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" Cincom Enterprise Compliance and Quality Management helps manufacturers improve revenue, profits, and customer satisfaction by delivering a fully integrated suite of solutions that resolve issues quickly and prevent recurrence, ensuring compliance with industry and regulatory requirements. "
Source : Cincom Systems
The High Costs of Non-compliance for Manufacturers
Regulatory compliance is also known as :
Data Loss Prevention,
Data Governance,
Auditing ,
Corporate Governance,
Sarbanes Oxley Compliance,
SOX,
Sarbanes Oxley Policy,
Risk Management,
Information Technology Audit,
Corporate Governance,
Information Technology Controls,
IT Governance,
Corporate Social Responsibility,
Governance,
Corporate Transparency,
Business Ethics.
Table of Contents
- Introduction
- Competing Globally Starts with Compliance
- Why the Time for Compliance Is Now
- Where Compliance Strategies Are Working
- Creating a Compliance Strategy: Intel's Lessons
Learned Globally
- The Bottom Line: Compliance Pays
Introduction
Of all the forces impacting manufacturing today, compliance
is fundamentally re-ordering the landscapes of entire
industries. Lack of compliance can cost millions of dollars
in lost market share and inventory write-downs for
products that are not compliant, and present significant
challenges in turning around a tarnished reputation.
In addition, there is the broader and much more costly
expense of re-architecting and redefining supply chains
and products to be in compliance.
There needs to be a very real sense of urgency around the
Reduction of Hazardous Substances (RoHS) Directive,
which went into effect on July 1, 2006 throughout the EU
and the Waste Electrical and Electronic Equipment (WEEE)
initiative. Since then, there has been a groundswell of
support for this standard, first driven by the need for
compliance to these regulatory requirements, and secondly
for the competitive advantages greater internal process
coordination provides. RoHS and WEEE have become the
forefront issues in manufacturing globally due to their
implications for any manufacturer selling into the EU.
What manufacturers need to realize is that through the
efforts to be more compliant with regulatory standards,
they can transform their manufacturing operations to be
more competitive. Compliance is transforming the
companies that have taken the time to re-architect and
redefine the many processes relied on for managing
suppliers on the one hand and channel partners, resellers,
and customers on the other.
For manufacturers that ignore compliance, the costs can
be steep. In fact, the EU has already made it clear that
they will not tolerate a lack of compliance with RoHS and
WEEE initiatives. Abacus, a distributor located in the
United Kingdom, has stated that approximately $6.1M in
inventory will be written off due to the products being
non-compliant with the RoHS standard. Other manufacturers
are battling lost sales opportunities due to "green friendly"
products with RoHS and WEEE compliance being
perceived as less risky than going with products from
manufacturers that have yet to gain compliance.
Becoming RoHS- and WEEE-compliant is more about
becoming part of a broader economic ecosystem that
encompasses a manufacturer's supply chain, illustrating
RoHS and WEEE compliance for the suppliers managed
and the manufacturing work completed. There is no
substitute for this level of supply-chain integration. To
become compliant with RoHS and WEEE, and to continue
selling into the EU, these are necessary steps.
Competing Globally Starts with Compliance
Manufacturers need to get beyond seeing RoHS and
WEEE initiatives as unwelcome costs and regulations that
influence their ability to complete in the global market,
and embrace the opportunities these initiatives provide for
selling more into the 25-nation EU marketplace immediately.
Secondly, to ignore these directives is to invite a loss of
market share, inventory write-downs due to non-compliant
products in warehouses, and the costly retrofitting of
supply chains to enable a manufacturer to become part
of a compliant series of suppliers.
It's been Cincom's experience, however, that in attaining
compliance and using it as a foundation for growing
global business development as well as selling, service,
and support strategies, manufacturers have the potential
to fundamentally redefine their businesses. Think of
compliance to RoHS and WEEE as the foundations for
making supply chains more globally synchronized and
more aligned with and coordinated with other compliant
manufacturers. A network of compliant manufacturers
emerges then, and from that foundation, any of the
manufacturers comprising this group can in turn create
stronger go-to-market strategies. Here are examples of
several from manufacturing companies that have looked
to transform compliance into a foundation on which
lasting competitive strategies can be created:
General Electric - G.E. spent $1.5B on Ecomagination
in an attempt to significantly rebrand itself as an
environmentally friendly and "green" manufacturer.
