The restricted substances have traditionally found extensive usage in Industrial control switches because they impart strength, reliability and durability. These are crucial properties as the switches often operate in harsh conditions such as in boilers, etc. They are expected to have a long life and operate accurately and reliably. These restrictions have therefore been challenging to the switch industry.

While the industry has taken commendable initiatives for RoHS compliance, the efforts have neither been easy nor entirely successful thus far. This is not to detract from the sincere efforts that have been attempted. The main problem has been the availability of RoHS compliant components and parts. The majority of electronic parts available today contain at least one of the restricted substances: Pigments contain cadmium, mercury is present in infrared detectors, PBBs and PBDEs in plastics used as flame retardants, lead in solder joints and inhibited paints contain Hex-Cr. (chromium is passivated by oxygen, forming a thin protective oxide surface layer which prevents oxidation of the underlying metal. Common oxidation states are +6 i.e hexavalent chromium and +3 (i.e trivalent chromium).

A number of products have been developed to replace the banned substances. However, long term reliability, an important parameter for the switch industry, is yet to be established. Examples of such alternates are Hex-Cr, replacements such as trivalent chromium, molybdates etc. These are, however, substrate specific; in other words they require a particular type of under-coating to be applied for proper adhesion and protection, which Hex-Cr does not need. This leads to extra costs, in addition to being less flexible operationally. Similarly, lead-free solders based on tin-copper-silver alloys have been developed to replace the traditional tin-copper solder. However, concerns related to durability and reliability still remain. Lead free solders also require a higher reflow temperature. This often entails expensive process changes and retooling.

Achieving RoHS compliance is, to say the least, an arduous task for any company. This is equally true for the switch industry. The difficulties are essentially due to the requirement to meet the maximum allowable limits of the restricted substances on a homogeneous material basis. This requires the entire material flow, starting from raw material and component vendors, to the end product stage be tracked. Also included in compliance standards are consumables like labels, glue, paint etc which can sometimes introduce the undesirable substances into the end product.

An added complication for many control switch manufacturers is that clients include the military and /or aerospace sector. There is no RoHS in aerospace and products with applications that can be considered exclusively "aerospace" need not be RoHS compliant. However this poses more problems in maintaining inventory control of RoHS compliant and non-compliant products for the switch supplier.

While achieving full RoHS compliance is the ultimate goal of the industrial control switch manufacturing industry, managing the transition is the biggest current challenge.

OSHA inspectors, called compliance and safety officers, carry out these inspections/audits. These may be carried out due to accidents, fatalities, situations of imminent danger, complaints and referrals or as a follow-up investigation. An OSHA audit can be a tedious and stressful experience for employers since the agency is empowered to impose penalties on those who are in violation of the standards. This is particularly true for small businesses that may not have the wherewithal to be in full OSHA compliance.

Generally, an employer who takes proactive action (and the associated pains) to try and adhere to mandated requirements will fare much better during such OSHA inspections. A little known fact for many employers is that compliance officers normally research the history of a worksite before an inspection. Therefore it pays to work with the inspectors and answer questions fully and honestly, rather than adopt stalling tactics. Actions like insisting on an inspection warrant, to buy time, can turn out to be counterproductive in the end.

Every workplace is unique; no universal formula can be prescribed for negotiating an OSHA audit unscathed. However, attention to some basic details can help immensely:

First, having an effective safety and health program which lays down the policies, procedures and practices for protection against occupational safety and health hazards helps to develop the proper mindset. Depending upon the type industry and the complexity of operations, these programs may even include a Processes Safety Management (PSM) program mandated by the 29 CFR 1910.119 OSHA Standards. A written program should be communicated to all employees.

Second, coaching employees on health and safety, including OSHA compliant training, should be routine. Proper training is necessary to insure that workers understand potential hazards as well as practice safe working methods.

Third, it is important for companies to stress employee participation in safe practices. Active employee involvement can greatly enhance compliance to OSHA standards.

Fourth, it is imperative that businesses have a written hazard communication program. This is particularly important in industries handling hazardous chemicals. The complexity of the program will obviously depend upon the specific needs of the worksite. It may range from a simple collation of information from Material Safety Data Sheets (MSDS), to a comprehensive OSHA mandated program in line with the 29 CFR 1910.1200 Standard.

