If your company is an electronics-product company, a contract manufacturer, or a component supplier, you likely feel relieved to have met the requirements of the Restriction of Hazardous Substances Directive. Our research one year ago, commissioned by the Consumer Electronics Association, concluded that the estimated total cost to the industry of RoHS compliance was approximately US$32 billion–1.1% of industry revenue (from Economic Impact of the European Union RoHS Directive on the Electronics Industry, January 2008).

And if you are one of our clients, you have a good sense of what you are doing for the EuP Directive and REACH Regulation, and also have progressed on your beyond-compliance business strategies. You are applying Lean and Green not only in your products’ bills of materials but also in overall product design, facilities, logistics, and more.

But do you know if there’s a leak in your roof? Are you prepared—today—to provide objective evidence to demonstrate RoHS compliance within 28 days of being asked? Do your internal-process auditors know what questions to ask about RoHS, and what answers are acceptable? If your products are currently exempt from the lead-in-solder restriction, do you have plans in place for a lifting of the exemption?

These are the questions that my colleagues Mike Kirschner and Ken Stanvick have asked, and their audit tool—tested by TFI clients—is a good response.

For the RoHS Directive, a producer shall (at the request of the UK enforcement authority) submit within 28 days of the date of the request technical documents or other information showing that equipment placed on the market comply. Due Diligence simply means that you have systems and procedures in place that work, and that you can prove it. Finally, if you have developed a program of checks, it must work. Having a system in place that nobody follows is as bad as having no system at all. This is something that demands periodic or even constant monitoring. In creating a system you must consider all aspects of your business, from the design stage through after sales. Identify the risks, adopt appropriate controls and safeguards, record your actions, and keep it under review.

Don’t forget the element of surprise: Last year a client told us, “If I announced to our Asian contract manufacturer that I was flying over for a RoHS audit, I know they would ‘pass.’ But what would I find if I just showed up?”

With the EuP Directive’s provision that Member States must provide a means for other interested parties (even competitors!) to submit observations on non-compliance of products, we know that having tight processes applies not only to RoHS.

What have you done to check if your “roof” is leaking? What are your favorite auditing tips?

Posted by Pamela J. Gordon, December 18th, 2008

Filed to Environment

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