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Enlisting Support For Compliance

Recent surveys indicate that large numbers of businesses are still not taking EU environmental laws seriously. Though the percentage of companies not compliant is small at only 20%, that still works out to thousands of businesses at risk. Furthermore, the surveys show that engineers process oriented people are already aware of the issues, but they are not being supported by the rest of the organization. Management and procurement tend to have much lower awareness levels.

What to do? Start teaching.

The fact that you are reading this likely indicates that you are already well aware of the impacts of RoHS and WEEE upon your company. If you are also the lone voice in the wind about these laws then it is time to begin educating the rest of the organization.

Managers usually respond well to risk analysis. Paint a picture of the situation: new environmental laws are emerging from Europe and other nations; customers are concerned and are asking how we will comply with the laws; our market share is at risk. Follow up with a high-level risk analysis. Identify the issues, the associated risks and potential solutions. Include action choices such as 'do nothing,' 'focused compliance' or 'full compliance.' I wouldn't spend time trying to estimate the cost and time required to implement. At this stage there are too many variables and uncertainties. Be prepared to talk about resources, and acknowledge the need to provide estimates after the goals are established.

Issue Risk Action/Solution, Consequences
Product line 'Rhone' has no WEEE label Loss of sales in Germany. Distributors are refusing to accept shipments now.
  1. Cease shipments to Germany, lose all German sales
  2. Ask distributor to apply WEEE labels and ensure WEEE compliance program is completed by 13 July 06 (1 month margin).
  3. Apply WEEE labels at factory; delay shipments; ensure WEEE compliance program is completed by 13 July 06.
Product line 'Rhone' contains 3 substances banned by RoHS
  1. Loss of sales in Germany.
  2. Fines for non-compliance could equal product sales price
  1. Cease sales in Germany by 1 July 06
  2. Make 'Rhone' compliant before 1 July 06
  3. Make 'Rhone' compliant within one year; cease sales in Germany 1 July 06; resume sales when compliant product ready

One thing to avoid is fear tactics. Don't use the many horror stories available about how bad it will be if the business doesn't comply immediately. Compliance takes time. Making compliance the top priority of the entire company would place the whole business at risk unnecessarily. It makes more sense to take a well-reasoned, deliberate approach, even when the deadline is uncomfortably close.

A thorough risk analysis will capture management attention very effectively. Once you have their attention you can then explain that compliance is a team effort that must include several parts of the organization including engineering, procurement and quality. Compliance also creates marketing opportunities. Emphasize the synergy of a cross-functional team.

With initial support established, keep the interest alive with other sources of information. The next page of this article is aimed at managers. Email a link to the next page to supportive managers. The page includes links to several articles explaining the issues strategically. Help key managers setup RSS news feed readers on their computers and subscribe them to the RoHSwell.com news feeds. These were the first news feeds dedicated to RoHS-WEEE topics. With a little effort, you can get your own compliance program rolling in no time.

Part 2, Resources for managers

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