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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.

8 comments on “REACH, RoHS, EOL, PCN Resources & Services, Part 1

  1. Barbara Jorgensen
    March 8, 2012

    I can't think of a better service than information consolidated in one place, and data that comes to me when I need it. Great find!

  2. dalexander
    March 8, 2012

    Barbara,

    You are so gracious. Thank you for the encouraging words. It is my intention to provide practicle help and cosolidate resource referrals in this series by including details that would help the readers pick and choose the best fit for their company needs.

  3. Brian775137
    March 9, 2012

    Douglas: 

    It looks as if you have discovered a gold mine.  I fully agree with Barbara; this would be extremely valuable to anyone who is planning to sell to those countries where REACH will be and is being implemented. 

    However I feel that there is a BIG question which needs to be answered or clarified.  You mentioned, in your article, that the cost for Cliff's service was to be $2K, but it was not clear to me if the $2K was per BOM uploaded or for any and all BOMs used by a company.  Also, I am presumiing that the $2K fee for the subscription is an annual fee, but this was not clarified in your blog.

    If it is $2K per BOM, this is a real bargain, considering everything that it provides for the subscriber, but if it is for any and all BOMs used by a company, then it becomes an outstanding service.  It could save huge amounts of time, effort and money, and severely lessen the possibility that a chemical listed in REACH might be overlooked, thus reducing amounts of fines or lost sales due the oversight.  Being in one place, as Barbara stated, is also a huge benefit to any company.

    The fact that the names of the manufacturrs are standardized automatically, is also a excellent item as it would serve to assure that there is only one company name used, reducing any ambiguity.

    I wonder if Cliff has considered the size of his storage capacity may have to become, if he is going to securely store multiple BOMs for all of his customers, not to mention the maintenance of such a huge database.  I'd love to own some stock in the company which is going to be providing it.

    Also, is a company who is producing a propriatary item going to want to upload his BOM into someone else's database?  Security for the customer's BOMs is always a major concern, especially if the BOM being stored is a part of a classified program.  Then, the Government would also be involved, and we all know how costs would escalate if this were to happen.

    Despite the few monkey wrenches I have thrown into the mix, I believe that Cliff has come up with a very valuable tool which can be of great service to the supply chain of any company.  Once these thoughts/questions have been laid to rest, we now have a single site from which we will be able to obtain all the current information we will need for REACH compliance, thus saving lots of money, and all the other things included become a “yummy” gravy for the meat.

  4. JennaK
    March 9, 2012

    @Brian75137

    There are several companies out there that have been doing this for some time now.  Going forward, security and space, I think, will be lesser issues compared with the methods of data collection and cost to the manufacturer.  Cloud based software such as this is very well suited to BOM management as it allows for seamless integration across a product team and real time updating of parts data from the data collection service. (Arena Solutions are you out there?) 

    Gathering material content information is a tedious process.  As the regulations pick up more steam, and they surely will, it will be a question of who has a current system in place that can stay ahead of reporting standards and frequently update their data while assuring it is free of errors, all at a responsable cost to manufacturers.

  5. Brian775137
    March 9, 2012

    @JennaK:  I couldn't agree with you more.  I was just trying to point out that the problem is more complicated that it first appears.  Thank you very much for your response – we need to keep track of this and personally, I welcome comments on the subject from everyone, even though I don't own the topic. Regards, Brian

  6. dalexander
    March 9, 2012

    Brian,

    The $2K is a yearly subscription fee and it covers as many BOM uploads and archival storage files as you need. This does seem very inexpensive and I am glad you asked for a confirmation. Cliff was with the original alert service called PCNAlert and has the necessary experience to manage a large customer base. Nothing speaks like experience. Anyone who wants to try the service can go to EEContent.com and give it a spin for free. I did that before writing the article. The results are almost instantaneous…2-3 seconds after I hit scrub BOM. There were some blank REACH cells and when I asked about them, Cliff said either the manufacturer hasn't published any documents or they may not be concerned with REACH issues yet. Then he volunteered to do the research on the missing cells at no charge. He said that he doesn't charge for the extra research, because it is to his company's benefit to identify missing manufacturer's documents so when he retrieved the new documents, if available, they would be added to his service and would be available to everyone. If the documents turn out to not be available after his efforts, it is probably a good idea to find a manufacturer who is REACH conscious and up-to-date. The earlier the REACH search is performed in the design, the more guidance a Design Engineer, Component Engineer, or Purchasing Agent will have to find compliant substitutes. I would run the BOM before a prototype was even built.

  7. dalexander
    March 9, 2012

    JennaK,

    I know Arena software from my days as a consultant to DANGER before MS bought them out. BOM.com was the name under which Arena marketed its service. You are right about the convenience of the cloud for archive, sharing, and services. As you mentioned to Brian about the other services available, I am familiar with several and we should be looking at all of them to provide the best referral service. Soon you will see an article on REACHDelivery and another on Total Parts PLus, one of the most comprehensive services available online.

    DCA's, Michael Kirschner sent out a bulletin recently saying there are another 13 more SVHC candidates under investigation now. One chemical is used in a huge number of passive SMT components. If that compound goes onto the REACH SVHC list, then the US is going to have to scramble to be compliant even faster because these SMT passive components are used on every SMT circuit design today.  You talk about your quinessential kick in the pants. This one compound will do the deed.

  8. FLYINGSCOT
    March 12, 2012

    This seems liek a good systems for helping companies with the various hurdles of compliance.  Our company tried a similar system a while back and those involved seemed to think it was a useful addition.

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