Designing a Data Storage System for Environmental Compliance (Focusing on RoHS-type Legislation)

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1 Designing a Data Strage System fr Envirnmental Cmpliance (Fcusing n RHS-type Legislatin) Krista Btsfrd 5-trees LLC Burlingtn, MA, USA kbts@5-trees.cm Abstract As mre gvernments pass, implement, and enfrce envirnmental cmpliance initiatives cvering electrnics, small t medium sized businesses cntinue t struggle with what data shuld be tracked, hw t track it, and keeping current n legislative changes. This paper will fcus n hw t stre and rganize cmpliance data as well as what a cmpany shuld lk fr in a data tracking system. Backgrund & Intrductin In 2003 when the Eurpean Unin (EU) passed the Restrictin n the use f certain Hazardus Substances Directive (RHS) cmpanies began scrambling t gather cmpliance data fr electrnics parts and cmpnents. The EU s RHS Directive restricts the use f six substances in electrnic and electrical equipment: lead (Pb), mercury (Hg), hexavalent chrmium (Cr6), cadmium (Cd), plybrminated biphenyls (PBBs), and plybrminated diphenyl ethers (PBDE). Even thugh there were n specifics n what data was needed t prve cmpliance with the Directive, mst cmpanies began gathering certificates f cmpliance. Sme cmpanies went a step further and began requesting materials declaratin data frm the supply chain. The industry began dcumenting cmpliance with the EU s RHS Directive by btaining certificates f cmpliance (CC): a simple frm stating the part r cmpnent purchased met the EU s RHS Directive. Sme CCs were acceptable t meet the burden f prf fr cmpliance; sme were wrthless. Since the EU s RHS Directive fcused n the amunt f restricted substance at the hmgeneus material level, cmpanies als began requesting infrmatin n the level f restricted substance cntained in each material f a cmpnent r part. In respnse t this request, the supply chain returned CC s stating that restricted substances were belw the expected restrictin levels specified by legislatin. A typical CC r materials declaratin respnse nly included the six restricted substances listed in the EU s RHS Directive. Eventually, guidance n hw t cmply with the RHS Directive emerged frm varius surces. The United Kingdm was the mst vcal f these surces. It published a nn-binding gvernment guidance dcument n the RHS Directive. The EU Cmmissin als published a Frequently Asked Questins dcument, which assisted in clarifying many f the definitins used in the RHS Directive. In 2006, the EU Cmmissin published an enfrcement guidance dcument t assist member states with evaluating and enfrcing cmpliance with the RHS Directive. In respnse t the guidance frm the EU Cmmissin and ther surces, several cmpanies began implementing a mre systematic apprach t cllectin and strage f data supprting cmpliance with the RHS Directive. Cmpanies als began wrking n a strategy t prtect themselves frm implicatins f ptentially false data. Prduct lifecycle management sftware suppliers began ffering add-n mdules t assist cmpanies in dcumenting cmpliance. Cmpanies created custm questinnaires and sent them t suppliers fr cmpletin. Mst questinnaires were in a spreadsheet frmat s suppliers were nt required t btain specialized sftware. These data files were created manually by entering data int the spreadsheet r a database which transferred the data t the spreadsheet fr distributin. The fld f unique questinnaires created a significant need fr standardizatin f the frmat in rder t facilitate data exchange. Withut a glbal standard available, the supply chain was verwhelmed by requests fr data. In respnse t the need fr a glbal standard, IPC released the IPC-175x series f materials declaratin standards. The IPC standard is Dwnladed/Printed frm

