What I learned this week …serves as a cautionary tale for people responsible for product compliance – PLM can help, but compliance requires a multi-pronged approachthat includes strong data gathering, analysis, and docuumentation capabilities (this is where PLM comes in) but also intelligent supply chain relationships and physical validation. 
This reminder came to me courtesy of AP Enterprise: US buyers must beware in China. The article is a good read, although I had some issues about their dig on 3rd party testing. Their point is you have to know what you are looking for in order to test for it – isn’t that what RoHS, REACH, the SIN list, and countless other lists of substances of concern are all about? Otherwise, some excellent points and examples.
What PLM Can Do
As my previous post discussed, PLM solutions help by Making Product Compliance Sustainable. In other words, PLM helps companies achieve product compliance without excessive compliance cost. Developing products that meet REACH, RoHS, and other compliance challenges requires manufacturers to:
- Identify Requirements
- Document Product Structures / BOMs
- Gather and Validate Component Data from the Supply Chain
- Analyze Products and Perform What If Analysis
- Mitigate Risk
- Document Compliance and Achieve Auditability
Most PLM solutions can play a significant role in documenting products and BOMs. Other, more capable PLM systems have added features to help companies collect and analyze compliance information in the context of the product design and product lifecyle. Clearly, PLM is a major benefit for compliance.
What PLM Can’t Do
What PLM can’t do is ensure that the data is accurate. As the example in the AP article shows, there are unscrupulous suppliers who are polluting supply chains with improperly identified, toxic materials. No enterprise solution alone can prevent this. Reducing exposure to these problems requires:
- Knowledgeable supply chain personnel
- Validation
PLM can still help in these regards, but it is not the primary tool. For example, PLM can be used to document physical tests in the context of the product record and analyze data for inconsistencies and potential inaccuracies. Some PLM systems also manage supplier records that can be used to document vendor audits and other supply-chain validation functions. But in the end, compliance can’t be based on blind faith in PLM data.
Implications for Manufacturers
PLM is a big part of the answer to reduce product compliance risk. Manufacturers can also leverage compliance information to reduce product and component supply risk. But in the end, having the right data is only part of the challenge. Virtual validation such as documentation and BOM analysis must be accompanied by scanning and/or destructive testing to be sure. Testing should be risk-based, but should also continue throughout the product lifecycle and supplier relationship.
So manufacturers will have to keep on guard, and not just in China. I hope you found it interesting. Let us know what this looks like from your perspective.