February 20, 2006
RoHS and WEEE - EMA Design Automation
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Jack Horgan - Contributing Editor

by Jack Horgan - Contributing Editor
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How do you fit in with RoHS and WEEE?

Our niche if you will in this new area is on the RoHS side. We are simply trying to give engineers the ability to define what we call compliancy by design by giving them content in their schematic with OrCAD so that when they pick a part, it is compliant. I think that part of the problem in the market place is most people are looking at RoHS as a manufacturing problem and WEEE as being so far downstream they don't care anymore. But we've taken the position that if you have the content that's compliant from the beginning of your design cycle, you now have the certification data for the RoHS ands WEEE.

What's the fundamental issue with RoHS facing manufacturers or designers?

We asked a customer just a few months ago how big his RoHS problem was. He told us that it was a $300 million problem to him because after July 1 he can not ship to Europe. The $300 million figure is the firm's annual revenue from Europe. That's the problem they face. If you are not compliant, you can be put out of business. What we have found is that most companies in the US have their head in the sand over this issue. They hope it will go away or they think that the EU is going to change its mind. That's not going to happen. The train has left the station and people have to become compliant.

If I am a manufacturer of an electronic consumer product like a DVD player, what is my responsibility with regard to RoHS if I am just assembling components from suppliers?

If you are doing component level design and manufacturing, you are responsible down to the resistor level to make sure that the part is compliant. If you are doing the assembly simply buying modules and bolting them all together, if your label is going on that end product, then you are still liable for that end product whether or not your individual suppliers are compliant.

We are involved in analysis at numerous companies where we are looking at the OEm's product but they have asked us to go to their suppliers and look at the subassemblies.

If I am getting a product from a supplier, am I responsible for testing that product's RoHS compliance or are there third party testing firms or do I rely on a compliancy statements from my suppliers?

All of the above will work. It's just a matter of risk mitigation, If you are satisfied that your supplier gives you a certificate of compliance and your legal department is willing to take that and defend that in front of the EU courts, then that could be suitable. But if you suspect that your supplier is saying that they are compliant when they are not, the liability is still on your firm for the product going to Europe. We had this case recently where a company told us that he is not worried about it because he has a Chinese contract manufacturer who is going to verify compliance. If anybody is going to be betting their company on that type of scenario, I would say that they do so
at high risk.

What do you advise your clients to do in terms of getting comfortable that their suppliers are in fact compliant?

What we are doing for our customers is going through their AVL (Approved Vendor List). We are scrubbing that list. We are getting that list compliant down to the component level. Not only do they have a RoHS yes or no, they have all the material data behind it. So when they print out the declaration statement for the EU that source data is right. They have it during the engineering phase and all the way to manufacturing and shipping. Basically we instantiate as much compliancy data in the original component level design data base as possible. That's where you mitigate the risk, early in the design cycle.

What type of data is necessary?

Things like the actual amount of lead by engineering units and how much Cadmium there is.

So on behalf of your client, you go to the firms on their AVL and gather all the information.

Exactly right. We literally have a large team of component engineers that are going line by line through the AVLs to validate and verify information.

Do you offer a service where you have a data base with all the collected information or do you do this on a client by client basis?

We are doing it primarily on a client by client basis because AVLs are customer specific. They are also intellectual property that companies keep very close to their chests for NDA purposes. We look at manufacturers' part numbers, we call the manufacture for the data, and we populate the data base. Because of this massive data collection issue, we have created an entity we call the Engineering Data Management (EDM). This essentially enables an engineering director to manage all of his compliant data in one data base without having to mess around with the big enterprise systems. So within EDM he can manage his compliant information in the work in progress kind of things where you are
re-designing and re-spinning boards. Once it is ready to go off to PLM, the data is all put together as a BOM and moved off to the manufacturing. We sell the tools OrCAD Capture and CIS Allegro but we've developed the methodology called EDM to manage this data.

Does the designer sitting in front of an OrCAD or Allegro screen only have access to elements that are RoHS compliant or does he have the option to choose?

It really depends upon the customer. For most customers we have made their AVL RoHS compliant. That's the optimum mode. So that engineers can not even design something with a leaded part. Some companies maintain inventory and know that they still have X amount of these leaded things. These items might become a suitable substitute for a lead free part to be used for prototypes. OrCAD also allows the customer to look at their data base, their design data and instantly know whether the design has any leaded parts in it or not.

Can you go backwards? Can you take an old design and map it against this data base and get a RoHS pass or fail?

Absolutely! In fact we have done that for numerous customers. It literally makes their jaws drop. Because their AVL is pristine when they look at their old designs, the bad stuff jumps right out at them. They know exactly what to change and what has to be redesigned.

Under these circumstances, do they typically find the changes to achieve compliance to be considerable?

It's hard to say that there is a certain number. We've seen 80% success rates and less of course. We've seen some situations where it is a straight suitable substitute to a lead free part. We've seen numerous situations where the leaded part is obsolete and there is no suitable substitute. It runs the gambit of problems out there.

The suitable substitute routine we do is especially applicable in the case of obsolete parts. Part obsolescence is in essence somewhat of a bigger problem than the RoHS issue. So many chip makers are obsolescing leaded parts right now that not only are these parts obsolete but their life expectancy is measured in months instead of years. So when a designer uses one of these parts that is available today, there is so much demand for those parts that not only could that part be obsolete but it may not even be available in the marketplace.

People say that they have an exemption, e.g. military and medical are exempt until 2010 time frame. What happens is that if the leaded parts go obsolete, they can't make their product anyway. We are engaged with several medical companies specifically that are way ahead of the curve because they clearly understand part obsolescence problem. By the way solving that problem solves the RoHS problem at the same time.

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-- Jack Horgan, EDACafe.com Contributing Editor.


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