Wiring Harness News May-Jun 2022 - Page 29

uct being banned from a region . The EU has recently passed legislation to step up their enforcement efforts , so the days of this being a “ don ’ t worry about it ” potential problem are coming to an end . Of particular concern is the amount of counterfeit or just plain fraudulent data swamping the data collection market . As an engineer who has spent 18 years in data collection management , whenever I see the phrase “ to the best of my knowledge ,” I know the data is suspect . Simply put , if it is accurate , it is already known to be correct . Often , I see data that includes a wild card , “ Misc . not to disclose ”. This is of course acceptable if it comes from the actual manufacturer of the material , who knows what it represents and is tracking it against the global declarable substance lists . But all too often I see instances where someone doesn ’ t get the disclosure from the material company and puts this wild card in to give the data a veneer of being official .
This leads to a problem , namely , how do we know if the data is real or made up ? In a recent review , it was noted that there were over 100 data submissions floating through the supply chains for Velcro that incorrectly stated the material used , and therefore their data could not have come from the manufacturer of Velcro . With the difficulties in extracting data at multiple levels of depth in the supply chains , companies are under pressure to speed up reporting and often just take report data that looks real , but may not be from the actual manufacturer . This is especially true for some overseas suppliers . Right now , we have no way of discerning if the data being collected are complete and real , counterfeit , or entirely fraudulent . Some sources are much better than others , but all have weaknesses . When you consider , for example , substances like PFASs with a future reporting requirement of 25 PPB , you start to gain an appreciation of the scope and depth of the problem that our multi-level supply chain creates .
A problem of this magnitude won ’ t be solved with tweaks and band-aids but requires an approach from an entirely new angle . We must accept , and demand that the needed compliance information be considered as a component of the physical part we are buying . It must be shipped along with the part , in digital format , and follow the part throughout the supply chains all the way to the OEM . With the data becoming a fundamental component of the hard part , we need assurance that it is assembled with the same quality as the hard part . All the same basic quality principles used in part manufacturing can be applied to compliance data . But if it is not , we are the ones on the front lines of liability .
Current compliance data reminds me of the quality issues in the parts industry from the 60s and early 70s , before the move to zero defects . Most data outside of IMDS in automotive , for example , is exchanged point to point between various systems where there is no traceability . So when there is a problem , how do we know if it was fixed by the person who actually knows the real data , versus whether it was done by someone who made it “ look ” right ? The attitude today seems to be , that if the customer accepts it , it must be good enough , and if there is a problem , they will send it back and we will try to fix it . Is this “ good enough ” approach sufficient in light of our future realities – both costs and liabilities ? I think not .
The Solution :
We need to rethink compliance data collection and realize it is part of a greater sustainability issue . To limit liability , the data will need to be verifiable , that is , traceable to the material manufacturers who know what actual substances are contained in the product as shipped and what they become after the product is cured ( if needed ). To contain the runaway costs of current compliance data collection , we also need to establish a new cross-industry data structure that includes a full material declaration ( FMD ) for the basic part which supports RoHS and REACH analysis . This new data structure must go beyond the standard formats such as IP- C1752A or B to provide an exchange format that will allow for future integration directly into LCA software . This forthcoming data structure will be included in what is currently called the “ Product Passport ,” as an aggregate of the substance content with the greenhouse gas impact , conflict mineral and recyclate content , recyclability , and much more . As an industry , we need to get behind this effort .
Efforts are underway to create the factory of the future . I envision this to include designing the product not only for sustainability but also for sustainable manufacturing . This will require us to integrate material data collection efforts into the “ factory of future ” efforts . It is time for us to begin demanding that the data be supplied with the purchase of samples to the designers of the products we manufacture , or directly to us with the purchase of parts . However , this will only happen if we band together as an industry to put pressure on our customers , suppliers , and component manufacturers . To make this happen we must create the change we need . We need to force the creation of a future where data no longer is collected but received with the shipping paperwork . We need to drive on organizations , such as IPC / WHMA to establish industry standards so this can happen .


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