REACH, RoHS, EOL, PCN Resources & Services, Part 1

Last week I interviewed Cliff Frescura of EEContent.com. Cliff and his team have contributed to the success of leading companies such as IHS, PCNAlert, i2 Technologies, and TACTech. Among other things, they provide product change and obsolescence management expertise to top OEMs, electronic manufacturing services (EMS) providers, and component manufacturers.

Now, the company has added to the mix of critical change alerts the European Union's Registration Evaluation and Authorization of Chemicals (REACH) and RoHS (Restriction of Hazardous Substances). The EEContent document retrieval and archival services will help high-tech companies and members of their supply chain assure compliance with these environmental laws.

Cliff began his career with a computer science degree and for several years was a hardware design engineer, but various projects he worked on steered him more toward business applications and forced him to change his emphasis from hardware to software engineering. This put him on a path of writing programs for barcoding, supply chain tracking, inventory management, forecasting, distribution center controls, and SKU tools management. In 2001, Cliff joined PCNAlert as director of solutions and worked his way up through the ranks to become CEO. In 2007, Cliff sold the company to HIS.

I asked Cliff to tell me more about EEContent.com and how and when he decided to become involved with REACH subscriber-based, email push notification alerts. He told me that he had foreseen the demand for an email alert service that would act much like PCNAlert but would be enhanced with REACH and RoHS notifications.

The critical differentiators between EEContent.com and rival services were subscription costs and target markets. Cliff said he saw that the other services were targeted more toward enterprise-level businesses that could afford higher pricing. EEContent.com has been designed to be affordable, even for a single-user in a small-to-medium sized company. When asked how he could offer the same services that the large companies need and still manage with the lower cost, he said that his company uses a lot of back-end automation for document retrieval and that most of the other services require heavy, hands-on, manual efforts and a larger support staff. He also said that EEContent.com's REACH data retrieval software incorporates new subcategories into its database.

Here's how it works: as a subscriber, for $2000 per year, your company can enroll in an online and email alert push notification program that will take your uploaded Excel bill of materials (BOM), map the manufacturer's name, part number, and your internal part numbers in the process of preparing a "cleansed" spreadsheet for a BOM "scrub." The software will identify all misspelled manufacturer names and correct them on the cleansed spreadsheet. This means that, if you may have one row on your spreadsheet that references "NatSemi" and another row that reads "National Semi," EEContent.com's mapping will recognize that and map both into "National Semiconductor."

The software actually learns over time and will make the automatic corrections on future BOM uploads. When you click on the "scrub" button (tied to a specific BOM), the spreadsheet is examined and returned in just seconds with additional columns showing the various PDF document types available for each BOM item for immediate download.

The document "type" column includes PCN, EOL, REACH, or RoHS, along with an additional column providing the internal EEContent tagged document number hotlinked to the relevant PDF. For REACH data returns, the substance of very high concern (SVHC) number shows the number of chemicals to which the document refers. For example, SVHC-53 indicates 53 prohibited chemicals, while SVHC-73 refers to the most recent list with a chemical count of 73.

Every time a manufacturer publishes a new REACH compliance document, the return would show the most recent compliance list. It is important to note that REACH documents are generally "blanket" in nature and not part-specific. Occasionally, a REACH document might read that all parts made by "ABC Manufacturing" are compliant except for a certain category of parts or product lines. However, the end-of-life (EOL) and PCN (product change notification) alerts are specifically matched to both the customer's internal part numbers and manufacturer's part numbers. The email alerts come daily via email and list any new documents that are pertinent to any of your previously uploaded BOMs. In this manner, you never have to be concerned about missing an EOL or PCN notice again.

The system allows you to upload as many BOMs as you like, and all the uploaded spreadsheets will remain in permanent archive until you delete them. The same BOM number with different revisions can be simultaneously maintained and scrubbed. By selecting filters for your email notifications, you may elect just to receive REACH documents or EOL alerts and exclude other notification types. Your BOMs are automatically reviewed for newly-released documents every night, 365 days of every year your subscription remains active.

I also asked Cliff what he considered the biggest hurdle in working with the various manufacturers of products requiring REACH compliance. He said all service providers have the same problem; they cannot control when a manufacturer will release the REACH documents, and so subscribers waiting for the documents have to sit tight until the company publishes the compliance notifications. EEContent.com has established a "signup for notification service" with key manufacturers. This means as soon as the manufacturer has published the document, EEContnet.com is notified and relevant documents are retrieved and made available to all subscribers.

EEContent also provides publishing tools to help the manufacturers get their notifications out at the same time the company releases the documents internally. As soon as a manufacturer's document is received at EEContent, it is electronically scanned and new key words are added to the search index. At the same time, the document is parsed into the correct alert type category, and EEContent's search engine, SEEC (SearchEEContent), is updated. The search engine will search on any key word, including part numbers, chemicals, CAS number, etc.

In the event that there are no current REACH documents on file, Cliff encourages the subscriber to contact the company and it will, at no charge, research the part's manufacturer and retrieve any documents not yet posted. This is, of course, only possible if the manufacturer has REACH compliance documents available. If not, the subscriber will be notified of that instance, so additional measures may be initiated in order to achieve compliance. In some cases, a new manufacturer that is REACH-conscious may have to be selected for any given part.

Two more services are worthy of note. First, on its daily alerts, EEContent.com provides company genealogies noting acquisitions, mergers, and divestitures that will help reassign your approved vendors list (AVL) manufacturers and part numbers to the latest manufacturer of ownership for the parts on your AVL. The second service is the ability to upload private content relevant to the BOMs on file. These could include schematics, application notes, email history, PCB layout artwork, or anything else that would help centralize the data that you may want to share with specific people via a cloud-like network. Everything uploaded is absolutely secure and requires a password for access.

With the comprehensive online and push email alert service that EEContent.com provides, your company can have the confidence and assurance that time-critical component alerts covering environmental regulations, availability concerns, and part changes will be managed and updated in the most efficient and timely manner.