QA the physical characteristics of the data collected
•2 Environmental compliance engineers to review, QA and manage the correction phase
•Database software
•IT implementation resources

Most companies do not have or can't afford this reality. Since the manufacturers are not likely to adopt a standard method for publishing in the near term, and more change is inevitable, the only solution available today is a 3rd party data provider; one that does have the resources to collect, QA, maintain and deliver. Our study found that the fees for these 3rd party services are typically less than the cost to implement the necessary resources internally. Other IPC members can attest to this and their success.

There are several companies that have successfully implemented Environmental Compliance Reporting. Companies like IBM, Emerson, National Instruments, and many more.

These companies realize that managing and maintaining the data is not for them. Managing the process is.

Call them and ask. They'll tell you.