Good post, Rob, and it raises a lot of issues. I'm actually reporting a story as we speak on some of the tools used to help facilitate compliance initiatives and most of the engineers/experts I'm talking to are echoing Ken's sentiments that the administrative burden of environmental compliance should not fall on the design engineer's plate. Rather, it should be the domain of an operations person or if that resource is lacking, be outsourced to a specialized consulting firm. The argument: That tracking down the increasingly complex details and paperwork that goes with this is a distraction for design engineers and takes them away from their core competency--designing good products. I'll be curious to hear others wade in.
I agree that compliance of this nature should be delegated as a special function especially given the scope of design compliance engineers are already dealing with. Each of the companies I have worked for (small to medium size), however, see the engineer as best qualified to find the right information and interpret those requirements as applicable to the company and its products. Given the cost of an engineer and the common view of them as overhead, you can see why a company would be resistant to assigning a full time, high dollar person to a very part time effort. Oddly enough, those same companies are also resistant to outsourcing this type of work.
Yes, it does seem to be turning into a specialized function. For most of my time at my previous employer (an OEM) it was the engineer's responsibility to know and meet the various international regulations. In some cases, we did have some help by requiring the company's subsidiary in the region to supply the necessary details. However, as this became more and more complex we ended up with a senior engineer who job was dedicated to global codes and standards and was the go-to-guy for all changes of that nature.
The last paragraph said it all.. big firms - specialized support is provide. Everyone else - engineer is responsible.
My concern: making strategic decisions based on (assumptions of ) salaries of employees... Can you assume the specialized support is always cheaper than the "high paid" engineer? (cost of regulatory mistakes?)
When making these decisions a company should used a balanced perspective. Otherwise you end up with bean counters running the company. Which creates bad situations ( example: decisions base on tax incentives not business needs).
Anyone want to see the actuarial table on risks on using specialized support vs engineer? Does anyone have such a document? based on the performance of the people in your organization? are the people in your organization typical/atypical of your industry?.... answers are not easy and are hard to judge fairly.
@Thinking_J - The related question is to what extent are these specialized support third-parties involved. Do they do a once-over at the beginning of the project and say you need to include certain thing, or are they involved at all steps including design finalization to make sure that all the requirements are properly met? Then, there's also the legal concern - if something is found not to meet the requirements at some point down the road, who is ultimately (i.e., financially) responsible?
To isolate and pick on environmental compliance as a responsibility of the Design Engineer in this context is to not see the forest for the trees. There are also engineering specialists for EMC, safety, quality, reliability, PCB layout and design, component selection, and so on. Manufacturers may have some, all, or none of these supporting functions in-house. All are necessary to produce a marketable electronic product.
Either you make the design engineer responsible for all this - resulting in their becoming the jack of all trades and master of none, which no design engineer I've ever met wants to, or can, be - or you assign the task where it makes sense.
And Jack Rupert, I've seen the extent of involvement extend from an afterthought once the product's gone out the door to deep pre-design involvement and everything in between. Best Practice, in my experience and opinion, is for extensive pre-design and early design involvement, with checkpoints throughout the product development project defined in a Product Lifecycle process (e.g. Design Review 1, Design Review 2, BOM Review, etc.). Structurally all these service areas have to be incorporated in to the lifecycle process in order to ensure as few surprises as possible during the product development and manufacturing processes (which result in redesign and therefore wasted time).It's all about the process.
Your question about liability is a good one - whenever you use a 3rd party you have to agree on the extent and limits of liability of both parties before you get started. If the process is solid, this isn't a concern (but should be documented anyway).
Good question, Jack, especially the part about liability. The liability can be stiff. Ten years ago, Sony had more than a million of Playstations ejected by The Netherlands for cadmium in the cables. That was just before the holiday season.
These service companies do more than just say this part is good and this part isn't. They can also manage the voluminous documentation involved. And they can tell the difference between RoHS regs in Europe, Korea, China and India.
The large component distributors can also lend a hand. They can go through a customer's BOM and compile the necessary documentation.
I agree that adherence to environmental regulation is a specialized function, but a lot of companies have the mind set that the engineer is paid to know all possible outcomes of the product including disposal. This can be an unfair mindset when multiple countries are involved and working through the regulations can be more work than actually satisfying the customer's needs.
With all of the regulations out there I just don't understand how anyone can expect a design engineer to keep up to date on the latest regulations for so many different regulatory commitees and regulations. At some of the larger companies they can afford to have one person that tracks this information and then passes the info onto the team. In other cases there is an opportunity for external resources to be used in order to stay up to date.
My experience is that it takes a village to handle all the new requirements. For us, design engineers perform a cursory and sometimes more detailed component/materials review. The project manager also reviews compliance and finally we rely heavily on our Contract Manufacturers to source compliant components and communicate issues. Of course, this can lead to other challenges such as compliant parts being in high demand and become long lead items which kicks back to the engineer to find an accessible alternate.
My solution is one that may not work for everybody, but it works for our products quite well. I include a statement that our product is worth repairing and worth ceclaining, and that it should never be discarded. We will pay for return shipping if a customer ever chooses to discard the product. Of course, this only makes sense if the product is worth reclaiming, which ours is.
So far, after ten years, no customers have chosen to dispose of the product, although several have proven that it can be damaged by electrical or mechanical abuse. I have learned that while it is possible to build a product that will stand up to the rigors of heavy and constant use, it is a lot more expensive to build one that will stand up to every form of abuse. ( This second paragraph is quite off topic.)
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