This has helped the company throughout Europe and
continues to be fine-tuned throughout the compliance
strategies the company is using specifically on RoHS and
WEEE to gain greater sales.
Toyota- Producing cars in the United States that meet all
emission standards and those of the EU, Toyota pays $33
per labor hour versus $88 for General Motors. In addition,
lean manufacturing through the use of the Toyota
Production System (TPS) has given this auto manufacturer
the potential of being the number-one producer of
automobiles in 2007. There are immediate implications of
this strategy for Toyota today as well. For the first time, in
July 2006, they surpassed all of Ford Motor Company's
brands in unit shipments globally. Clearly, compliance and
lean manufacturing are working for Toyota.
IBM - Turning recycling and compliance into a sustainable
business model starts with the GARS unit of IBM collecting
20,000 end-of-lease machines each week and then either
reselling, refurbishing, or dismantling them, contributing
less than 2% to landfill. This recycling operation also
contributes several million in revenue to IBM's leasing
operations.
Sun Microsystems - Focusing on trimming down the
energy usage of its servers, Sun Microsystems invented
CoolThreads technology, which increases the performance
of its servers while dropping their energy consumption.
This creates energy savings for their customers,
contributing to lower operating costs and lowered lifetime
cost of ownership.
Fujitsu Transaction Systems - Heavily dependent on sales
throughout the EU, Fujitsu Transaction Services has
established itself as a leader in retailing, and is actively
using environmental regulations as an opportunity to
educate and solidify relationships with its retailing
customer base. Fujitsu's strategy of using regulatory
compliance as an opportunity to educate both their
customers and prospects have turned them into thought
leaders in the core markets they serve.
Global auto manufacturer - Developing a series of
strategies for managing the discontinuance of older and
end-of-life vehicles - which is also an EU regulation - this
manufacturer spent less than 1% of its total revenue on
complying RoHS regulations. Many of the company's
competitors are spending up to 4% of revenue on
compliance as a result of having to first get processes
connected with each other and the need for speeding up
the RoHS compliance efforts across their supply chains.
Hewlett-Packard - One of the first manufacturers to
embrace the concept of turning compliance into a
competitive advantage, HP was the first to define programs
specifically aimed at design-for-environment (DfE) objectives
in the context of new product development. Starting this
initiative in 1992, HP's efforts to be environmentally
compliant have made their transition to RoHS and WEEE
compliance to meet the EU directives much more
achievable given their experiences in this area. An example
of this is HP's strategies for recycling the tens of millions of
CRTs being retired from use throughout Europe. HP has
been asked to desegregate the most toxic components of
their CRTs and recycle the less-harmful elements. They've
been able to accomplish this using the processes put in
place from DfE initiatives over 10 years ago.
There are many other examples of manufacturers gaining
competitive advantage through compliance, and the one
take-away all of these companies share is a common focus
on using the regulatory requirements of the EU as the
foundation for transforming their supply chains and
approaches to selling. The essence of the lessons learned
is that those manufacturers that are turning compliance
into a competitive advantage look to integrate quickly
with other supply chains that have either achieved
compliance or are aggressively pursuing it. Finding those
supply-chain networks that are aggressively pursuing these
goals and when possible, joining them, is what the leading
manufacturers are doing today to speed their efforts at
attaining compliance.
It's been Cincom's experience that in
attaining compliance and using it as a
foundation for growing global business
development, selling, service, and support
strategies, manufacturers have the potential
to fundamentally redefine their businesses.
Why the Time for Compliance Is Now
In addition to the urgency surrounding compliance to
the RoHS and WEEE initiatives, when it comes to turning
compliance into competitive strength, the highestperforming
companies are more interested in streamlining
supplier- and customer-facing processes first, accomplishing
higher levels of quality second, and creating a more
secure information environment third. AMR Research
recently delivered a webinar titled "Compliance as a
Catalyst for Competitive Advantage," which provided the
following insights into global compliance spending in 2006
through 2010:
- Thirty-six percent of companies are working to
integrate and streamline their business processes,
and this includes supply chains, customer fulfillment,
and service.
The competitive benefits of compliance are driving
these companies to attain greater levels of inter-process
integration and use the investments in compliance to
take on the more difficult integration and process
redefinition tasks.
