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Retooling for Compliance

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Dave Palmer
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Systems thinking
Dave Palmer   11/10/2011 11:11:58 AM
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It's good that these tools are out there.  As the article points out, though, it's even more important to train engineers to start thinking about products from a life cycle perspective in the first place.

A good engineering education should train us in systems thinking, so it's just another step to apply this to environmental sustainability.  If you have the mental tools to think about how a component fits into a subassembly and how a subassembly fits into a product, then you already have the mental tools to think about how a product (and the processes needed to manufacture it) fits into an ecosystem.  MIT has a course called Systems Perspectives on Industrial Ecology, available on OpenCourseWare, which I found very useful.  I would urge anyone who is interested in this topic to check it out.

As a matter of fact, there are many interesting engineering courses on OpenCourseWare, some with full video lectures.  This includes a course by Dr. Ken Russell, who used to write Design News' "Calamaties" column.  For those of us who didn't have the good fortune and/or financial resources to go to MIT, it's an incredible resource.

Beth Stackpole
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Re: Systems thinking
Beth Stackpole   11/10/2011 1:57:50 PM
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Thanks for the reference, Dave. I think approaching this from a systems thinking point of view makes a lot of sense. Not only does it give you that ecosystem perspective at a macro level, but also on a micro level, thinking about how parts are both assembled and disassembled when it comes to end of life.

williamlweaver
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Compliance for Compliance Sake
williamlweaver   11/13/2011 11:38:46 AM
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@Beth and @Dave, I don't wish to start a "Compliance is Evil" war, but I honestly do not know the purpose of the "dramatic changes" in compliance discussed in this article. I teach Systems Thinking to project managers and I am a devote of the Wharton School's late Russel Ackoff and this "Purposeful Systems". I would quickly support a massive regulatory push to document an industry that was producing dangerous products using environmentally-destructive processes. However, your article describes how Schneider Electric had 12 months to document 60,000 system components to remain in compliance with Restriction of Hazardous Substance (RoHS) regulations and avoid the loss of $600 Million in revenue. Schneider was able to "convert its entire product portfolio to meet its RoHS deadline and avoid any revenue loss.

This statement leads me to conclude that the entire supply chain involved with the $600 Million product line was not in any violation of the RoHS regulations. From a Systems Thinking perspective, what was the Purpose of the RoHS regulations? Did the authorities have reason to suspect that 80% of the products were Hazardous? 60%? 40%? 10%? 5%? If after compliance, 0% were found to be hazardous, of what purpose is the RoHS? What of the secondary Systemic consequences of less capital available for use on new research and product development? The building of new factories? The Discovery of New Business Opportunities and Customers?

I am all for Agile product and software development. But I'm leery of Agile Regulatory Development. Kudos to Schneider for developing an innovative electronic compliance system to address RoHS. One of the primary tenets of Systems Thinking is an awareness of the Change of Game. What is an appropriate level of effort to be consumed by regulatory affairs? After electronic compliance systems are adopted industry-wide, what are the next challenges in compliance to be met?


Rob Spiegel
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Re: Compliance for Compliance Sake
Rob Spiegel   11/15/2011 2:58:44 PM
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Hi williamlweaver,

The electronics industry did quite a good job of complying with RoHS. for one thing, the industry had a multi-year jump on the problem. Big suppliers like TI was fully in compliance years before the rules took affect. Major distributors such as Avnet, Arrow and Newark were able to quickly guarantee they could fill customer BOMs with compliant parts. It became a competitive issue among suppliers. That took a lot of the pain out of RoHS for the OEMs.

Ann R. Thryft
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Re: Compliance for Compliance Sake
Ann R. Thryft   11/16/2011 12:55:36 PM
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Your right about the chip makers, Rob. Unfortunately, the head start on compliance with ROHS didn't extend to some of the high-end embedded board makers, such as those producing single-board computers. There compliance and even understanding the details of the regulations, were all over the map. It took a couple of years for that part of the industry to sort things out.

 

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