Previous columns have addressed some of the topics that provide a foundation for understanding the scope and complexity of the worldwide movement to achieve hazardous-substance free (HSF) products and production processes. This month, let’s take a look at how people have been behaving and why they’re acting the way they are in response to the new accountabilities originally imposed by the European Union’s (EU) WEEE and RoHS directives. Depending on your role and responsibilities in your work and life, you may be seeing quite a range of differing behaviors. Generally speaking, a demand placed upon any one of us creates tension. A basic principle in nature is that tension seeks resolution. Tension drives us to take action to gain relief. In our day-to-day lives some examples of tension triggers are:
Individuals and organizations may well be experiencing tensions such as these as a result of the imposition of the hazardous substance restriction requirements. The demand for compliance with the requirements being imposed by numerous legislative, regulatory, business and judicial bodies can be felt as very threatening and triggers our instinct for survival.
It used to be survival hinged on food, sex, shelter and good hunting grounds. Survival threats were wild animals and natural events. With RoHS and WEEE, perceived threats to survival stimulate fears that customers will turn to a compliant competitor, a country will refuse to allow importation of your noncompliant products, you’ll be financially liable for the costs of remedying noncompliance, or that you may be criminally prosecuted if noncompliance is thought to be willful. Individual countries within the European Union are free to establish their own processes for determining compliance and their own policies regarding enforcement and penalties.
As a nation and a competitor in the global marketplace, the United States has been confronted by a threat to its survival in the past. It had lost its dominant position in more than one global industry. It was taught by the Japanese that it was much more cost-effective and far more beneficial to focus on developing a controlled, capable and reliable process to build quality into a product, rather than trying to inspect it into the product after the fact.
In the United States, our response to the tension created by the imposition of the accountabilities embodied in the EU directives took a curious turn. These accountabilities and what needed to be accomplished were imposed without guidance as to how to get it done. It seems that protecting ourselves and our customers from noncompliant companies became the perceived path to tension resolution. This triggered many enterprises’ regression to the old practice of screening finished product and harvesting good product from bad to ensure quality. For some, scrap and rework again became an accepted cost of doing business while trying to achieve compliance. That product-focused resolution is likely to be short lived. The newer forms of RoHS being promulgated by China and Korea, among other countries, are specifically written to require evidence of a process management approach to ensure compliance.
What’s going on in your company, with your customers and suppliers? Is the hazardous substance restriction compliance behavior you are participating in or observing primarily tension-resolution driven, or HSF goal-objective driven? Some have sought tension resolution by sticking their heads in the sand and ignoring what was going on around them. Some called their attorneys to mount their defenses against liability consequences. Some shifted responsibility for ensuring compliance completely onto their suppliers. Others have publicly declared their commitment to doing the “right” thing. Some of them—not having had their feet held to the fire by their customers or regulatory enforcers—are now comforting themselves that they’re doing “good enough.”
On the other hand, some people are motivated by their belief that developing their process management capability so as to achieve HSF compliance will differentiate them from competitors and provide a significant competitive advantage. For example, the component manufacturers of Asia have been the leaders in making RoHS-compliant parts and reducing hazardous substances in their products. The most extensive adoption of and adherence to QC 080000 IECQ HSPM is in Asia.
Stakeholders in this worldwide change are somewhat inclined to take one of two approaches: Affect the conditions that triggered the pattern of behavior that caused the problem or manage the consequences to discourage repetition of that behavior.
Following are a few items from past columns.
Which ones are oriented toward conditions triggering behavior and which are aimed at consequences?
Change of this magnitude isn’t an event. It’s a process. Fundamentally, it means that many of us must learn to behave differently.