Fifth, periodic self inspections and compliance audits will help to identify violations and allow corrective action to be taken. Earlier cases of accidents or injuries, if any, can also be analyzed for possible preventive measures. This will minimize the likelihood of being cited for violations during OSHA audits.

Record keeping is one of the most important tools for providing proof of a company’s efforts to comply with an OSHA inspector. The scope of documentation is wide and the more accurately records are maintained; the better it is for audits. Examples of relevant documentation would be accident reports, injury and illness reports, exposure records (hazmat exposure, noise exposure, etc where applicable), past inspections and action-taken reports, as well as employee training records.

All these steps will lessen the stress of an OSHA inspection and reduce the odds of receiving citations and penalties. As an OSHA fact sheet states, "OSHA’s primary goal is correcting hazards and maintaining compliance, rather than issuing citations or collecting penalties."

There are several categories of electronic waste or e-waste that fall under the WEEE Directive: large and small household appliances as well as consumer products are included. E-waste in this directive means electrical and electronic equipment (EEE) designed for use with voltage ratings of up to 1000V ac or 1500V dc. Hence manufacturers of most electronic consumer goods used in day to day life, fall under the purview of the directive. Since the consequences of non-compliance are serious (including possible ban on doing business in EU countries), manufacturers need to be conversant with the WEEE and the related RoHS directives.

The WEEE Directive seeks to minimize the environmental impact of e-waste by mandating its collection, treatment, recovery and/or recycling should be facilitated and financed by producers. It also proposes that consumers be able to return their waste equipment free of charge. Manufacturers, therefore, need to assess the impact of these requirements and initiate appropriate action for implementation.

This involves setting up collection centers for e-waste, arrangements for transportation to the recovery and/or recycling centers, facilities for recycling and determination of final disposal options. Recovery and recycling of electronic waste is specialized work and recycling plants must conform to certain minimum standards.

Operation of captive recycling facilities may be both uneconomical and beyond the core competence of equipment manufacturers. Hence suitable tie-ups with external recycling establishments may need to be entered into by manufacturers, either singly or through collective arrangements. The foregoing are post-sales activities.

It is very important for a manufacturer to also understand the importance of certain pre-sales actions which impinge upon compliance significantly. These are actions at the design and manufacturing stages.

First is the effort to design equipment which can be dismantled into the smallest possible parts and components. This will facilitate recovery of the parts for reuse; a more economical proposition than say, recycling.

Second, manufacturers must ensure labeling of products is in line with the requirements of the WEEE Directive including a "Do Not Landfill" note.

Third, reduction of hazardous material content in the product greatly reduces the need for expensive recovery efforts. It also contributes to overall environmental conservation. For this reason, the importance of RoHS compliance of products and processes cannot be over emphasized. The sooner manufacturers recognize this fact; the better their profits will be long term.

The WEEE 2002/96/EC Directive is not a law and individual EU member states are to incorporate its provisions into their own legislations. Since differences in the laws across the EU member states are inevitable, multi-national manufacturers may need to develop innovative compliance solutions.

Further, the WEEE Directive is based on Article 175 of the EC (European Community) Treaty - the Treaty establishing the European Union. This allows member states to include additional products as long as they countries adhere to European Community laws governing overall trade and commerce within and beyond the EU. Manufacturers must stay abreast of more environmentally sound practices and current WEEE changes. They also need to be aware of the implication of such changes on their businesses.

The problems arise chiefly from the requirement to meet the prescribed threshold limits on a "homogeneous material" basis. A European Commission document of December 2003 states that "Homogeneous material means a unit that cannot be mechanically disjointed into single materials". An example would be the ceramic material used in a capacitor. In this case the limits would apply to the ceramic material (and all other similarly homogeneous materials) and not to the capacitor as a whole.

To insure compliance, data on concentrations of the hazardous substances, needs to be transferred throughout the supply chain and across the manufacturing process. This would also include process materials like paints, glues, labels, etc.

A supplier who extends a guarantee that his product is RoHS compliant takes on, by implication, potential liabilities attributable to his component and material vendors. This is feasible only if adequate end to end tracking and documentation systems are in place for all materials and processes - a difficult task indeed, even in the US, for companies dealing with the EU.

