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REALITY CHECK: EPHRAIM SCHWARTZ                 http://www.infoworld.com
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Tuesday, November 2, 2004

CAUGHT IN A REGULATORY CROSS FIRE

By Ephraim Schwartz

Posted October 29, 2004 3:00 PM Pacific Time

Here's a bit of advice for those of you planning IT budgets. For the
next five to 10 years, set aside 10 percent to comply with new
government regulations, both from the United States and from other
governments in your major markets.

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In fact, some industry experts are predicting that three regulations due
to go into effect during the next 21 months will cost IT exactly that
much. From the Food and Drug Administration comes the Food Allergen
Labeling and Consumer Protection Act (FALCPA), with a deadline of
January 2006. From the European Union, the Restrictions on the Use of
Certain Hazardous Substances in Electrical and Electronic Equipment
(RoHS) Directive goes into effect July 2006 and the Waste Electrical and
Electronic Equipment (WEEE) Directive starts August 2005. And similar
regulations are expected from China and California.

RoHS, in particular, will have a dramatic affect on the computer
industry. It will prohibit the sale in the European Union of electronics
products that contain more than 0.01 percent of eight hazardous
materials, one of which is lead.

Lead-based solder has been used in the electronics industry for close to
seven decades, says Scott O'Connell, an environmental engineer at Dell.
For Dell and other electronics manufacturers, switching from tin-lead
alloy to tin-silver-copper alloy -- or some other formula -- is just as
much an informational challenge as is it is a manufacturing one.

On the manufacturing side, companies must retool their reflow ovens to
handle this tin-silver-copper solder, the melting temperature of which
is 30 degrees to 40 degrees higher than that of tin-lead alloy.

On the IT side, imagine every part number that must be changed. Also,
consider that every part must come with a declaration from the supplier
that the part is lead-free, and that declaration must travel with the
product from design to the day it ships.

To compensate, Dell must integrate new workflows into its existing BOM
(bill of materials) infrastructure for product development, in addition
to acquiring PLM (product lifecycle management) software from the likes
of Agile. Also needed is a software tool that can automatically send a
request to each supplier to certify its regulatory compliance and then
verify that certification on Dell's side before the product is released.
On top of that, Dell must now not only train its own internal staff on
the new business processes but train its suppliers as well.

Dell would not quantify the total expense, but O'Connell admits there
are "significant resource costs around managing the transition."

For other industries, FALCPA will also mean major changes. FALCPA
requires food processing and manufacturing companies to list on their
labels the eight most common food allergens that may be contained in the
finished product. Steve Phelan, founder and senior vice president at
Formation Systems, a PLM vendor, says companies will need to include
ingredient tracking not only for themselves but for their suppliers --
all the way down to the raw-materials level -- as well.

And WEEE, a waste disposal and recycling regulation, will make
manufacturers responsible for what happens to goods at the end of their
product lifecycles. According to Chris Wong, chief product officer at
Agile, this means that product design will need to factor in product
disposal.

If you think reserving 10 percent of your IT budget for regulatory
compliance tools is too drastic, consider this final thought. According
to Bruce Richardson at AMR Research, one manufacturer estimates that
compliance with RoHS alone will cost it anywhere from 1 percent to 2
percent of its revenue. That company's revenue is $400 million; you do
the math.

Ephraim Schwartz is an editor at large at InfoWorld.


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