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Agile Product Lifecycle Management Product Governance and Compliance User Guide Release 9.3.3 E39296-01 |
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# 3 Levels of Due Diligence Using PG&C

Requests For Information - the main subject of this chapter - can take many forms, based on the regulations a company may adhere to and the declarations used to gather compliance-specific data. But the capabilities of the PG&C solution are not wholly defined by such PG&C objects as Specifications and Declarations.

In setting up your company's RFI process, it can be helpful to analyze the level(s) of due diligence that you will be undertaking. Here are some simple examples of due diligence, from a relatively straightforward level to a more complex level.

## 3.1 Specification Management

In terms of substance-based environmental compliance, the simplest level of due diligence involves specifications.

- Let the system assign specifications to all parts within this BOM, and set declared compliance on the specification for a part.

- Define a specification, list exemptions, attach specifications to the product level.

- let the system roll up the compliance information and review for compliance at the product level.

- This use case illustrates the usage of PG&C for general product compliance such as compliance with an FCC specification or with a "MilSpec."

## 3.2 Declarations Gather Compliance Information

A higher level of due diligence is achieved by using a declaration process including a supplier sign-off to gather compliance information. Use declarations to collect information about the compliance of a part or a supplier with a certain specification.

## 3.3 Full Use of PG&C Business Objects

The highest level of due diligence for substances-based environmental compliance is achieved by the full use of PG&C object types. - substances, specifications, declarations, part groups - as well as solution-oriented features of "non-PG&C" object types - items, manufacturer parts, suppliers - to produce comprehensive disclosure statements about compositions.

## 3.4 Summary

This simplified hierarchy demonstrates that you can tailor the use of the PG&C solution depending on the required type of compliance and the desired level of due diligence. Substances and even Declarations are not absolutely required to gather benefits from PG&C. The Specification is the most crucial object type; and the Composition - the collection of compliance data - is unique to Agile PG&C.

## 3.5 RFI Process Overview

A Request For Information (RFI) consists of a material declaration, which lists the parts in a product assembly and shows the substances and materials contained in those parts. It is linked to specifications, which may restrict how much of a particular substance the product assembly may contain. A declaration request to a supplier can contain multiple combinations of parts and part groups and specifications (or compositions).

The RFI process is depicted below.

The general sequence of the RFI process is:

Process step | More information about this step
--- | ---
Performed on Buyer side by Compliance Manager
Identify parts and part groups for which compliance data is required. | Parts and Part Groups
Identify people within your company (for parts) and suppliers (for manufacturer parts) who can provide compliance data. This may be an informal process - collecting names and verifying that internal and external (supplier) users with appropriate roles and privileges are available in the database - or involve more research and creation of an Approved Suppliers List, or ASL. | Managing Your Suppliers
Create declarations - one supplier per declaration - for parts, manufacturer parts, and part groups. | Creating Declarations
Route a declaration to an information supplier using the Declarations workflow. | Routing Declarations
Performed on Supplier side by Material Provider
Supplier completes the declaration with data and an electronic signoff. | Information Supplier Fills Out a Declaration
Performed on Buyer side by Compliance Manager
Compliance data is assessed for completeness and validated for correctness. This may include running inboard compliance rollups. | Rolling Up Compliance Data
Reviewed and approved declarations are released, which publishes the data across the company's product record in Agile PLM. | Completing the RFI Process

### 3.5.1 Creating Declarations without Supplier Interaction

In another commonly used scenario, the Compliance Manager creates a Declaration on behalf of a supplier and import the compliance data without supplier interaction. This process is often automated using process extensions for mass imports.

## 3.6 Declaration Workflow and the RFI Process

There are seven default classes of Declarations in PG&C, and they all use the Default Declarations Workflow. The Declarations workflow is the vehicle to send RFIs to your suppliers.

As such, every declaration is a routable object used to keep track of the compliance information about all the substances and materials that are contained in parts or part groups associated in the declaration. As a routable object, the user's actions (on either the buyer or supplier side) result in the declaration moving into another status where the next user will act on it.

The user assigned as the "change analyst" of the compliance workflow is called the compliance manager. The compliance manager creates and sends a declaration request to an information supplier. The supplier completes the declaration by providing data statement for each combination of specification and part - the composition.

In the sequence that results in an RFI, the first main task is to identify those parts (Items and Manufacturer Parts) and part groups for which you must seek compliance information.

The other main task is to identify the people who will gather and provide that information. This includes people within your company (other compliance managers and assistants) and people who work for your suppliers.

## 3.7 Routing Declarations

The Default Declarations workflow follows a straightforward process flow, as detailed in the following table.

Important: PG&C permits customized workflows to be sent to suppliers. See your Agile administrator.

