Resources & Services for REACH Compliance

One week ago, I had the delightful opportunity to interview Michael Kirschner, president of Design Chain Associates (DCA). His company, which was founded 11 years ago, focuses on helping companies around the world comply with environmental regulations like RoHS and REACH.

After talking with Michael for an hour and 20 minutes, I realized I had discovered a major source of knowledge concerning REACH education and implementation.

As I wrote in a previous article, I will be identifying services and resources that can help you understand and comply with REACH. Here is the first installment. Hopefully, it will convey some of the respect I have for Michael's business acumen and technical competencies, as well as how critically important it is for companies to be able to identify and tap resources to meet evolving regulatory standards.

Coming from a reliability and component engineering background, DCA has a deep knowledge of component failure mechanisms and materials used in semiconductor and packaging design.

In the 2007 book Exposed by Mark Schapiro, Michael is quoted discussing the impact of European environmental legislation: "This is an unstoppable force. This is not some flight of European fancy. It's not going away." Either you get rid of those chemicals, he said, or you give up selling to Europeans. Back in 2007, the high-tech industry was generating $500 billion of annual sales to Europe. This was a wakeup call to US manufacturers.

Michael helped organize the UC Berkeley Conference of 2005-2006 and invited Rob Donkers to participate. Rob served as deputy head and head of the chemicals unit in the Directorate General Environment in Brussels. His responsibilities included coordinating the development of a new EU chemicals policy and legislative framework (aka REACH). He was also the chief EU negotiator on the 2001 Stockholm Convention on Persistent Organic Pollutants.

As it started to address RoHS, DCA partnered with the well-known electronic component distributor TTI Inc. to provide Webinars educating TTI's customers and others about the REACH and RoHS programs. Michael also serves on the Green Ribbon Science Panel of experts who provide advice on scientific matters, chemical policy recommendations, and implementation strategies for the California Department of Toxic Substances Control.

DCA's services are targeted to "article" manufacturers. REACH identifies an article as an object given a special shape, surface, or design during production that determines its function to a greater degree than its chemical composition. Article manufacturers need to understand the environmental regulations and secure the training and education required to develop implementation strategies, which in turn require planning and execution. As with any program introduction or improvement, an understanding of where you are and where you want to go is essential. The actual term for this is "gap analysis." BusinessDictionary.com has a very good definition:

A technique for determining the steps to be taken in moving from a current state to a desired future-state. Also called need-gap analysis, needs analysis, and needs assessment.
Gap analysis consists of (1) listing of characteristic factors (such as attributes, competencies, performance levels) of the present situation ("what is"), (2) cross listing factors required to achieve the future objectives ("what should be"), and then (3) highlighting the gaps that exist and need to be filled.

Within a manufacturing organization, the folks responsible for RoHS are also responsible for REACH. But that individual or group could come from operations, quality, environmental, or any number of other departments inside the company. DCA's goal is to help people impacted by REACH understand how and why their individual jobs are involved. Michael listed a few such roles: marketing manager, design engineering, component engineering, test engineering, and manufacturing engineering. Just looking at this abbreviated list indicates that this is not a segregated issue.

I consider the scope of the education no less important or overreaching than quality assurance. Every product has a lifecycle, and companies need to incorporate compliant environmental practices into every stage of development and after-market concerns. In a 29-page paper that Michael wrote, "Manufacturing industry challenges and responses to EU, California, and other product-targeted environmental regulations," there is a matrix showing "EU Regulations vs. Lifecycle Phase impacted." This table presents a very concise understanding of when a company must institute environmental management disciplines into product planning and development.

The entire paper is well worth reading for anyone interested in this subject, and it makes a strong case for environmental programs within a company. A deep understanding of REACH and RoHS regulatory impact is a necessity for any "article" manufacturer to meet the EU's uncompromising requirements to do business in the member states.

China, India, Brazil, and many other countries are adopting EU-like legislation. If your company is doing business outside the United States (and even within it), it is in your best interest to learn about these environmental mandates as quickly as possible. It's also essential to identify the businesses and other resources that can help you navigate the maze, because few companies have the capabilities in-house to do this.