One of the difficulties faced is that the RoHS directive does not specify compliance procedures, certificates or testing methods. The differences in the regulations of individual member states also introduce an element of uncertainty. These challenges are further compounded by the inadequacy of many current test methods to demonstrate RoHS compliance. In addition to this, there are the multiple data requirements of suppliers, as well as their ability to manage these huge amounts of information.

RoHS guidelines suggest that for compliance, producers should have a compliance assurance system (CAS). This would have material declarations and component analysis as elements, among other things. One system which facilitates information exchange between manufacturers and suppliers is the IPC-175X Standard and includes process and material declarations and their requirements. The standard can be used to support compliance activities at different levels of sophistication, denoted as "classes". These RoHS classes range from Class 1 (simple yes/no information at homogeneous material level) to Class 6 (which combines the Class 5 ’full disclosure’ level with manufacturing information). The Intervening Class 4 is a sort of compromise solution combining Class 3 level information (which includes JIG A & B homogeneous material level information) and manufacturing information.

The class system appears to provide a feasible way forward to achieving RoHS compliance. However, the hard work is in achieving the RoHS class compliance itself. Every supplier needs to implement the IPC 175X standard or equivalent. This necessarily comprises establishing end to end monitoring and documentation systems. Quick fix solutions will not be sufficient for success.

Available data from the US Bureau of Labor Statistics (BLS) highlights the fact that non-fatal workplace injuries and illnesses have been progressively reduced from 5.3 to 4.6 cases/ 100 equivalent full time workers, during the period 2002 to 2005. Stringent regulations for workplace safety and the dedication of agencies enforcing the same have made this remarkable feat a reality.

The Occupational Safety and Health Administration (OSHA), an agency under the Department of Labor, has the primary responsibility of developing and enforcing worker and workplace related health and safety regulations. OSHA promotes workplace safety through a variety of ways, including the 29 CFR 1910.119 PSM standard and the 29 CFR 1910.120 HAZWOPER standard. The essentials of the OSHA Workplace Injury and Illness Prevention Program emanate from the provisions of these standards.

All employers are required to implement and maintain (a) a workplace Injury and Illness Prevention Program (IIPP), (b) an OSHA mandated Hazard Communication Program (as per 29 CFR 1910.1200), (c) an Emergency Action Plan (EAP) in accordance with provisions of 29 CFR 1910.38 and (d) a Fire Protection Plan.

The EAP, orientated towards disaster management, and the IIPP, designed for minimizing incidents, are not mutually exclusive. The two programs complement each other and have certain common requirements. An example of this is the recommended use of Material Safety Data Sheets (MSDS) to identify potential hazards that may arise from the different types of chemicals in use at the workplace. The 1910.119 PSM standard mandates the use of MSDS, meeting the requirements of 29 CFR 1910.1200, section (g).

An IIPP is a mechanism for reviewing and eliminating/reducing potential hazards in the workplace. An effective IIPP can not only protect workers but also benefit employers by reducing lost man-days and workers’ compensation costs.

The workplace Injury and Illness Prevention Program (IIPP) can be conveniently discussed in terms of the California-OSHA adopted IIPP. Applicable categories of employers in California are required by law, Title 8 (T8), of the California Code of Regulations (CCR) to have an effective, documented Injury and Illness Prevention Program.

The Cal-OSHA mandated IIPP essentially has seven basic components. These are: (1) identification of program implementing personnel, (2) a written outline of the company’s system of evaluating and combating safety and health hazards, (3) a schedule of periodic inspections, (4) investigation procedures for workplace injuries and illnesses, (5) a description of employee training program(s) on safe work practices and specific job-related safety information, (6) a system for communicating with employees on occupational health and safety matters and for enforcing safe working practices, and (7) a retention policy for record documentation compliance.

Records and reports (29 CFR 1904) are integral and important parts of any effective OSHA workplace Injury and Illness Prevention Program. Records help to identify causes of incidents and develop future strategies for improving workplace safety. Records typically include work-related accidents, fatalities, injuries and illnesses, incidents of exposure to toxic or hazardous materials, Material Safety Data Sheets, health and safety related training imparted to employees, inspections, audits and other statutory records required for worker’s compensation, insurance etc.

