Category Archives: Supply Chain Materials Data Management

What is Product Stewardship, Exactly?

Posted on by

What does product stewardship mean in the business world, exactly? Sometimes it seems to indicate product end-of-life measures, specifically regarding electronics or e-waste policy. Sometimes it is defined as a person to make sure a product is RoHS compliant or otherwise is clean of toxic chemicals such as lead, cadmium and mercury.  Other times it seems to mean a more Sustainability Manager type of role. The fact is that product stewardship can contain all these things and more.

We recently came upon this job description for a Product Stewardship position. We’re running it here to show specific job requirements.

Product stewardship job description. DuPont defines product stewardship as “a principle that directs all participants involved in the life cycle of a product to take shared responsibility for the impacts to human health and the natural environment that result from the production, use, and end-of-life management of the product.”

DuPont, for instance, and this is not atypical, approaches product stewardship through the American Chemistry Council’s Responsible Care program. DuPont sees product stewardship as an “inclusive effort that considers the interests of all important stakeholders, including customers, regulators, academics and advocacy groups.”

Product stewardship software. Product stewardship software is more or less a “steroid infused” chemical counter — or substance audit platform — with the added twist of:

  1. Automating chemical data collection from suppliers.
  2. Screening materials and B.O.M.s against regulatory lists vis a vis REACH, RoHS, WEEE, Prop 65.
  3. Functions such as MSDS distribution.
  4. Other document and agency reporting management.

Increasingly, product stewardship personnel is required to have expertise with related software, just as Finance Administrators are required to have familiarity with financial systems.

DuPont’s Product Stewardship Job Description
DuPont says its vision is to be world class in Product Stewardship and Regulatory efforts and to be recognized as a key contributor to DuPont business success through the development and management of safe, sustainable products.

The average product stewardship annual salary is said to be around $85,000 by Glassdoor.com, but if the regulatory compliance piece is taken seriously it is often higher, into the low six figures. The salaries are respectable relative to other “fields of green,” but there is still some insecurity around how long companies will nurture the stewardship side of manufacturing — so the tenure of these positions, like the tenure of so many positions these days, is indeed a question mark.

Product Stewardship Focus Areas and Responsibilities

  1. Provide a variety of consulting services to the businesses in areas such as the determination of product misuse, product safety, health hazards and potential environmental impacts. Other areas may include advising the businesses on appropriate labeling requirements; facilitating the auditing process at toller, manufacturer and other partner locations and the analysis of public perceptions and reactions to the businesses products.
  2. May oversee implementation of the Responsible Care Management System and Corporate Product Stewardship standards.
  3. May obtain, organize and assemble data and information from various internal personnel, databases, external sources, etc. to enable global regulatory submissions.
  4. Understanding regulatory requirements and the purpose of submissions to ensure compliance with national and state submission requirements.
  5. May Prepare forms, letters, labels and other documents necessary for regulatory submissions.
  6. May develop MSDSs that comply with local standards.
  7. Assisting in the preparation of responses to inquiries from regulatory agencies, customers, internal DuPont personnel, and others.
  8. Assisting in the management of products and/or regulatory projects, including the independent management of sub-projects.
  9. Monitors and analyzes regulatory trends and positions of industry and stakeholder groups.

Job Requirements

  1. Strong networking and leadership skills.
  2. Chemistry, Biology, Science, Public Health, Occupational Health, Toxicology, Environmental Science degrees preferred.
  3. Outstanding problem solving, analytical and interpersonal skills.
  4. Excellent writing/verbal communication and presentation skills.
  5. Accomplished computer skills including Microsoft office and applications and database experience.
  6. Strong work ethic and the ability to work in cross-functional teams to deliver concrete project deliverables in a timely manner.

DuPont says it is an equal opportunity employer, and as of now this job is posted here but these posting come and go so don’t be surprised if the link is broken. We’re not in DuPont’s HR department; we just want to illustrate what product stewardship looks like.

Should Whistleblowers Get Leave With Pay?

Posted on by

Nobody likes a tattletale, a gossip or a rat. You can lose the trust and respect of your co-workers pretty quickly by stepping out of line that way.

With that in mind, it’s highly unlikely that the US Occupational Safety and Health Administration’s (OSHA) revision and overhaul of its “whistleblower” program will affect much.  The effort did purge some backlog and, yes, it does aspire to make the process of reporting a safety fail quicker and easier going forward.

But there’s still one elephant in the room.

Why workers don’t report safety issues. What I’ve never heard anyone say about whistleblowing is something so basic that I wonder if rulemakers miss it.

The fact is that most workers today live paycheck-to-paycheck, or very close. And if their section of the manufacturing, construction or mining project is shut down while a reported safety issue is inspected or fixed, there is no paycheck coming in. A project suspension or furlough is a pay freeze. Not just for the person who reported the safety breach, but for coworkers. Who wants to be responsible for family, friends and neighbors losing their income?

