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Moving Compliance Upstream
Rather than dealing with compliance directives after the fact, smart companies are retooling to make compliance a consideration at the onset of design
Beth Stackpole, Contributing Editor -- Design News, December 10, 2007
Like any startup in the electronics space, Control4 was on a mission to get product to market as soon as possible. The company, which manufactures home automation systems, pushed its engineers to innovate new product designs and then worried about whether they’d pass any number of compliance directives only after they hit the market. But with safety and environmental compliance regulations on the rise, Control4 knew it needed to institute some major changes over the long term to make compliance a consideration far earlier in the design process.
Under the stewardship of Director of Engineering Harold Sullivan, Control4, over the last couple of years, embarked on a strategy of putting new disciplines in place to make compliance a priority at the onset of product inception. The company also brought in Arena PLM software to serve as a central platform for tracking changes and modifications to the products in the pipeline, including validation and tracking of a number of compliance directives such as those around environment and safety. The idea, Sullivan says, was to eliminate all of the manual and inefficient processes for dealing with compliance, which in the end, ended up impeding Control4’s ability to launch products in any kind of timely fashion.
“If you wait to deal with compliance at the end and try to duct tape a solution, it’s never elegant, never efficient and it ends up being very costly,” Sullivan says. “Everything you were trying to accomplish initially — which is to get a product out the door on the cheap and fast — ends up being for naught because you get caught up in an expensive cycle of respin, test and respin.”
Control4 is on to something many companies are just starting to recognize. With the July 2006 deadline for major environmental compliance initiatives like the European Union's Restriction of Hazardous Substances (RoHS) and Waste from Electrical and Electronic Equipment (WEEE) come and gone, forward-thinking companies are rethinking their engineering and product development processes to incorporate compliance requirements into the early design phase rather than chase after compliance in reactive mode. Moving compliance efforts upstream in the design cycle should help companies avoid any miscues that could lead to high-profile product recalls along the lines of what toy maker Mattel faced earlier this year when it found lead in toys produced by some of its Chinese suppliers. In addition, a design for compliance strategy, akin to any other design objective such as design for cost or design for quality, will ensure any changes made to a product structure because of a particular compliance directive are identified and handled early on when it is less costly and resource intensive.
“We need to have compliance requirements elevated to the same status as market requirements or functional requirements,” says a spokesman for Siemens PLM Solutions. “If you’re taking compliance into account in the early phases, you might be leaving out something that is essential to what the product ultimately will have to do.”
Consider Mattel and the child’s toy example. “If an engineering group is designing a child’s toy, they know this toy needs to be safe, it needs to be fireproof and it needs to be fun,” the Siemens PLM spokesman says. “They also need to know up front that it needs to be environmentally compliant and not have any lead because that fact will impact the decisions they make about the types of materials and components that go into their design as well as their choice of suppliers.”
While most companies will acknowledge the importance of designing for compliance, putting a working strategy in place is a whole other story. Engineering organizations have to reorient their work practices to fully support such a strategy, from figuring out exactly what compliance directives impact their product offerings to creating a culture that orients individuals to making the information-gathering work a key part of their job. Bringing in systems like PLM platforms, which serve as a central database for all product-related materials, is one way to help a development team fully embrace the practice by allowing engineers to easily tag and search for compliant materials.
“Engineers always design for whatever requirement is defined — that’s not new,” says Mike Burkett, vice president, PLM at AMR Research Inc. “So if compliance is well defined, they’ll design to it. The challenge, then, is to define what those compliance requirements are up front — that is the difference between designing for compliance versus being reactionary.”
Proactive Solutions
Being reactionary is exactly how most companies are still attacking the compliance problem. Engineering or the procurement organization — or sometimes both — collect material specs and data sheets from suppliers, maintaining old-fashioned paper-based records or spreadsheets that indicate the parts and materials composition of a product with a notation about whether or not particular components meet the various compliance standards. Sometimes the information is shared across development teams, but more often it’s not. That means engineers working on other products that use similar parts have to replicate the data collection effort, which is labor intensive, time consuming and frequently, error prone.
