Business News

Management of RoHS compliance within Bookham

The controlled transition to sufficiently reach RoHS compliance is a complex undertaking involving the entire supply chain. By operating a fast-scan process to identify risks early, backed up by a later in-depth certification process, Bookham has succeeded in making the transition to full RoHS compliance without writing off any significant inventory. Alan Hughes, Kevin Prowse, Karen Whicker, Nick Watt, Reiner Breu of Bookham discuss the process used to effect the transition to RoHS compliance and the system designed to assure ongoing conformance.

Directive 2002/95/EC of the European Parliament of 27th January 2003 on the Restriction of the use of certain Hazardous Substances (RoHS) in electrical and electronic equipments came into force on 13th of February 2003. This directive prohibits the use of heavy metals (lead, mercury, cadmium, hexavalent chromium) and two brominated compounds (PBB and PBDE) in all applicable electrical and electronic equipment placed on the market within the EU. The directive is applicable throughout the EU from 1st July 2006, and similar legislation is planned in many other parts of the world.

Bookham maintains an ISO14001 Environmental approval, and has an active policy of removing hazardous and polluting materials from its manufacturing process and its products. The new legislation was identified by the environmental quality team, which is accountable for ensuring the company’s business compliance to environmental legislation; RoHS compliance is now an integral part of the company’s environmental policies and procedures.

Initial approach to achieving RoHS compliance
The RoHS initiative in Bookham started late in 2004 with the establishment of a Steering Committee and multi-functional working groups. The magnitude of the task of achieving compliance over many thousands of product codes and many thousands of components from hundreds of suppliers was extremely daunting.

Given the size of the task and the need for rapid action, the company’s first step was to poll its key suppliers with questionnaires to identify any non-compliant material as quickly as possible. It rapidly became apparent that the company’s supply chain was faced with similar problems in dealing with any infeed materials: initial responses were slow and a significant amount of time and resource was needed to gather the information.

As soon as any component was identified as non-compliant, it was placed on a “black list” and further purchase of these components was blocked via the Materials Resource Planning (MRP) system. Where RoHS compliant alternatives were available from our Approved Vendors, purchasing was simply redirected to the compliant parts. Where such alternatives were not available, an additional layer of approval was introduced to allow the purchase of only a minimum quantity of the noncompliant parts to satisfy immediate customer orders prior to the transition to full compliance.

Having made the transition to compliant alternatives, where they were already available, Bookham was left with only 90-100 “black-listed” components where the company needed to work with its suppliers and customers to achieve compliance. In the majority of cases this required only minor changes to the material content to achieve compliance – for example, removal of non-compliant flame-retardants in strain-relief “boots” on fibres and removal of Cr-based plating to metals. In spite of the fact that many of these 90-100 components were generic parts used widely across the company’s product range in many thousand products delivered to hundreds of customers, none of these changes had any adverse impact to our product manufacturability.

Inventory management and product codechanges
During the transition period it was recognised that Bookham needed to manage both non-compliant and compliant piece-parts, and clear inventory management was critical to being able to demonstrate RoHS compliance. In order to achieve this, Bookham introduced a policy of separate part numbers for compliant and non-compliant parts for both piece-parts and finished goods. The final product code was changed to designate RoHS compliance only when the complete Bill of Materials was fully compliant. The process to manage this phase-over is illustrated in Fig 1. This phase-over approach allowed Bookham to consume any remaining non-compliant material without incurring high costs of scrap.

Throughout the phase-over process, Bookham’s customers also needed to understand the company’s ability to supply them with RoHS compliant parts and the management process to effect this transition. In the majority of cases, the policy of changing part number to track compliance was entirely in line with customers’ requirement to track inventory through their own factories. Such changes in product codes clearly had an impact on their purchasing groups, and in most cases required complementary changes in their purchasing process.

There have been some instances where the customer had no need to achieve RoHS compliance for their end-product, and saw no benefit of changing their Bill of Materials to accommodate our RoHS compliant product code changes. In this event we have adopted a policy of providing the RoHS compliant product build standard under the original non-compliant product code, but have determined that these parts will not be certified as RoHS compliant. We are able to do this having ensured that all of our RoHS compliant products are fully backward-compatible with the previous build standard. This has the further advantage that we are able to continue to offer spares as required under the original product codes as recognised by the customer, but without having to maintain obsolete non-compliant inventory to do this.

Having identified any product changes at an early stage, Bookham was able to communicate this to its customers and issue Product Change Notification in good time ahead of its contractual obligations and six months in advance of the legislation coming into force.

An additional complication in the EU exemptions list is the designation of “Lead in Solder” as exempt for Telecoms Infrastructure applications only. This is widely referred to as “5/6” compliance. In order to identify where this applicationspecific exemption has been applied, Bookham has designated its final product codes with a “J” (5/6 compliant) or an “R” (6/6 compliant).

Management of compliance
The initial survey, by questionnaire, of the Bookham supply-base provided the first feedback for early identification of noncompliant materials. This was rapidly followed up with a rigorous Certificate of Conformance process and, again, many of the company’s suppliers needed significant management to complete this process successfully. In cases where there was any uncertainty from either the supplier’s side or from Bookham, additional material analysis was conducted. A formal Analysis Decision Tree process was introduced to identify where material analysis was required.

In order to warrant product compliance Bookham needed to update its product configuration database implementation (Agile) to track and control RoHS compliance and provide traceability for all purchased materials within product Bill of Materials structures, including electronic copies of all suppliers’ Certificates of Conformance. New reports were created within the database to easily generate Technical Files showing Bill of Material breakdown with confirmation of RoHS compliance by manufacturer and line item. A Due Diligence process was introduced to audit and assess Technical File content. The product configuration database in Agile acts as the master controller which then drives the Bill of Materials held within the ERP system (SAP in our case) controlling customer order fulfilment and MRP, and the FMS system controlling product build.

Ongoing assurance of RoHS compliance
All New Product Introduction within Bookham now requires demonstration of RoHS compliance at an early stage in the design cycle, with the intent that no new product is introduced into production without first being fully RoHS compliant. Management of suppliers and infeed materials going forward includes supplier assessment, certification requirements and random testing of material where appropriate to underwrite the information provided by the suppliers and provide ongoing assurance of compliance. Bookham’s policies, procedures and documentary evidence for RoHS compliance is audited by independent external auditors as part of the company’s ISO9001 and 14001 assurances. RoHS compliance was specifically audited in April 2006 and the BSi auditors found no areas of concern and no further actions were required.

Having started its RoHS compliance program in earnest at the beginning of 2005, Bookham was able to offer volume shipments of fully compliant product from 1st April 2006 – after some 15 months of hard work with suppliers and in updating many thousands of materials codes on internal systems.