For most of American workers, work is about making sure there’s food on the table each week for the family. After food and water, there are clothes, medical bills, educational expenses, plus payments to banks a la my own well-documented pet peeve: the incomprehensible DEBT that a typical working family carries in this country (mortgage and auto), plus mandatory miscellaneous payments (insurance and alimony) that must be honored each month.

That’s a lot to risk just to report a potential safety issue.

There are also well-documented issues on the importance of respect and community in the workplace; and whistleblowers typically aren’t the most welcome folks on campus after the fact. But what do you stand to gain by reporting a safety fail? Maybe it gets fixed, maybe not. And what do you stand to lose? Everything.

A recent Food & Drug Administration law takes strides to protect whistleblowers, and now OSHA is doing same, but without a salary protection plan these measures won’t inspire workers to feel more confident about reporting safety breaches.

Good effort.  But missing the mark.

Why Young Executives Leave

Posted on by

Guess who’s not coming to dinner? Young executives aren’t, not if your company is serving up lumbering, frustrating Enterprise Resource Planning (ERP) or other enterprise level software.

In a recent supply chain software survey, more than 65% of respondents, executives age 35 and younger, said they would be at least somewhat likely to change jobs due to negative experience using their company’s enterprise software. That’s right: They’d leave because the software stinks.

When you first read that, it’s surprising.  After a few seconds, it  makes sense.  Software is such a huge part of the working experience now. It’s no longer enough that software “does the job.”  It has to be non-frustrating to use and make sense. The next generation of managers and executives insist on both; they will leave the company if the tools aren’t up to par.

The Chief Technology Officer (CTO) and the Information Technology (IT) department itself should take heed.  Things are changing fast — the roles of both the Officer and the Gentlemen in IT are being re-evaluated as data management evolves and Generation Y moves into management.

Generation Y software.“Today, if you’re providing software at the enterprise level, it’s important that the software handles modern data challenges, demonstrates immediate benefits, and be almost so easy to use that users don’t give the technology much thought,” says Chris Nowak, a “GenX-Y” software industry veteran.

“Brand loyalty in enterprise software these days,” Nowak says, “ironically comes from a tool being so effective that customers give you hardly any thought at all.”

“Employers invest in attractive offices and other benefits designed to attract and retain young talent, but this study makes it clear that the enterprise software people use every day has a significant impact on the quality of life for today’s professionals,” IFS North America Chief Technology Officer Rick Veague said. IFS is the company that sponsored the survey.

The next generation of executives won’t put up with stinky software.

Using Spreadsheets Instead of Modules?

At first glance, there seems to be no harm in employees using a spreadsheet to track data, say, for materials in a supply chain, right?

Actually: the entire point of ERP and relational database-driven SaaS modules for any kind of data management, from HR to MSDS to chemical components, is that in a database there is a single instance of accurate data.

“The single instance of data is then nurtured (maintained and updated) by multiple qualified and permissioned users,” explains Nowak.  “This consolidates resource man-hours and eliminates waste in the form of duplicate and outdated versions of the data.”

If 10 employees are using their own spreadsheet and 15 others are using the ERP — there can be no central, single instance of data; at best there will be 12 instances of data. Multiple instances of the same data undermines the point, and the efficiency, of data management systems such as the ERP.

An Unexpected IT Solution: Dismantle the IT Department.An esteemed senior analyst at Gartner, Jim Shepherd, recently wrote in First Thing Monday that the Information Technology (IT) department should be dismantled.

The IT department is a thing of the past, Shepherd argues (persuasively).

Instead of IT being its own department making choices for the company, Shepherd proposes that IT should be selected and paid for at the department level. That would put the power and the onus of choice on the heads of those who actually use it. This would increase engagement and decrease costs, in theory. It could result in fewer young executives skipping out of the company altogether due to poor fare.

If you can gain access to the FTM column, it’s worth reading. (Gartner, Shepherd, Do You Really Need an IT Department Anymore? June 27, 2011)  The follow up column on July 18, 2011 is also worth reading — the follow up column suggests a slimmed down version of the IT department:

  1. a CIO for steerage/vision
  2. a single-digit headcount for scouting purposes/inter-departmental assistance
  3. a budget of .5% annual revenues (as opposed to the 2% – 5% that IT Departments now get)
  4. the excess revenue pool would be folded back into the business

Summary:  Human Resources (HR) ought take an interest in what IT is up to.  And IT should be aware that its ERP and other data management tool choices affect not just Ops and Finance, but also HR.

Implementing An Environmental Management System

Posted on by

An environmental management system (EMS) keeps companies competitive and helps improve environmental performance by assuring regulatory compliance, reducing operating costs, and increasing awareness of the environmental impact of the company’s activities. Any company that handles chemicals or multiple MSDS-worthy products should have an EMS Plan in place. Manufacturers find an EMS most urgent, but almost every business can benefit.

