Dell designs and engineers its products to prevent pollution and conserve natural resources throughout the system's life, achieving environmental responsiveness in tandem with sound business management. Reducing the environmental impact of Dell products begins at the design stage as cross-functional product design teams work to make thoughtful and effective decisions that will have positive environmental results throughout the equipment's life cycle.
Dell recognizes the critical window of opportunity during the early design stages of a product when even a small environmental consideration can have a large effect on the environmental impact of a product throughout its life cycle. Dell is working toward capitalizing on this window of opportunity with the Dell Design for Environment (DfE) program. The Dell DfE program instills environmentally sound principles into product design.
Dell's Design for Environment (DfE) program incorporates into product development environmental attributes such as reduction of environmentally sensitive materials, decreases in equipment energy consumption, extension of product life span and utilization of parts that can be reused, resold or recycled.
Complementing these attributes, Dell's DfE approach works to achieve higher product quality and longevity, improved customer satisfaction and innovations in materials management. Greater efficiencies in manufacturing and service along with reduced costs associated with asset recovery also result from this program.
Environmentally Sensitive Materials Elimination
Dell directs its suppliers to restrict and/or eliminate environmentally sensitive materials in the components and products supplied to Dell.
Consistent with our Chemical Use Policy, periodic revisions of our restricted materials list will be made to incorporate legal requirements, relevant aspects of international treaties and conventions (such as the Convention for the Protection of the Marine Environment of the N.E. Atlantic (OSPAR) Chemicals for Priority Action), and specific market demands.
Product Content Restrictions
Dell's Restricted Materials Guidance Document lists substances that Dell bans or restricts. For each listed substance, a threshold limit has been established to account for unavoidable impurities along with exemptions consistent with regulatory requirements.
Dell has implemented robust compliance assurance processes to ensure Dell's precautionary chemical use policies are met throughout the entire supply chain.
Compliance Verification Process
Dell is planning to implement a software solution that will improve the collection of materials compliance declarations throughout the supply base. This new solution will integrate with Dell's product record system to enhance the accessibility of materials compliance data and enable compliance roll-up throughout each product's bill of materials. In addition, this solution will enable improved tracking of compliance throughout a product's life cycle. Part of the deployment effort includes training, both at Dell and through the supply chain. This solution is targeted to be in place by the middle of 2006.
Until this data collection solution is deployed, Dell is managing compliance verification of parts and products by way of a Supplier's Declaration of Conformity (SDoC), modeled after ISO/IEC 17050-1 and through an audit program. Dell is collecting SDoCs to support compliance verification efforts. To sign the SDoC, the supplier must ensure that the product meets the Dell Materials Restricted for Use specification and record any applicable exemptions. At Dell's request, the supplier must also be able to provide technical documentation in the form of internal design controls, supplier declarations, or analytical test data. Dell's goal is to collect supplier declarations on each part in a product bill of materials. This will ensure each product meets the legislated materials requirements.
As part of every new supplier contracting process, Dell requires suppliers to sign an agreement acknowledging they are aware of and will abide by Dell sustainability requirements and principles. For additional details, see Supplier Principles: Supply Chain Management System.
Compliance Verification Audit Program
A second tier in Dell's compliance verification strategy is a supplier audit program. This program can be divided into two parts: a traditional audit and an in-depth supplier survey. A traditional audit is conducted on a quarterly basis in which Dell parts are selected at random and submitted for third-party analytical testing. Samples are tested for restricted materials including those highlighted by the RoHS Directive. The audit allows Dell to investigate gray areas, enforce SDoC diligence, and assist in supplier compliance uncertainty. Dell also actively screens samples in-house by using an X-Ray Fluorescence (XRF) unit.