- Twenty-eight percent of companies are leveraging
their spending in compliance to deliver greater levels
of product quality. In the auto industry specifically,
product quality is such a critical product attribute that
any given model's reputation is made or broken in the
first 90 days of its launch. The focus needs to be on
ensuring product quality and compliance at the same
time to create a globally more competitive product. In
the case of auto manufacturers selling into the EU for
example, RoHS and WEEE have been part of their
supply-chain, manufacturing, service, and product
discontinuance plans for well over four years so far.
- Fourteen percent are using compliance as the
cornerstone for securing their IT environments.
Spending on securing networks and infrastructure
continues to show double-digit growth as an IT
spending category mainly as the result of security threats
originating both inside and outside organizations. Efforts
aimed at compliance as they relate to security deal with
the processes of recruiting, evaluating, and integrating
new suppliers into an organization"s supply-chain
network; the recruiting, validating, and promoting of
channel partners; and the protecting of intellectual
property and core information assets as they relate to an
organization's ability to compete. Compliance and
security are tightly coupled in many organizations due to
the need to keep the most critical information confidential.
This is especially the case in healthcare industries for
example. In the context of manufacturing, however, the
intersection of compliance and security centers on first
validating the components that comprise all products,
then defining recycling and disposal strategies to ensure
that the most harmful components to the environment are
discarded according to initiatives. Each company's
knowledge of these areas is a core competitive advantage;
no two companies will have the same strategies and
approaches to managing these processes.
- Eleven percent look to use compliance spending to
synchronize supply globalization efforts. From the
best-practices examples of companies earlier in this
paper, it's clear that "going your own way" works when it
comes to creating compliant supply chains. The key
lesson learned from these companies that are attaining
best practices in compliance management throughout
their supply chains is that they take a very systematic
approach to creating, sustaining, investing in, and
strengthening supply-chain compliance. It is much too
large of a task for any manufacturer or global
organization to take on alone; the companies
accomplishing this adopt more of a strategy of joining
efforts with suppliers that are ahead of them in terms of
compliance to directives, with RoHS and WEEE being at
the forefront of many manufacturers' efforts today.
- Ten percent are leveraging compliance spending to
gain greater visibility into operations. This translates
into visibility three to four layers deep throughout their
supply chains and the ability to better sense and respond
to demand signals both in terms of purchase orders and
fulfilling custom orders as well. Compliance to the RoHS
Directive specifically nearly requires more accurate levels
of supply-chain visibility and a strong focus on having
greater control over the component's composition,
quality, sustainability, and recyclable content. Those are
all critical information elements every manufacturer must
know in order to fully comply with the RoHS Directive.
In addition, the defining of strategies to achieve WEEE
compliance is also dependent on having a strong
knowledge of the composition and recyclable attributes
of each product's many components. So while only 10%
of manufacturers according to AMR Research are
leveraging compliance spending to gain greater visibility
into their supply chains, this figure doesn't reflect the
pervasiveness of the need for this level of transparency
and visibility throughout many manufacturing industries.
It is Cincom's experience that the more manufacturers
embrace making their supply chains more transparent,
the greater the ROI and the higher the level of agility
and ability to respond to change.
The bottom line is that when manufacturers are looking for
a catalyst to bring major change into their organizations,
compliance to RoHS and WEEE Directives is a potent
motivator.
RoHS: a Global Call to Action from the EU
As of July 1, 2006, the EU requires manufacturers selling
into their 25 member nations to restrict the content of six
specific substances in both products produced in-country
and those imported - either in subassembly or final-product
form. The six specific substances are:
- Cadmium (Cd)
- Hexavalent chromium (Cr [VI])
- Lead (Pb)
- Mercury (Hg)
- Polybrominated biphenyls (PBB)
- Polybrominated diphenyl ethers (PBDE)
The content limits for these substances have been defined by the EU as:
- 0.01% Cd in homogeneous material
- 0.1% Cr (VI), Pb, Hg, PBB, PBDE in homogeneous material
The EU's RoHS Directive defines homogeneous material
as material of uniform composition throughout that cannot
be mechanically disjointed into different materials.
Examples of such materials are alloys, board resins,
ceramics, plastics, coatings, glass, metals, and paper.
"Mechanically disjointed" materials can, in principle, be
separated by mechanical actions such as unscrewing,
cutting, crushing, grinding, and abrasive processes.