The OSHA workplace Injury and Illness Prevention program, admittedly, imposes meticulous requirements on employers. However the benefits that an effective IIPP can provide far outweigh its inconveniences.

The WEEE Directive provides guidelines for the collection, treatment, recycling and recovery of waste electrical and electronic equipment. The "polluter pays" principle means collection and recovery is largely at the manufacturer’s expense. Specified products include such things as large and small household appliances, IT and telecommunications equipment, consumer equipment, IT and telecommunications equipment.

Reduction of hazardous material content in products at the manufacturing stage will reduce the content of such pollutants in electronic waste. This will enhance the economic feasibility of recycling. Hence RoHS compliance, which in any case is needed for doing business in the EU, is the first important element for any effective recycling. Increased efforts to design products that facilitate recycling of WEEE components and materials are extremely beneficial.

Recycling is one of several waste disposal options. Its effectiveness depends, to a large extent on the type of material to be recycled and the availability of appropriate technology. E-waste such as a computer can be discarded by the original users, but it may still be perfectly functional equipment. In this case material recovery and reuse is a better alternative than recycling. In fact the reuse of waste electrical and electronic equipment is the preferred economic option.

Recycling is technology and material specific. It is mandatory to collect electronic waste separately from municipal waste. While primary administrative responsibility lies with the state, manufacturers have an important role in educating customers on proper waste disposal. The WEEE directive mandates collection of electronic waste at the manufacturer’s cost. Manufacturers must not only ensure that convenient collection points are set up for consumers but must also make provisions for the transportation of the waste materials to the recycling plant.

The WEEE directive mandates that recycling sites should conform to certain minimum standards to prevent adverse environmental impact when treating waste EEE. In most cases, it will not be feasible for a single manufacturer to operate its own recycling center.

Throughout the WEEE recovery chain, producers are required to finance the cost of e-waste collection from consumers; transportation to the recycling center; treatment; recovery and disposal. Producers will generally need to collaborate with other manufacturers to collectively bear the cost for the recycling and waste disposal obligations.

The WEEE and the RoHS are here to stay and further strengthening of environmental regulations is inevitable. One such step is the impending Registration, Evaluation and Authorization of Chemicals (REACH), regulations effective from June 1, 2007 in the European Union. The REACH regulation will control the use of a very wide range of chemicals and is not limited only to the electronics sector. In this increasingly difficult milieu, a proactive approach by producers to comply with the WEEE electronic recycling directive will surely give them dividends for increased competitiveness.

OSHA is charged with the regulation of hazardous chemicals, to ensure safety in the workplace. Hazardous materials are regulated via the Process Safety Management (PSM) 29 CFR 1910.119 standard. The agency also regulates hazardous waste clean-up operations as well as emergencies arising from hazmat related incidents through OSHA regulation 29 CFR 1910.120.

This Hazardous Waste Operations and Emergency Response Standard, known in short as HAZWOPER, became effective on March 6, 1990. The HAZWOPER 1910.120 standard encompasses:

* Clean-up operations required by a governmental body, conducted at uncontrolled hazardous waste sites
* Corrective actions involving clean-up operations at sites covered by the Resource Conservation and Recovery Act of 1976 (RCRA)
* Voluntary clean-up operations at sites recognized by the government as uncontrolled hazardous waste sites
* Operations involving hazardous wastes that are conducted at treatment, storage and disposal (TSD) facilities pursuant to RCRA regulations
* Emergency response operations involving substantial threats involving hazardous substances, without regard to the physical location of these threats

The OSHA standard concerning worker exposure to hazardous materials deals with hazards that workers may be exposed to in the workplace, and is not only oriented differently but is more broad-based than that of the DOT (which is more concerned with Hazmat Transportation). It is interesting to note that even though the 1910.120 HAZWOPER is an OSHA standard, it does not use the OSHA Hazard Communication Standard (29 CFR 1910.1200) for hazardous chemicals. In fact the definition derives from the EPA’s Comprehensive Environmental Response, Compensation and Liability Act (CERCLA, also known as Superfund).

