Keep it simple, stupid! Lead-free compliance doesn't have to be complicated. in fact, the less complex it can be, the better it will be for everyone in the supply chain.

THE FINAL COUNTDOWN has begun. We are on our way to a bright new, environmentally better tomorrow!

The implementation deadline for the RoHS Directive is less than a year away. Can't you feel the excitement? Is your pulse racing? Or maybe you're experiencing a different feeling, a knot in your stomach that tells you, "Here we go again. What a waste!"

It has been my experience that whenever someone unfamiliar with your business, processes or technology tells you what to do and when to do it, you end up spending a lot of time and resources just to get back to where you started. They do nothing and you do everything, which to me is a classic definition of waste!

Don't get me wrong. I applaud the motives and intentions of the EU legislators--who most likely have never been involved in the manufacturing of any product or development of any technology--in trying, via the RoHS Directive, to improve the global environment.

There have been some extraordinary efforts made by material suppliers, product designers and the industry in general to develop and refine chemistries, processes and materials to conform to both the spirit and letter of the RoHS Directive. However, the countdown to July 1, 2006 has begun, and as the old adage goes, "The devil is in the details."

Which brings me back to waste. One of the reasons that so much time and resources are wasted when that unknowledgeable person tells you what and when to do something is that he is clueless about all the details that need to be worked through in order for implementation to be successful. One detail related to implementing the RoHS Directive that will likely create the most heartburn has nothing to do with producing lead-flee product. Verification via some sort of declaration may be the most difficult, controversial and wasteful aspect of the lead-free initiatives.

When dealing with anything that is a potential waste of time and resources, the best thing to do is focus on keeping everything as simple as possible. When required to certify via any sort of declaration, all you can do is confirm what you honestly believe to be true. Simplicity and honesty should be your benchmark.

So how do you make the verification of something that is as wide in scope as the RoHS Directive simple? By verifying what you know--the materials you buy and the processes you use. It serves no benefit, and is virtually impossible, to verify what is not in your product. Focus on what you know and have the documentation to support. Beginning with the quotation process, if a customer asks for a board to be made lead-free, respond not by saying it is quoted to be made lead-free but rather quote what process and materials will be used in production. Your quote may state that the board is quoted using a tin surface finish on laminate made by ABC Company. It is the customer's responsibility to accept or reject the materials and processes used.

Fabricators all build to the customer's print. When an exception to the customer's print is needed fabricators have the customer sign off on that change before proceeding with the order. Supplying lead-free product and complying to Rolls should be no different. The customer knows the application and the applicable assembly process best. The customer has the responsibility to specify what materials and processes he requires, and to sign off on any exceptions should a fabricator's materials or processes differ from those on the print.

When you verify that you have produced product per a specific process, your honesty enters the picture. For years companies have verified processes. Many companies today verify that they produce product to, say, a MIL standard. If a product is ordered to be built to a MIL standard, fabricators need to honestly believe they have produced that product to meet the MIL standard before they sign the certification and ship product to the customer.

Equally, fabricators order raw materials from suppliers who send certifications with the materials. Fabricators have always relied upon suppliers to honestly declare that the materials indeed meet the standards they are certified to. RoHS compliance should be no more or no less than existing material and MIL compliance: When the product is shipped and a declaration is signed and sent with the order, the same level of honesty and integrity needs to be applied by everyone in the supply chain.

Simple? Yes, but not necessarily easy. Too many companies want to force the compliance documentation effort to others in the supply chain. Everyone wants to receive--not produce--the verification document. In short, everyone wants to be in the best position in the case of a lawsuit.

Which brings us to the ultimate waste. The best way for everyone to avoid the waste of a lawsuit is for each of us in the supply chain to treat lead-free as we would any other material specification. In short, keep lead-free simple!

PETER BIGELOW is president and CEO of IMI (www.imipcb.com). He can be reached at [e-mail].