Manufacturers of electronic equipment, including computers and cell phones, have been working voluntarily with their suppliers for years to eliminate hazardous substances such as toxics and heavy metals from their supply chains. However, the enactment in 2002 of European legislation called Restriction of Hazardous Substances (RoHS) has propelled the industry globally into action. As a supplier of critical components, Texas Instruments routinely receives requests from its customers to document its procedures and performance with regard to limitations on banned and restricted materials.

Texas Instruments recognized RoHS as a competitive issue, since inability to comply could result in delayed time to market and loss of market share, and could also threaten established customer relationships. Industry experience has shown that slight deviations in restricted substance content can result in product recall costs on the order of hundreds of millions of dollars. Accordingly, in mid-2002 Texas Instruments formed a cross-functional team to address this issue, championed by the Director of Quality, and including representatives from Quality, EHS, Legal, Procurement, and Manufacturing. The role of EHS was to characterize customer expectations and raise awareness of relevant legislation.

The goal of the team was to develop a systematic process for assuring compliance with regulatory and customer requirements regarding banned and restricted substances. The team encountered a number of barriers in developing the process, including:

•  Great variability in customer information requests, although all were driven by the same need
• Time and effort required to communicate the importance of this issue to internal stakeholders
• Challenge of assigning responsibility for managing this issue to the appropriate internal group.

The team engaged in many internal meetings and communications to determine the scope of the issue and design a process that addressed it satisfactorily. The resulting action plan included:

• Review and expansion of an existing chemical screening specification to cover the new requirements
• Development of the new process, including procedures and software
• Development and administration of training for all stakeholders
• Modification of audit mechanisms to include the needed verifications
• External stakeholder communication, including customers, regulatory agencies, and electronics industry associations in the U.S., Europe and Japan.

Texas Instruments believes that the costs of the initiative were well worth the outcome: the ability to demonstrate to customers an effective process that assures tight control over restricted substance utilization. Initial customer response has been very positive, but it will take time to measure and quantify the overall benefits in terms of profitability, market share, and customer retention. One thing is clear - the process could not have been developed and integrated so rapidly without the established insights of EHS personnel into the company's operations and business processes.