The HAZWOPER definition, in addition to the CERCLA listed hazardous substances, also includes: certain biological and disease-causing agents, the Department Of Transportation defined hazardous materials, as well as hazardous waste.

The CERCLA Standard incorporates exhaustive guidelines on issues relevant to the safe handling of hazardous materials. It requires detailed written safety and health programs for employees involved in hazardous waste operations. It provides examples of risks that would be relevant, such as situations that are injury threatening, immediate danger to life and health (IDLH), and danger to life and health (IDLH). It also provides examples of threats to environments, oxygen deficient situations etc.

Another important aspect of the OSHA standard is training. The HAZWOPER standard, which deals with hazardous waste operations and emergency response situations, necessarily requires a certain level of skill on the part of employees. OSHA mandated training courses may range from 4 to 40 hours depending upon the nature of the hazards being dealt with. After the initial training, OSHA also requires follow-up / refresher training. Fortunately, there are a number of commercial organizations which provide OSHA training programs, to ensure compliance to OSHA standards.

The EU RoHS and the China RoHS both restrict the use of the same six chemicals used in electrical and electronic equipment. These are lead (Pb), cadmium (Cd), mercury (Hg), hexavalent chromium (Cr VI), and fire retardant PBBs (poly-brominated biphenyls) and PBDEs (polybrominated diphenyl ethers). Both the RoHS limit Cd to 100 parts per million (ppm) and the other five to 1000 ppm on homogeneous material basis. This means that the restrictions apply to any single substance that could (theoretically) be separated mechanically. There are significant differences in the two regulations.

Firstly, the RoHS applies to ten categories of waste electrical and electronic equipment (referred to as WEEE) and includes a number of exemptions. It does not apply to industrial machinery, replacement parts for equipment sold prior to July 1, 2006, military equipment or aerospace applications. The China RoHS, on the other hand, proposes to include (in a catalogue to be issued), a list of electronic information products (EIPs) to which the regulation will apply. This will be a limited list (understood as 1800+) out of the universe of electrical and electronic equipment covered under ten broad headings in the document. Another difference is that the EU RoHS does not specify any labeling requirements whereas the Chinese document does so. Further, the Chinese RoHS will be implemented in two phases. Phase 1 effective March 1, 2007 requires specific labeling and content disclosure. Phase 2 will enforce the actual restrictions and require mandatory testing in local laboratories.

The differences between the two regulations mean that EU RoHS compliant products may not automatically be China RoHS compliant. Suppliers will have to work hard for compliance, particularly to document the content of the hazardous materials at ppm level in the products in the disclosures that will be required in Phase 2.

The Chinese RoHS compliance is only one of the worrisome issues facing suppliers. Of even more import are the impending Registration, Evaluation and Authorization of Chemicals (REACH), regulations which come into effect from June 1, 2007 in the European Union.

The REACH regulation, whose final draft was adopted in December 2006, is targeted at a wide range of hazardous chemicals and is not limited only to the electronics sector. It is much broader in scope than RoHS which covers only six hazardous materials. The REACH regulation will control the use of thousands of chemicals. Since many of the chemicals are likely to be used in the electronics supply chain, REACH will affect suppliers who have achieved RoHS compliance or are struggling to do so.

The RoHS and now the REACH, considered a bane by many suppliers, are stepping stones towards a cleaner, greener environment. Businesses which recognize this and embrace the change will surely prosper in this new century.

One is the Restriction of Hazardous Substances (RoHS) Directive 2002/95/EC (popularly called the Lead free RoHS) which limits the presence of six hazardous materials in electrical and electronic equipment. The other is the Waste Electrical and Electronic Equipment (WEEE) Directive 2002/96/EC. The WEEE directive aims at minimization of the impact of e-waste on the environment, by increasing re-use and recycling and reducing the amount of WEEE going to landfills. EU members are required to incorporate the provisions of both the RoHS and the WEEE are directives into their individual legislations.