For example, any semiconductor package contains many
homogenous materials including plastic molding material,
tin-electroplating coatings on a lead frame, lead frame
alloy, and gold-bonding wires. Lead is the RoHS restricted
substance used most often in electrical circuits for
example. It completes viable electrical connections either
in solders or between the semiconductor die-and-carrier
within integrated circuit Flip Chip packages.
Manufacturers' strategies for compliance as it relates to
these substances rest heavily on an enterprise-wide
approach to data collection throughout the sourcing,
supply chain, and traceability of production lots or in the
case of semiconductors, foundry yields, throughout a
global supply chain. There is also the critical need for
showing component replacement at any point in the
supply chain, production, or servicing workflows for any
manufacturer selling into the 25-nation EU marketplace.
Implications of WEEE in 2006
Waste Electrical and Electronic Equipment (WEEE)
is a series of regulations that apply to all electrical and
electronic equipment powered at up to 1000Vac or
1500Vdc and placed on the market in EU member states.
These regulations fall into any of 10 product categories,
unless the equipment is part of another type of equipment
that does not fall into any of these categories. The 10
product categories are mainly but not exclusively consumer
products, but some industrial products are also in the
scope.
Manufacturers must have plans in place for each of the
following activities to comply with the WEEE standard:
- Financing the collection of obsolete and out-ofcompliance
products
- Defining a treatment strategy for products that can be
brought into compliance with the WEEE standard
- Logistical and pricing plans that define the recycling
and recovery of all electronic waste
From a manufacturer's over-arching series of business
strategies, the core focus to provide for process-level
support to WEEE standards must include the following:
- Reverse logistics support through multiple layers of a
supply chain
- Support for per-lot tracking of electronic components
including semiconductors
- Support for supply-chain integration with order
management, service lifecycle management, and order
querying systems both from a presales and post-sales
strategy perspective
- Inventory tracking and in-transit analysis of shipments to
ensure greater visibility to components, subassemblies,
assemblies, and finished products pertaining to WEEE
compliance.
WEEE Directive's Exceptions
The Directive's requirements do not apply to the following
products that are deemed to be either in the national
interest of the United Kingdom or are of such fundamental
nature that they lend themselves more to disposal than
recycling. These products have been analyzed for the
WEEE Standards organization and have been exempted
from the Directive:
- Equipment intended specifically to protect the UK
national interest and for a military purpose, e.g., arms,
munitions, and war material
- Filament-based light bulbs
- Household light bulbs and luminaries
- Large-scale stationary industrial tool
- Surgically implanted medical equipment
- Infected medical equipment at end-of-life
Where Compliance Strategies Are Working
The following sections provide insights into where
compliance strategies are working, highlighting how
manufacturers sometimes turn extensive process reengineering
and high costs into a lasting competitive
advantage and often, cost and efficiency advantages.
Reorienting Supplier Relationships Toward Compliance
Intel's many efforts at RoHS compliance has permeated
their supply chains, enabling them to more efficiently plan,
produce, market, and service global markets. Intel's
supplier relationship management strategies illustrate best
practices in infusing motivation to adhere to RoHS and
WEEE compliance not only to avoid fines and lost
business, but to increase sales and broaden market
credibility throughout the global supply networks of which
these companies are members.
Supply Chain and Distribution Channel Implications of Compliance
Having attained the unenviable position of being the first
member of a supply chain to be penalized for lack of
compliance, Abacus Ltd. and its $6.1M write-down of noncompliant
RoHS inventory in the United Kingdom signals
that while the organizations regulating these activities
don't have 100% coverage and visibility into all activities
across all levels of supply chains, they do have the
authority to stop and fine any member of a supply chain
immediately.
Manufacturers that have the responsibility of ensuring their
supply-chain partners are aggressively pursuing RoHS and
WEEE compliance. This starts with discussions and reviews
of distributors, dealers, sales rep organizations, and valueadded
resellers regarding their strategies for returning
non-compliant inventories and quickly alleviating any risk
of non-compliance. If you're a manufacturer that relies
heavily on distributors that have a high percentage of their
inventories in at-risk RoHS and WEEE-compliant products,
insist on seeing their RoHS Compliance Plans. For many
distributors, these will have been in place for over 18
months.
