Do You Comply?

I imagine I’d go crazy if I were a manufacturer today. There are so many regulations to follow, and with the burgeoning environmental/green standards, which can differ per country, the complexity grows. Then, when I begin to think about the various substances that are regulated, like lead, hazardous chemicals, etc., coupled with the specific industry regulations, I start feeling like I need a Business Intelligence solution to understand it all. (Breathe now.) And then, I imagine how extra-complex it must be for OEMs and Tier 1 suppliers who are outsourcing their parts manufacturing around the globe, where depending on the country, the manufacturing cultures differ, and thus their awareness/compliance to the complex web of. . . directives.

Welcome to the second post in our introductory Green PLM blog series.

We can quickly get overwhelmed when we start digging into Compliance. When it comes to Green Compliance, we’re still in the early days, i.e. there’s a lot more to come. Most of the directives bubble up from Europe, and to my knowledge, so far there are no widespread, ISO-type standards.

Mike Zepp, our in-house regulatory compliance expert, used to deal directly with the type of scenario I imagined above, and now he helps Dassault Systèmes arm companies with tools to successfully navigate through the green compliance jungle. Mike was in Paris recently and kindly agreed to let me video-interview him. Here’s what Mike has to say about Compliance and the role PLM, particularly managing product-linked data throughout the lifecycle, can play to help. The real-life example he cites in the video is particularly telling:

It seems to me that using an efficient compliance assessment and impact analysis data management tool will help put some greenbacks into your Green PLM, or at least save you some. While this is only a piece of Green PLM, it’s a major one.

Stay tuned for my next Green PLM post on reducing material use in product design.



P.S. Here are some Green Compliance resources:

Examples of product recycling directives:
End-of-Life Vehicle (ELV)
Waste Electrical and Electronic Equipment Directive (WEEE)

Examples of banned substances directives:
Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH) Directive
Restriction of Hazardous Substances (RoHS)

The Voice of the Customer: Process Integration and Traceability Through Requirements Management

  • yeah, these regulations are not just hurting manufacturers from a ideological perspective. The Consumer Products Safety Commission (CPSC) has introduced legislation that will shut down many children product manufacturers because they will not be able to afford compliance testing for products. Some manufacturers are already pulling out of the US…

    There’s more here:

  • Josh,

    The small toymakers are raising a big stink about this now, and it’s expected that the regulations will either have a delayed implementation, or something will be done to allow them to keep going while they work out a component testing program or something similar that will greatly minimize or eliminate the impact on independents. I can’t imagine someone making organic toys in their Vermont workshop can really be expected to pay $4000 per toy design for testing.

  • It is a great example he gave, but it is not clear how PLM would have solved this problem… Play the case through, supplier needs to be replaced, procurement goes to action, procurement uses teh documents that they used to purchase from the last supplier… drawing and specifications. Why was this missed? Reguardless of having PLM or not having PLM procurements buys based on specifications. I doubt very much the buyer said to the new supplier just make me a few thousand of these or something like this… It would not matter if these were in PLM or microfilm (we all remeber that stuff, you know the first PLM tool), so there is more to the story, don’t you think?

  • Mike Zepp


    You are correct that a ‘simple’ PLM system documenting BoM’s, specifications, and drawings would not have by itself solved or prevented the problem stated in my example. However, a compliance enabled PLM system fully integrated into all of the business processes of the company would have had a strong potential for preventing the problem. Let me explain.

    If this company had been using a compliance enabled PLM solution where the corporate change management process (including supplier resourcing) is managed within the PLM solution, the supplier change would not have been approved for production start without having received & approved the material compliance declaration from the new supplier.

    In the case of the example quoted, the supplier change was approved “without” having received the material compliance declaration because the compliance quality processes had been ignored, overlooked, or misunderstood by the Buyer who sourced the new low cost supplier.

    A compliance enabled PLM system which controls the change management process could have forced the buyer to follow all of the required business process steps (inclucing material compliance) before approving the supplier to begin production of the newly sourced sub-component.

    I hope this helps answer your questions.

  • Mike Zepp

    Josh & Matt,

    You are correct that the required product testing within the new CPSC regulations for product safety of children’s products is an issue which will garner much more debate on the impact to small toy manufacturers. I expect to hear much more about this in the new year, especially once the new administration takes office.

    A similar debate is brewing around the mandatory product testing requirements for electronics manufacturers selling to the Chinese consumer market. Despite being a far future requirement (i.e., whenever China begins to publish their ‘Catalog’ of products that need to comply with their ‘China RoHS’ requirements), the debate began immediately over the fact that all testing was required to be done at a ‘Chinese Certified Lab’

    The one thing for certain in this area of environmental or material compliance is that it will continue to evolve & change. For this reason alone, if not for the many others, companies need a “compliance enabled PLM solution” which can help them track & manage all of the chemical substance content information across their global supply chain, their complex product designs, and their eco-system of customers & partners.