A fellow WEEE/RoHS Warrior writes the following note and asks readers to share their thoughts and experiences.
Dear Dr. Ron,
After now having worked for a fairly large OEM for a couple of months, I am seeing some very frustrating happenings with respect towards environmental compliance. First off, some inescapable facts:
- My company is at the forefront of environmental compliance
- The world is rapidly moving towards environmentally friendly products and services
- Reporting requirements will only become more extensive.
Having said that, I was under the impression that industry would be gearing towards these inevitable changes and get in front of this. I am frustrated, exhausted and very sorry to say, the truth is more that industry is lagging sorely behind this. What I am seeing are increasingly more material analysis requests from end-sellers (as well as WEEE contract/consulting firms) going way beyond the six banned RoHS substances; more into the realm of Green and REACH requirements. We are barely able to provide RoHS/WEEE information let alone the additional substances required by the other areas. In the mean time, Certificates of Compliance are flowing (with virtually no basis, proof or substantiation mind you) like wine at a Roman orgy. The general procedure is, when in doubt, issue a certificate. For heaven's sake, don't disrupt the flow of product from one place to another. Just fill out the form, slap on a sticker and we are legal to sell.
With the lightening fast pace of new product introductions and end-of-life& the speed of new technology, the acquisition of new companies and mergers (making it very hard to assimilate BOMs in existing databases), coupled with the inability and challenges to measure materials at the homogeneous level, it is no wonder that compliance is very difficult to prove, maintain and keep on top of. In my humble opinion, we need to stop, catch our breath, asses our challenges/issues/concerns with RoHS/WEEE, implement corrective actions then apply what we have learned to Green Procurement, REACH and all other pending environmental compliance programs for the future.
Thank you and best regards,
Environmental Compliance Engineer