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92 SMT007 MAGAZINE I JULY 2018 In a good reporting tool, then, some accom- modation must be made for accepting these "wildcard" substances which inherently have no CAS number. We have seen a commonly but not universally accepted limit of 10% per homogenous material can be checked in the tool to ensure this limit is not exceeded. A good tool should also allow for a choice of a customer-specific wildcard substance name, which is not subject to checking from a CAS number list or a CAS format validation routine. Based on our review, if proper warnings are provided, this appears to be the best way at present to handle such data. Requirements Part Four: Fewer Barriers, More Open Road So far, we have presented desirable features to help generate FMDs. The real power, though, is only realized through ability to revise, reuse, and build on data once it has been initially entered into a tool. First of these capabilities is ability to quickly edit the substances in a material. For compa- nies making a family of items with related composition, changing just a few entries, or modifying the percentages of them, can be done in seconds and saved under a different product name and XML file, with version track- ing as desired in the file name. This should be allowed during an existing session or combined with the next feature. Once a complete XML FMD is gener- ated, productivity is enhanced if that file can be easily imported again at a later date and edited as required. This portability and flex- ibility of data allows a supplier further down the supply chain to utilize a growing library of common materials and their formulations, and to quickly create new ones without having to repeat some or even most of the data entry. In most cases, the company's own information, like company ID, contact and authorizer, will be repeated over many declarations. If contact and authorizer are the same person, they could be copied directly with a choice in the tool. While we are focusing here on the Class D FMD, ability to generate Class A or Class D declarations at the same time may be useful. These should be selected, or de-selected as desired, or as required by the customer. Class A query/response answers should be straight- forward, as should selection of exemptions from a list. Similarly, the substance data in the Class D data section should be quickly erased to enter fresh data while retaining the rest of the information already entered. Interactive helps should provide guidance to first time and infrequent users. Checks along the way improve speed and accuracy without having to consult a user's manual, which inci- dentally should also be easily accessible for those who wish to read the instructions first. Finally, the tool should prevent hang-ups and errors. Support services should be provided, and a process to investigate and resolve bugs, or perceived bugs, should be easy to submit and provide timely responses. At the end of data entry there should be a final validation of the XML, included manda- tory information has been entered and the weights of substances add up to each homog- enous material being reported. These checks help ensure that the XML will successfully load to the customer's system. Conclusions: To the Superhighway According to some observers, FMD still has too many barriers to really catch on. We disagree. Supply chain reporting has to begin somewhere, by providing data to middle supply chain companies, and so forth up to chain to the OEM. FMD is the only reporting approach that helps to minimize the ongoing burden of keeping up with the ever-growing lists of regu- lated substances and expiring exemptions. We have mentioned that the IEC 62474 database is now invoked as the reportable substance list in IPC-1752A Amendment 3. In addition, development of an IEC 62474 inter- national standard for reporting is in process, which will also specify an XML format. Work is underway to harmonize the schema of both IPC and IEC standards via communication and common participants in both IPC and IEC stan- dards development, but differences should still be expected. Development of the IEC reporting

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