Status | Action
--- | ---
Pending | Compliance manager (an Agile user who has been assigned the Compliance Manager role) creates a new declaration, or modifies an existing declaration by adding new items, manufacturer parts, or part groups. Specifications are added to the declaration, and also an information supplier; there is always only one supplier per declaration.
Open to Supplier | The declaration requests the supplier - an Agile user who has been assigned the (Restricted) Material Provider role - to confirm whether parts comply with specifications. For more information about creating and managing suppliers, see Managing Your Suppliers.
Submit to Manager | Supplier confirms or denies that the parts that they supply comply with regulations. The supplier electronically "signs" and submits the declaration back to the compliance manager.
Review | The compliance manager and other reviewers verify and approve the contents of the declaration. A reviewer (system user or supplier user) can acknowledge a declaration when the user is added as an acknowledger.
Released | The compliance manager releases the declaration, thereby publishing the new data about the substances and materials into the product record. Once published, the materials are visible on the Compliance tab of the part or part group, as appropriate. The "buyer" company can now examine the quantities of all materials in a given top-level assembly and find out if the assembly is compliant with a set of specifications.
Implemented | Once the parts are manufactured and disseminated in the field, the compliance manager implements the declaration, thereby completing the workflow.

For more information about workflows and customizing workflows (including how to add and remove approvers, acknowledgers, and observers), see Routing Objects with Workflows section of Getting Started with Agile PLM.

Once a declaration is opened to a supplier, only the supplier's declaration recipients can edit it. For other users, including the compliance manager, the declaration becomes "read-only" until it is returned by the supplier (unless, as always, the behavior of the workflow has been modified by the administrator).

Note: A released declaration is not set back to Pending status if one of the approvers rejected it and the workflow has a rule that says "If rejected, set to Pending."

### 3.7.1 Notifications when Declarations Advance to and from Supplier

This set of default behaviors regards automatic notifications, not user-designated Approvers and Observers.

- Declaration Buyer to Supplier - The notification is sent to the "Default Declaration Recipient" specified on the General Info tab. Although this notification is sent only to the default recipient, other users in the supplier company with Material Provider role can respond to the declarations as well.

- Declaration Supplier to Buyer - The compliance manager is automatically added to the notification list. If no compliance manager was selected, the system add everyone on the Compliance Managers notification list.

- Declaration Supplier to Buyer - If there are no compliance managers in the system, the originator is added to the notification list.

#### 3.7.1.1 Acknowledgments for Declarations

A user or user group added as an acknowledger can acknowledge a declaration. Following are examples for acknowledgments for declarations.

Add Acknowledger from the Change Status dialog or the Add Reviewers dialog:

When the Acknowledger opens the declaration, the Acknowledge button is enabled:

The Acknowledger clicks the Acknowledge button and acknowledges the declaration:

#### 3.7.1.2 Receiving Notifications

Following are the notifications tied to the Acknowledge function:

- Substance Declarations - Declaration Acknowledge Change, Add Acknowledger

- Substance Declarations - Declaration Status Promotion, Acknowledgers

- Substance Declarations - Acknowledge Material Declaration, Notifiers

- Substance Declarations - Acknowledge Declaration, Remove Acknowledger

- Substance Declarations - Acknowledge Declaration, Escalation

- Substance Declarations - Acknowledge Declaration, Reminder

For more about declaration notifications, please refer to Using the Declarations Workflow in RFIs.

## 3.8 Information Supplier Fills Out a Declaration

This manual has more information about suppliers in Chapter 11, "Managing Your Suppliers." The PG&C Supplier Guide is written to suppliers and documents the supplier experience in the PG&C solution.

When a declaration request is opened to an information supplier, the supplier is responsible for completing the declaration and disclosing if any restricted substances are contained in the components and subassemblies it provides and whether those substances comply with specifications.

To complete and sign off on declarations, one or more declaration recipients for the information supplier must be assigned the (Restricted) Material Provider role. If you have questions about who in your supply chain has been assigned this role, see your administrator.

The declaration recipient should do the following to complete a declaration.

- For each part, manufacturer part, and part group, fill in the Mass, Mass PPM, and Compliance fields, particularly for substances that are restricted by specifications;

- Add or remove substances from the Substances tables (under the Items, Manufacturer Parts, and Part Groups tabs) on the declaration as necessary; to do this, they must use process extensions (Export AXML and Import AXML) or the Microsoft Excel-based Client, as long as they are in the Basic mode ("supplier interface") of Web Client. Available process extensions in the Actions menu vary, depending on the Declaration subclasses. IPC-1752 declarations have different Import/Export options available than substance declarations or homogeneous materials declarations;

- Complete other flex fields on the <parts/PG> tables as well as the <parts/PG> Substances tables.

For detailed tasks about adding, removing, and editing data on declarations, see Tabs and Attributes in Declarations.

When the material provider changes the status of the declaration from Open to Supplier to Submit to Manager, he must "sign off" the declaration.

## 3.9 Completing the RFI Process

Once the compliance manager has received, reviewed, and approved the content of the declaration, he advances the workflow to the Released status, and the new data about substances and materials are automatically published to Agile PLM. Once published, the materials are visible on the Compliance tab of the part or part group, as appropriate.

The "buyer" company can now examine the quantities of all materials in a given top-level assembly and find out if the assembly is compliant with a set of specifications by running compliance rollups. See Rolling Up Compliance Data Using Internal Rollup.

## 3.10 Reviewing and Publishing a Declaration

Once a declaration is released, it is automatically published. When a new declaration is published, it overwrites substances from previously published declarations.

If the substance data on an item's or manufacturer part's Compliance tab is from a declaration, you cannot modify it except through another declaration.

When a declaration is released for a part or part group:

- The composition appears in the Active Declarations table in the part's Compliance tab.

- If a matching active composition exists (same supplier + same spec), then the previous composition is moved to Historical Compositions table and the new one becomes active.