Effective August 13, 2005, the WEEE directive, excludes equipment related to state security, arms and ammunition and war materials However it does cover thirteen categories of e-waste:

1. Large household appliances - excludes ODS fridges/freezers
2. Small household appliances (e.g. toaster, kettle, vacuum cleaner)
3. IT and telecommunications equipment
4. Consumer equipment (e.g. videos, radio, hi-fi) - excludes CRTs
5. Lighting equipment - excluding flourescent tubes
6. Electrical and electronic tools (e.g. drills, saws, sewing machines)
7. Toys, leisure and sports equipment (e.g. electric trains, video games)
8. Medical Devices - excludes contaminated items
9. Monitoring and control instruments (e.g. smoke detector, thermostats)
10. Automatic dispensers (e.g. vending machines)
11. Cooling equipment including category 10 devices with cooling
12. Display equipment (CRTs) including plasma and LCD
13. Gas discharge lamps (e.g. flourescent tubes)

The WEEE Directive is based on article 175 of the European Commission (EC) Treaty which established the European Union. This directive makes producers responsible for financing the collection, treatment, and recovery of waste electrical and electronic equipment. It also seeks to oblige distributors to allow consumers to return their waste equipment free of charge. This provision is based on the precept that the polluter should pay and applies irrespective of the selling technique, including distance selling.

Another aspect is the encouragement of product designs that facilitate dismantling and recovery. Producers are also required to provide reuse and treatment information on their products. This is to facilitate the reuse of components and to ensure the correct and environmentally sound treatment of WEEE, including maintenance, upgrade, refurbishment and recycling. EU member states are empowered to include additional products to the WEEE directive.

There are also provisions for and minimum standards for authorized collection and recycling sites. The directive also has certain labeling requirements such as the name of the producer, date code and a “Do Not Landfill” mark which consists of a crossed out wheel bin with a bar underneath indicating that the product was placed on the market after August 13, 2005.

The European Community has taken the lead on environmental issues and often, a role model for other nations. Many nations including the United States and China are considering WEEE legislation. The federal US legislation is expected to be in line with the EU WEEE. However, the draft legislation of the China WEEE, whose details are still sketchy, does not appear to be so. The China WEEE, when it comes, is likely to pose serious challenges for suppliers.

The Players
The letters S, A, P stand for some German words. At this point, knowing what those letters mean, is as irrelevant as knowing what IBM stands for. (By the way, I just learned that SAP was started by former IBMers). SAP was founded in Germany in 1972. It had become greatly successful and respected in the European market before it made any serious inroads in North America.

Oracle Corporation, a US company, leads the way in the home grown variety of enterprise-wide software. At its start in 1977, the focus was on database solutions. It took close to 20 years before a reasonable facsimile of an ERP system was produced.

Both companies started with ERP systems which handled basic business functions such as order entry, accounts receivable, production, inventory, purchasing and accounts payable - all integrated with a financial backbone. Now their offerings have expanded to include ERP off-springs like Customer Relationship Management (CRM), Business Intelligence, and Supply Chain Management (SCM) to name a few.

The Definitions
At dictionary.com, I looked up definitions for sap. The two definitions I would have given:
1) to undermine;weaken or destroy insidiously - with Synonyms: impair, enfeeble, deplete, exhaust, enervate
2) Slang. a fool; dupe.

But two other definitions surprised me:
1) Fortification. a deep, narrow trench constructed so as to form an approach to a besieged place or an enemy’s position
2) Fortification.
a. to approach (a besieged place or an enemy position) by means of deep, narrow trenches protected by gabions or parapets.
b. to dig such trenches in (ground).

Which sap is SAP?

The Challenges:
* SAP corporation is still the leader in the ERP space, but Oracle is gaining ground.
* Turnover in SAP’s top ranks is worth noting and watching
* SAP is sticking to old ways of doing things - ways that have been successful in the past.
* They have evolved from mainframe R/2 to client server SAP R/3 and then to enterprise version mySAP. Now, SAP is giving more attention to “software as a service” to try to capture more of the midsize market. Are they committed to operating in that space?

The Approach
Oracle is building approach / attack trenches by acquiring companies that make Oracle a more comprehensive solution provider. Is SAP impaired by this? An April 2007 InformationWeek article talks about SAP’s CEO Kagermann and his strategies for the future. SAP did not capture the lead position by being a fool. They cannot and should not be discounted. SAP is still a force to be reckoned with.