2 designed t gather materials cmpsitin data and t prvide the ability t create a certificate f cmpliance. Currently under review by the IPC 2-18 cmmittee, the 175x-series standard prvides a basic frmat fr gathering, maintaining, tracking, distributing and reviewing materials declaratin infrmatin. The Data What t Cllect In an ideal situatin, a cmpany wuld send a material data request and the supplier wuld cmplete it with all materials listed at the hmgeneus material level. Als, a supplier wuld prvide a certificate f cmpliance with each shipment either in hard-cpy r electrnic frmat. In reality, a generic certificate f cmpliance r a generic materials declaratin is returned. Rarely are bth dcuments returned in ne request respnse. With cmpanies beginning t apprach envirnmental cmpliance in a mre practive manner, it is recmmended t nt nly gather data n the txic six frm current RHS-type legislatin, but begin requesting full materials declaratin. This means that cmpanies shuld cllect data n every substance used in the manufacture f the part r cmpnent which remains with the part. A cmprmise between full materials declaratin and the current RHS txic six materials is t gather data t the Jint Industry Guide Materials Cmpsitin Declaratin fr Electrnic Prducts Annexes A and B (aka JIG-101 r JIG A&B). This standard (c-authred by EIA, JEDEC, and JGPSSI) lists substances which are restricted, reprtable, r prhibited by existing legislatin. It als lists substances f cncern t industry and/r gvernment. In additin t the materials declaratin data and certificates f cmpliance, cmpanies shuld als gather data n the supplier s envirnmental activities. This wuld include infrmatin such as the supplier s envirnmental plicy, internal r external audits regarding ec-cmpliance, qualificatins r certificatins in regards t ec-cmpliance, and any dcuments pertaining t verall envirnmental effrts such as cnsumables recycling. The data culd als include any quality certificatins, such as ISO-900x. It is recmmended that cmpanies als have an internal plicy stating their wn effrts twards envirnmental cmpliance. This internal plicy may include radmaps, team member names and jb descriptins, and cmpliance prcedures. All f these dcuments, in additin t the data strage system, are part f an verall ec-cmpliance strategy. Hw t Cllect Cmpliance data can be cllected in a variety f ways frm manual t semi-autmatic cllectin methds. Manual data cllectin means gathering data via direct cntact with the supply chain. Data is gathered thrugh s, phne calls, fax cmmunicatins, and web searches, and placed in a central depsitry. If the data is available in a machine readable frmat, it can be autmatically upladed t the central system. Tday, mst data is cllected via semi-autmated methds. This includes the use f frms r custm questinnaires. Fr example, the IPC-175x Materials Declaratin standard can be used t gather data semi-autmatically. The frm requires initial, manual input but sme cmpanies have develped internal peratins t autmatically return a cmpleted frm. Regardless f the hw cmpanies gather data, the strage methd needs nt nly t be rganized, but als have the ability t be searched and distributed. Frmat The strage frmat depends n the type f data. Human-readable frmats are cmmnly used fr dcuments which supprt the methds f cmpliance r a general statement regarding cmpliance; e.g. certificates f cmpliance, envirnmental plicy statements, certificates frm external audits, etc. A cmmn file type is the prtable dcument file, such as Adbe Acrbat. Machine readable dcuments are cmmnly used fr hard data, such as material cntent data. A cmmn frmat is extensible mark-up language (XML). XML allws fr machine readability, as well as ffers frmatting capabilities fr a human readable frmat. Fr materials declaratin data, it is recmmended t be in a machine readable frmat with capabilities fr human interactin; such as with XML. The IPC-175x material declaratin standard versin 1.x des have XML capabilities allwing fr machine readability f the underlying data within the Adbe Acrbat frm. Regardless f the type, all data shuld be stred in a nn-editable frmat. If this is nt pssible, the dcument shuld have the ability t track changes. Dwnladed/Printed frm

3 The Data System Levels f Data Strage Systems There are three basic levels f data strage systems: simple, intermediate, and cmplex. A simple system is like a file hierarchy within an perating system. This is a simple and ecnmical slutin fr many cmpanies. Cmpany level dcuments are kept in a flder, data specific t a bill f materials is kept in a flder, and an enhanced bill f materials spreadsheet has a link t all data in supprt f the cmpliance f the prduct. The spreadsheet als lists whether the part is fully cmpliant r cmpliant by exemptin, as in the case f meeting the EU s RHS Directive. This detail allws cmpanies t determine if the part is cmpliant with additinal laws such as China s Administratin n the Cntrl f pllutin Caused by Electrnics Infrmatin Prducts (China RHS) legislatin, which des nt include any exemptins. An intermediate system is cmmnly fund as an add-n mdule fr an existing inventry management system r prduct lifecycle management system. It gives the ability t run reprts manually t grup the data necessary t prve a prduct r prduct line is cmpliant. A cmplex system has fully-integrated checks and balances. It is an algrithm which checks the relatinships between data, exiting legislatin, prpsed legislatin, and human review sign-ffs that the data is legitimate. In sme cases, multiple algrithms are necessary fr maintaining checks and balances. Basic Functins and Capabilities Data systems have tw majr functins: strage and distributin. String the data depends n cmpany size. As the size f the cmpany increases, the data system typically increases. It will likely be assciated with a bill f materials structure r apprved vendr listing. Distributing r reprting usually ccurs at the request f an enfrcement agency and pertains t a given law r directive. Reprts shuld be available nt nly n a part basis, but als n a finished prduct basis. In additin t strage and distributin, a data system shuld include a gd search feature and cmpliance tracking capabilities. The system shuld have the ability t search data pints such as given levels f material cntent and special circumstances (e.g. exemptins fr EU RHS). A data system shuld have the ability t track cmpliance at the part level, sub-assembly level, and the cmpleted assembly level. It shuld als be able t track cmpliance with active and prpsed legislatin; including deviatins frm specific legislatins, as in the case f the EU s RHS Directive, which has exemptins which will change ver time. The system shuld als be expandable in rder t fllw a practive apprach t meet future requirements. Attachment strage capability is a must fr any data strage system wrking with ec-cmpliance data. Ging Frward: Determining Needs A data strage system is part f an verall cmpliance strategy. The fllwing questins can help a cmpany t find r design an apprpriate data system. Where is the cmpany within the supply chain? The answer t this questin will pint t hw accessible/searchable the data needs t be and hw is it rganized. Fr a cmpany within the supply chain, data will need t be easily accessed fr custmer requests. All pints in the supply chain will need the ability t search n specific materials, especially n cmpliant parts cvered by exemptins; particularly in the case f the EU s RHS Directive. Hw will the data be cllected? Will it be manual? This is smene sitting in frnt f a cmputer, r n the phne, requesting the infrmatin frm the supply chain. Semi-Autmated r fully-autmated requires manual input and review f basic infrmatin, but sme data exchange is dne autmatically between cmputers. A web site which takes a custmer s input f a part number and returns a certificate f cmpliance r a materials infrmatin sheet based n the part number input is an example f semi-autmated cllectin system. In fully autmated systems a data file is sent t a machine and a series f frms is autmatically created. Dwnladed/Printed frm