Abacus Ltd. had prior-period inventories of products that
were not RoHS and WEEE compliant. In the process of
selling this inventory, the EU Enforcement teams in the
United Kingdom discovered the violation and required
Abacus to discontinue shipping of all non-compliant
products. The EU enforcement process is not allencompassing,
but rather it focuses on a combination of
market intelligence, random selection and products known
to contain materials of high concern. In addition, the EU
enforcement teams focus on products known to contain
materials of high concern, high volume and short-life
products as well as coordination of market and industry
intelligence with other member states.
The fact that a member of a supply chain is the first to be
cited for RoHS and WEEE violation also points to the
many areas where manufacturers need to improve the
performance of their supplier partnerships. Here are some
additional areas where manufacturers need to work on
better supply-chain integration and strive to create
stronger supplier relationship management strategies:
- Look to create higher levels of visibility over inventory,
and demand multiple layers through their companies.
- Ensure higher levels of forecast accuracy, and demand a
network-wide management supplier.
- Minimize inventory carrying costs, lower inventory
turnover, and increase accuracy of out-shipment data.
- Look to trim back on marginal suppliers that aren't
consistently delivering RoHS and WEEE compliance.
- Create higher levels of process and system
standardization throughout the entire supplier network
to ensure that compliance can be achieved by every
member of the supply chain.
- Create collaborative planning and forecasting strategies
that interlink suppliers between themselves,
manufacturing, and distribution centers to ensure
greater potential for the early warning of potential
violations. This needs to happen globally to ensure that
cross-shipments from one location to another don't
accidentally happen.
- Create a compliance scorecard to monitor, measure, and
modify supplier and channel relationship strategies. In
order to attain this, it's critical for manufacturers to
develop change-management programs that involve
suppliers, dealers, distributors, resellers, and sales-rep
organizations so that each stakeholder group has a
vested interest in the highest performance possible in
the supply chains and distribution channels. Incenting
change through increased sales and reducing the risk of
violating compliance is a strong motivator to create this
level of synchronization through both supply chains and
distribution channels.
Manufacturing Compliance Strategies
The many manufacturers that by necessity must adhere to
the RoHS and WEEE Directives are finding the following
as key lessons learned in initiating, sustaining, and
strengthening their compliance strategies. Cincom
considers these to be an evolving set of best practices as
they relate to manufacturers' compliance strategies:
- First, work with the Legal Department to have due
diligence completed on your company's potential
exposure. Having a legal strategy is essential as
products shipping today will need to be in compliance
with the RoHS standard. Manufacturers attaining best
practices have these compliance strategies in place and
also have found that working with key suppliers on
sourcing only RoHS-compliant components greatly
simplifies compliance strategies through distribution
channels.
- Create a corporate-wide compliance team that
includes C-level executives. This is another critical step
in that for many manufacturers, the concept of how to
change is just as important as the why of changing. The
evolving best practices in this area include having a Clevel
executive spearhead the corporate-wide
compliance team and staffing it with members of
Engineering, Quality Assurance, Logistics, Marketing,
and New Product Development. This is critical for the
success of RoHS compliance efforts.
- Define to the product level your company's exposure
to RoHS and WEEE compliance. The first task of the
compliance team needs to be the definition of an
RoHS/WEEE Product Roadmap with risk assessments
defined for each specific product. These risk
assessments are focused on the areas of revenue and
profit implications of rapid product compliance, creating
when necessary product re-launch strategies for RoHScompliance
and most critical, the synchronization of
efforts with supply-chain and distribution partners as it
relates to RoHS compliance influencing sales and
inventory strategies.
- Qualify suppliers and validate their RoHS compliance
plans. As mentioned earlier, this is a critical step in the
development of compliant supply-chain strategies and
needs to be the focal point of the compliance teams'
efforts.
- Aggressively pursue a supply-chain material
declaration process including the use of
questionnaires to capture all needed information.
This is another critical step as the RoHS directive
requires manufacturers to be fully informed as to the
substances in all of their products. Companies attaining
best practices in this area are using material-declaration
questionnaires and need to be tracked as part of a
broader compliance management system.
- Perform statistically significant testing of incoming
components and finished products to validate
compliance efforts. The strategies defined by the
corporate-wide compliance team need to center on
sampling for each of the RoHS substances and then
tracking these results and publishing them internally.