Control4 initially handled compliance in much that manner, according to Sullivan. Some of the validation data was stored in spreadsheets, some was tucked away in people’s heads and without the proper business processes in place, there was a lot of repetitive work. To rectify the situation, Sullivan’s group went in and with help from outside consultants, educated the departments, including engineering and procurement, in the intricacies of the relevant compliance directives along with their potential impact. Arena PLM was also deployed in February 2007 to serve as the central repository for all compliance-related information and for tracking changes and modifications to products to ensure they met the standards. “We’re using Arena to track and ID critical components — it’s a single repository where we can go and review a (bill of materials) … and monitor the progress of what we’re doing in terms of whether products are meeting the standard,” Sullivan says.
Prior to the new strategy, engineering teams could be left without any way to easily track down the proper information. For example, when Sullivan’s predecessor left the company, no one there knew anything about how to generate the product labels that were required by one of the compliance directives. “It held us up from getting product out the door,” he says. “It took two months to figure out what the proper labels were and how to generate them. That wouldn’t happen again because all of that information we had to recreate then is now archived and very well documented in Arena.”
Arena isn’t the only PLM platform to build out compliance capabilities. PTC, Dassault Systemes, Siemens PLM Software and Oracle Corp. have all, over the last few years, added compliance modules to their offerings as part of their pitch to position PLM as the primary platform for addressing compliance. PLM, rather than Enterprise Resource Planning (ERP) or CAD systems, are the most likely candidates to serve as a system of record, vendors in that space claim, because it’s the tool set that engineers are most likely to access during the critical, early stages of design. “To the best of my knowledge, there’s not another system that allows you to effectively store such a complex collection of information,” says Mark Holman, Arena’s senior vice president of operations and strategic development. “There’s no place to store this in a CAD or EDA system. It’s theoretically possible in ERP, but there’s not an engineer on the planet that uses an ERP system when they’re designing product.”
It’s Not My Job
As difficult as it might be to leverage a system like PLM as part of a compliance initiative, the technical challenge pales in comparison to the process change that’s required for a successful design for compliance strategy. Getting engineers who never thought much about compliance to consider it as seriously as any other design objective takes education and a concerted effort by top management to position compliance as a company priority, according to Chad Hawkinson, PTC’s vice president of product strategy, electronics industry. “Engineers need to know that their boss is measuring them based on compliance, that the company really cares about it and that customers care about it as well,” Hawkinson says.
Companies with a healthy requirements management culture are the best candidates for succeeding at design for compliance, says Vasco Drecun, PLM research director at Collaborative Product Development Associates (CPDA). These companies, which nurture communications and up-front evaluation of a design, tend to be more open to considering compliance as just another requirement and are more likely to have formal processes in place. “A lot of companies believe they’re better off by jumping into design right away before clarifying all their assumptions and they’re not process-centric in development,” Drecun says. “That causes engineering to start with assumptions and then rework. A better spectrum is to incorporate compliance constraints as just another early requirement.”
It’s likely that engineers will balk at much of this process change, claiming it limits their design freedom and creativity or that compliance information gathering is outside the scope of their responsibilities. Narragansett Imaging, a manufacturer of imaging subsystems for medical, defense and machine vision applications, experienced that firsthand when it embarked on a series of changes to promote compliance along with parts reuse. First up was implementing Arena PLM, including its Compliance Module. The next was to get engineers accustomed to researching and collecting materials to prove out compliance as part of their design work.
Today, any time Narragansett engineers create a new part within Arena, they are required to attach all evidence collected on compliance and make annotations if there are any kind of exemptions. New business processes are also in place that call for engineering to completely review a BOM for RoHS compliance prior to transferring it to manufacturing. “At first it was painful for them, but now they’ve been working with it for over a year so it’s become part of the way they select components,” says Doug Sherman, vice president of engineering for Narragansett Imaging. It’s also incentive to reuse components, Sherman says, because then they can avoid going through that process.
For QLogic, a maker of high-performance networking solutions, getting engineers to consider compliance requirements as a serious design objective had everything to do with top management involvement. After the Mattel recall, compliance caught the eye of executives who became concerned about their own liability. With the quality management group as the sponsor, QLogic added the Compliance Module to its Agile PLM system, now part of Oracle, and began to task engineers with considering compliance requirements as part of early design objectives. “At first they balked — they didn’t think it was their role,” says Iqbal Rana, a business systems analyst and senior principal at QLogic. “But when it comes from the top, engineers will do it. Now with highly visible cases like Mattel, everyone knows compliance is important.”
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Moving Compliance Upstream
Rather than dealing with compliance directives after the fact, smart companies are retooling to make compliance a consideration at the onset of design
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