4 Is it pssible t track a part r cmpnent via exemptin r ther special circumstance? This is a must-have fr any data system fcused n envirnmental cmpliance and is specifically used fr tracing the level f restricted materials. As mre RHS-type legislatin is passed, requirements change, making the tracking prcess mre invlved. By allwing fr tracking based n special circumstances such as exemptins, a cmpany can immediately determine which parts are affected when the special circumstances change. Cnclusin A data strage system is part f an verall cmpliance strategy. Like many parts f a business strategy, it will evlve ver time. Having a system framewrk and an understanding f hw RHS-type legislatins arund the wrld are evlving will allw fr the creatin f a basic system which is als flexible. A part simply listed as cmpliant des nt give enugh infrmatin t make the determinatin that it truly cmplies with multiple laws. By using a data strage system capable f having specific fields fr restricted substances, as well as applicable exemptins, cmpliance data is mre easily accessible. This capability allws cmpanies t adjust prcedure, rather than start frm scratch, t prve cmpliance with a new law. By gathering materials beynd the RHS txic six, such as the materials listed in Annex A&B f the JIG, cmpanies are better prepared fr the next RHS-type law, regardless f the gverning bdy implementing such legislatin. A system capable f reprting the cmpliance status f individual parts, as well as sub-assemblies and final assemblies, makes the eventual reprt t an enfrcement agency less stressful and a mre prductive. In the design prcess, cmpanies use existing parts. By having full materials declaratin data n parts already used in existing designs, the ease f reprting use f restricted substances allws fr imprved utilizatin f resurces. With regulatins expanding int new territries, as well as the ptential f additinal substances being restricted, cmpanies have a cntinual, grwing need fr the ability t trace nt nly the current restricted materials, but als materials which have the future ptential fr being restricted. By fllwing the recmmendatins fr cllectin and strage f cmpliance data put frth in this paper, cmpanies can cntinue t practively apprach envirnmental cmpliance. Dwnladed/Printed frm

5 References Department f Trade and Industry nw mved t: Publicatin: DTI RHS Guidance Ntes Publicatin: DTI WEEE Guidance Ntes Eurpean Unin Cmmissin Publicatin: Enfrcement Guidance Dcument IPC-175x-series Standard / IPC 2-18 Cmmittee Published Standard Cmmittee Meeting Attendance Meeting Minutes Jint Industry Guide Materials Cmpsitin Declaratin fr Electrnic Prducts Annexes A and B (JIG-101 / JIG A&B) American Electrnics Assciatin (AeA) IPC Lead-Free Cnferences December 2005 Bstn, MA, USA March 2003 San Jse, CA, USA August 2006 Mntreal, QC, CANADA September-Octber 2006 Singapre, SINGAPORE Octber-Nvember 2006 Frankfurt, GERMANY, EU December 2006 Bstn, MA, USA SMTA RHS & Lead-Free Successful Strategies Cnference June 2007 Bxbrugh, MA, USA Envirnmental Cmpliance Attitudes twards Electrnics in Nrth America 2007 Btsfrd/Messina/Simmn Death, Taxes and Envirnmental cmpliance: things yu can cunt n trees LLC AeA E-Waste Rad Shw Chicag, IL, USA; April 23, 2007 Prtland, OR, USA; April 25, 2007 Bstn, MA, USA; April 27, 2007 Dwnladed/Printed frm