So, you have spent considerable effort on converting your products to RoHS compliant. But, you do not build your products. That is the responsibility of your Electronics Manufacturing Services (EMS) provider. For all of your efforts, your products, your sales, and your reputation are dependant on your EMS partner(s).
There are many places that an EMS partner can cause a RoHS non-compliance event that may result in a business interruption for your company.
How do you reduce your risk?
With the push for cost reduction in products and manufacturing processes, many EMS providers are applying leaner measures. Such measures often result in less foresight and less attention to potential issues.
If you do not ask explicitly for RoHS compliance assurance and verification, do not expect it to be completed.
What you need to ask
There is a wide range of questions you could be asking your providers. Questions related to reliability, supply chain, mechanical components, contamination, incoming inspection, surface mount, second-tier suppliers, and inventory management are a few areas to be considered.
But, what are the priority items to discuss?
There are five (5) critical questions to ask your EMS provider. These five questions are by no means an exhaustive list, but are items that should be discussed and will provide a starting point in reducing the risk of interruptions to your business.
Question 1: Will your Pb-free process meet my business needs?
One primary reason an EMS provider is your EMS provider is that he meets your manufacturing needs. Until now, this has generally been based on products using leaded solder. Just because an EMS provider produces acceptable leaded solder products does not mean he will produce acceptable Pb-free products.
The question above is a general question, but there are a number of specific areas of concern.
Recommended areas to investigate include: experience with Pb-free solder, range of board type and board layers processed, processes to prevent Pb contamination and process control, reliability, experience with new board technologies, and cost.
In particular, reliability is a concern; not just for tin whisker growth (which is often the first question in people’s minds), but for more standard reliability-related to a significant change in the process.
The risk of early life failure or related issues due to process inexperience have been seen to be a far more significant risk during the transition to Pb-free than the ignominious tin whisker problem.
Question 2: How are you managing your supply chain to ensure my supply chain business continuity?
When a product is converted to RoHS compliant, generally 50 to 70 percent of the internal components are replaced.
How is your EMS provider going to ensure new RoHS-compliant parts are the parts that are placed into the product? What is the EMS provider’s inventory policy? How does he handle parts that are only identified as RoHS compliant by the date of manufacture? What procedures has your EMS provider put in place for incoming inspection to ensure that the part requested is the part received?
These may seem like a lot of straight forward questions, but it only takes one part to make a product non-compliant.
Question 3: How are you managing my custom mechanical components and constituent materials?
Most electronics OEMs have focused their RoHS efforts on the catalog parts in their Bill of Materials. However, virtually all products found to be non-compliant by the EU enforcement agencies during RoHS compliance verification in 2007 were non-compliant due to mechanical components.
For many companies, a significant portion (by number of parts and by part size) of their mechanical components are custom designed and have constituent materials specified only in text on drawings.
How is your EMS partner ensuring that those written specifications (often identifying metal, finish, and plastic standards) are RoHS compliant?
A resistor with Pb on its leads buried deep inside the product is much harder to identify for RoHS non-compliance than the front face-plate of a telecomm product coated in Pb paint.
Question 4: How are you going to ensure the compliance of my screws, nuts, and bolts?
In many industries, the process for inventory control of screws is to fill up a bucket of screws when it gets too low. Screws and other fasteners are not normally RoHS compliant and provide significant opportunity for product non-compliance. In many cases, RoHS non-compliance of some screws can be spotted by the naked eye.
Review process inventory control of RoHS compliant fasteners with your EMS provider.
Question 5: If a non-compliant component does end up in my products, what’s the plan?
Even if you have an excellent RoHS program and your EMS provider has an excellent RoHS compliance process, all it takes is one component for a product to be non-compliant.
What is your EMS provider’s process if a non-compliant part is found on finished boards? …on finished products? …in a customer’s hands?
These questions are important questions to get out of the way early, both to have a resolution process in place with your EMS provider and, buy-in from executive management.
Regulatory compliance managers that get buy-in from their EMS provider plus their own executives before a non-compliance incident occurs generally fair better on both a corporate and professional level.
In the end, the risk of business interruption due to RoHS non-compliance is strongly tied to the RoHS proficiency of EMS partners. Product recalls and sales gaps are not often career-enhancing for the people involved.
As my grandfather once told me, ‘Trust everyone, but make sure you cut the cards.’
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