- Creating an enterprise quality and compliancemanagement
strategy differentiates those
manufacturers that are attaining best practices.
From the many steps toward creating internally
synchronized, yet agile processes for staying in
compliance, the highest-performing manufacturers are
also aggressively pursuing an enterprise quality and
compliance-management strategy to capture, organize,
and quickly interpret and act on compliance-related
knowledge gained.
Managing Customer Relationships to Compliance
Given the fact that all manufacturers producing products
that are influenced by the RoHS sense risk on compliance
relative to suppliers and channel partners, it's a very good
idea to share RoHS compliance statistics with your OEM
and distribution customers. Companies attaining best
practices in enterprise quality and compliance
management practice sharing results extensively with all
levels and types of customers. Consider this an
investment in customer relationships and transparency of
your operations aimed at serving them.
Summary: Compliance Is Revolutionizing Value Chains
The many steps toward compliance suggested throughout
this paper underscore the need for manufacturers to
urgently pursue enterprise-wide quality and compliance
initiatives. The key lesson learned is that processes
surrounding sourcing, supplier relationships, manufacturing,
fulfillment, and customer management all must be
coordinated toward the common goal of compliance
being very visible throughout an entire value chain.
Creating a Compliance Strategy: Intel's Lessons Learned Globally
In 2000, Intel began its RoHS and lead-free compliance
efforts to ensure that all products being sold into the EU
would be compliant by the July 1, 2006 deadline. There
are additional compliance laws being enacted in the state
of California and throughout the Asia-Pacific. China is
considering adopting the RoHS standard within the 2007
time frame as well.
For Intel, the challenges were particularly acute since
many of its components contain lead and other
substances that are prohibited under the RoHS directive.
Intel's approach was to create an RoHS compliance crossfunctional
team and attempt to be the first major
semiconductor and microprocessor vendor to attain RoHS
compliance within its manufacturing processes. Second,
Intel focused on the task of creating a sustainable and
stable series of suppliers they could work with that also
had RoHS compliance efforts in progress.
Through the use of enterprise quality and compliancemanagement
efforts, Intel accomplished the following:
- Lead reductions of up to 95 percent across the
company's product line and 100 percent in selected
products.
- Introduction of the first lead-free wirebond ball grid
array (BGA) package.
- First lead-free flash memory products.
- First RoHS-compliant network interface card that is leadfree
in the second-level interconnect (SLI).
- Greater supply-chain visibility and compliance
throughout the entire supply-chain network that is
dominated by Intel product demands.
- Compliance programs and training throughout
distribution channels including both OEM and direct
sales forces.
- Extensive use of engineering specifications and chemical
analysis reports for all RoHS at-risk products.
The Bottom Line: Compliance Pays
For the manufacturers attaining best practices in
enterprise quality and compliance management, their role
as innovators of processes that influence and interact with
supply chain, purchasing, sourcing, manufacturing, and
fulfillment all need to be synchronized through an
enterprise-wide quality and compliance-management
strategy. All of the data generated needs to be organized
and turned into strategies for accentuating higher levels
of competitiveness.
These manufacturers attaining best practices are going
after compliance by looking at the intersection of business
process management and the need for having greater
visibility into their supply chains, manufacturing processes,
and distribution channels. RoHS compliance efforts have
in the case of leading manufacturers - including Intel -
actually revolutionized their component, semiconductor,
and microprocessor businesses while attaining RoHS
compliance in the process.
Combining business process management and efforts
toward regulatory compliance is delivering stronger-thanexpected
competitive advantages for those companies
that are aggressively pursuing a company-wide
compliance strategy. At the center of these efforts, is the
need to take the lessons learned and create sustained
competitive advantage through the use of enterprise
quality and compliance-management strategies.
Combining business process management and efforts
toward regulatory compliance is delivering stronger-thanexpected
competitive advantages for those companies
that are aggressively pursuing a company-wide
compliance strategy. At the center of these efforts, is the
need to take the lessons learned and create sustained
competitive advantage through the use of enterprise
quality and compliance-management strategies.
Combining business process management
and efforts toward regulatory compliance
is delivering stronger-than-expected
competitive advantage ...
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registered trademarks of Cincom Systems, Inc. All other trademarks belong to
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© 2006, 2007 Cincom Systems, Inc.
FORM CM060725-1 3/07
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