Stanley H. Salot  |  10/03/2008

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Bio

Achieving Green Compliance

Analyzing process-based vs. test-based manufacturing.

IECQ QC 080000: The Standard for Lean-Green Compliance

Although not all manufacturers around the world understand the value proposition of a lean-green, process-based manufacturing program, there are more than 1,250 that do--those that are registered to the IECQ QC 080000 standard.

IECQ hazardous substance process management (HSPM) has proven to be an efficient, effective, and financially prudent way for manufacturers to demonstrate international compliance with hazardous- substance-free components, products, and related material requirements and legislation.

Adding a lean-green, process-based manufacturing program enhances this concept and adds even greater value.

When properly implemented, QC 08000 certification provides its management and stakeholders:

Evidence of due diligence as required by:

--EU RoHS directive, WEEE directive, battery directive, packaging directive, end-of-life vehicle directive

-- China RoHS MII No. 39

-- Korea RoHS

-- Japan RoHS

Demonstration of a company’s commitment to social responsibility through:

--Customer Green Product specifications

--OEM’s commitment to green products

--Contribution to the reduction of hazardous waste

--Reduction of carbon footprint

Communications throughout the organization through:

--Executive-management-established HSPM policy and objectives

--Social responsibility training of all personnel in the organization

--Ensuring technical competence specifically related to HSPM

--Technical review of customer contracts to ensure understanding and compliance to HSF/green specification

--An established early-warning communications system should an error occur anywhere in the product life cycle

A design and maintenance-vigilant system that includes:

--Hazardous substance (HS) or hazardous-substance-free (HSF) reviews required throughout initial design activities

--HS/HSF reviews required throughout repair and maintenance activities

--A system that continuously monitors directives, regulations, legislation, customer, and OEM specifications on a worldwide basis

Annual surveillance by a third party with:

--Management commitment to a third-party registration assessment

--Management commitment to an annual third-party surveillance assessment program

Internationally accredited third-party system to ensure competence and compliance that specifies that:

--All third-party certification bodies are internationally accredited for their technical competence.

--All third-party certification bodies undergo annual accreditation surveillance reviews.

--All third-party certificates are registered and displayed on the IECQ web site for easy access with no access fee.

 

For many of us, a debate regarding lean-green, process-based manufacturing vs. testing-based manufacturing as a means to achieve green compliance is a “no brainer.” For some reason, however, many executive-level managers are unaware of what lean-green, process-based manufacturing management professionals already know: Lean and green are a good combination. Together they can save your company money, save your customers money, and help you demonstrate your commitment to good global environmental stewardship.

Somewhere along the way, Corporate America received a series of misleading messages from legal teams and industry associations related to the European Union’s directives on the recycling of electrical and electronic product waste (WEEE) and the restriction of hazardous substances (RoHS). The message was simply, “If you fail to meet these requirements, the penalties will be high.” According to EU member state representatives, fines of up to 15 million Euros could be imposed, and senior management representatives could receive prison sentences of up to 10 years. The message was clearly given to ensure that executive managers paid attention.

Is the message getting through?

As I visit companies throughout the United States, attend Import Safety Summit meetings in Washington D.C., and participate in U.S. and international technical committee meetings, I continue to be amazed by the processes that U.S. executive managers support and implement and the level of company resources committed to these processes. After years of spending time and money to learn and implement lean process management systems (LPMS), they continue to adopt hazardous-substance-free, green manufacturing programs based on testing methodologies that were proven inefficient, ineffective, and very costly more than four decades ago. What happened to the lessons that we learned about process management and lean manufacturing?

At a time when everything around us is changing minute by minute, our manufacturing environments cannot afford to revert back to the old ways and days. Testing to ensure compliance with emerging environmental management standards is not the answer. Although I admit that some testing is required, it should be done on the basis of validating that lean-green manufacturing processes are under control. Testing should not be used to determine whether every toy train, cell phone, GPS, iPod, laptop computer, hair dryer, toaster, curling iron, and talking teddy bear is compliant with hazardous substance and recycling management requirements.

Senior managers seem to be taking their direction from folks that have not learned the value of process management or simply do not believe in it. By direction of some of the smartest technical minds in industry, the amount of time and money that Corporate America is pouring into technology to manage hazardous-substance testing and data collection and reporting is staggering. We are talking about millions and millions of dollars. I have repeatedly seen companies respond to lengthy hazardous-substance content questionnaires from customers. Most of these questionnaires have 50 to more than 100 questions. Whole departments staffed by environmental engineers and supply chain assessors have been created just to handle these customer inquiries. This has been done in large part because lawyers have told managers that if their companies fail to properly control the hazardous-substance content of their products, they could be fined and imprisoned. With this degree of justification, it really is not hard to see how middle management could easily get executive management to sign up to supporting a high degree of product testing. With corporate lawyers indicating that these new requirements can be referred to as “Be a Manager; Go to Jail,” it isn’t hard to understand why even the chief financial officers grin and bear the cost with little to no serious challenge.

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About The Author

Stanley H. Salot, Jr., is founder, president, and CEO of Business and Quality Process Management LLC. He is an acknowledged expert in business and quality process management and is active in U.S. and international industry standards development bodies. He serves as president of the Electronic Component Certification Corporation, the U.S. representative of the International Electrotechnical Commission Quality Assessment System for Electronic Components (IECQ). Salot co-authored the international standard QC 080000 for hazardous substance process management for the electronic/electrical component industries.

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