Conformity Magazine - December 2007 - (Page 22) requirement, but is relying on its recycling laws to drive manufacturing to a lead-free process. Another problem to be faced by manufacturers is the changing regulatory environment from country to country. For example, while medical equipment is presently exempted from the EU’s RoHS regulations, that is not the case in China. Also, substances which are not presently covered may find themselves on the hazardous materials list in the future. Closer to home, a majority of the states within the U.S. are also working on their versions of RoHS regulations. For example, California is preparing to adopt a subset of the EU’s statutes. As presently written, it will only cover TV displays larger than 40” and will not exclude PBB and PBDE (California’s requirements can be found in SB20/50 – the Electronic Waste Recycling Act of 2003, or EWRA). Enforcement Efforts The ability to ship non-compliant products to the global marketplace without incurring monetary penalties is rapidly shrinking. Companies shipping products with substances banned under the EU’s RoHS regulations after 1 July 2006 can face monetary fines or prosecution by the EU. The avoidance of financial penalties is not the only concern – the negative publicity which can be generated by RoHS-compliant competitors can significantly impact sales. As a further incentive to induce compliance, managers and CEOs must be aware that the possibility of prosecution may extend up the managerial ladder, should it be shown that failure to comply was due to neglect, or consent, of any manager. It is important to note that RoHS compliance extends past the producer’s manufacturing operations, and includes subunits in any system that ships to an EU location. Unfortunately, imposition of RoHS penalties is spotty at best, which tends to actually penalize those manufacturers that work to maintain compliance because of increased production costs when compared to the scofflaws. As yet, no policing authority has been emplaced to assure RoHS compliance, and even the much more mature CE testing is not strictly enforced. For example, non-conformance rates to CE testing in Germany is reportedly as high as 50%, and still exceeds 30% even in UK. Typically, non-compliant products are either unmarked or, if CE marked, do not possess the required backup documentation. The Burden on Manufacturers The imposition of regulations necessary to meeting the EU’s RoHS requirements can impose an almost onerous burden on manufacturing processes and quite probably increase product costs. But one of the benefits of RoHS compliance is that the produced units are safer to handle and create less health and environmental risk when disposed of at the end of their life cycle. For these underlying reasons of variability in “green” restrictions, a manufacturer must view RoHS compliance as a continuing effort, not a one-time occurrence. The effort required for companies to achieve RoHS certification can basically be divided into three major areas, as follows: production processing, incoming inspection, and the implementation of accurate database/recordkeeping procedures. To convert a company’s production processes to comply with RoHS requirements can take years of constant work by a dedicated committee. As RoHS compliance affects almost all areas of the manufacturing entity, it is necessary to include managers from the engineering department, the quality control department, the purchasing department, and the sales department. In other words, the effort must be an all-encompassing, organization-wide activity that is embraced by executives and managers in all of the participating areas. Further, the RoHS compliance committee must be chaired by an executive who is sufficiently senior within the organization to ensure that the recommendations and procedures will be carried out. One major challenge to converting to an RoHS-compliant facility (particularly if you are converting only a portion of your product line) is to adequately manage the inventory control function. The question arises both as to part identification of the end product as well as purchased parts and materials. (For example, is it necessary to change all part 22 Conformity DeCember 2007 http://www.amphenol-aerospace.com http://www.amphenol-aerospace.com/filtercatalogs http://www.amphenol-aerospace.com http://www.amphenolcanada.com
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