Planning. Before you implement the EMS, decide where the EMS will apply within your organization. Choose your environmental management representative (EMR), who acts as the project manager for the EMS. Select a team of experts, consisting of facility and city representatives. Build an implementation team of personnel from the “shop floor,” ensuring adherence to the EMS at all levels of your organization.

During the planning phase of your company’s EMS, you must define the environmental aspects and impacts. An environmental aspect includes activities, products, or services that interact with the environment (i.e., air emissions, energy usage). An environmental impact includes any change to the environment resulting from activities, products, or services (i.e., air quality changes, natural resource usage).

It’s also important to identify legal requirements and issues related to your company with regard to regulations and compliance issues.

Once you’ve completed your planning, you can develop the environmental policy, consisting of regulatory compliance, pollution control, and a continual improvement program. Your EMS should also include an environmental objective (i.e., reduce energy usage) and environmental target (i.e., reduce energy usage by a specific date). You should figure out who’s responsible for each objective and target, what resources are available (i.e., personnel, financial), and when milestones will be achieved.

Documentation and training. Determine which operational procedures require documentation, and locate documentation related to environmental aspects that may already exist. Work with personnel to develop new documentation, and don’t forget to include health and safety requirements.

Your environmental aspect list also helps you to identify your training needs. All employees should be trained in:

·        Environmental policy
·        EMS roles and responsibilities
·        Procedures and work instructions
·        Consequences of not following EMS requirements

Your company’s EMS must detail how to communicate internally, as well as how to request, obtain, document, and respond to external communication. Communication can include items such as your environmental policy, legal requirements, and objectives.

Preparing for emergencies. Part of the EMS should focus on how to prepare for emergencies, such as spills, and should identify which procedures already exist to help you properly respond to the situation.

Evaluating your progress. It’s important to periodically assess your EMS to see how much progress it’s making toward your environmental objectives and targets. Based on the following, determine whether the EMS was carried out according to plan:

·        Have you identified what to monitor?
·        Have you chosen the indicators/metrics?
·        Did you establish a schedule for monitoring?
·        Did you document the process?
·        Have you communicated the information?

Auditing your EMS. Internal EMS audits review how well your company is meeting its objectives and targets by evaluating your procedures, documentation, programs, and implementation. The audit also determines whether your company is continually improving.

·        Prepare for the audit with planning, resource allocation, and determining audit objectives
·        Examine documents and records; identify conditions that require immediate action
·        Prepare and submit the report to management

Management action items. Management personnel decide whether the EMS is working efficiently, and whether changes or improvements are needed. Management should review the EMS process, determine what to evaluate, document the process, and record the outcome of the review.

More information. The Public Entity EMS Resource (PEER) Center (peercenter.net) offers tips on developing an EMS for your company — a good reference.

Guest blogger Laura Chidester has worked as a technical journalist for over 10 years.  By day she manages the documentation team at Actio Software Corp. while continuing to report on broader industry and environmental trends.

China Repeals Policy That Favors Chinese

Posted on by

We’ve blogged about China before (see China Is More E Than E-Waste These Days).

In his article for Harvard Business Review called “What’s Wrong With America’s Innovation Policies,” Bruce Nussbaum talks about China’s “Fast Follower” innovation policy and how it’s a combination of state-driven policies that:

  1. require Western companies to partner with Chinese firms to do business
  2. demand transfer of the latest technologies in exchange for access to markets
  3. favoring “indigenous innovation” in government purchasing; fencing off green and other industries from foreign competition
  4. offering low-interest state-bank loans to local champions

Well, China has now repealed the technology policy that favored Chinese producers in government purchases of computers and other tech goods.  The policy was at odds with World Trade policies but was in place for a long time anyway.  This announcement from the Chinese Finance Ministry is the second time in a month that Beijing repealed a technology policy after complaints by its trading partners.

The Associated Press is now reporting that a brief ministry statement late Wednesday June 29 said the Chinese government would no longer enforce procurement rules that are part of a decade-old “indigenous innovation” campaign to spur domestic technology development.

“This repeal represents a forward step toward leveling the playing field in the government procurement market in China,” said Davide Cucino, president of the European Union Chamber of Commerce in China, in a written response to questions, as quoted in Product Design and Development.

Still, a great place to be in regards to profiting from China’s economic surge is, interestingly, in Education.  Parents sending their children to study in the U.S. is an insurance policy that many Chinese these days are purchasing.  While the trade playing field appears to be leveling on one hand, some argue that China is edging closer to a police state type of nation — leaving the educated, competent and savvy once again looking Westward for quality of life.

A Single European Railway: On The Right Track

Posted on by
A locomotive rolling down the track (photo by Migro)

The Council of the European Union (the Council) announced last week that it has reached agreement toward a directive that would establish a single European railway area.

This would-be directive is a recast of the so-called “first railway package.”  The approach consists of three* directives:

  • The development of European railways.
  • Licensing of railway undertakings.
  • Management of railway infrastructure.

“The purpose of this recast is to simplify, clarify and modernise the regulatory framework for Europe’s railway sector so as to improve conditions for investments, increase competition and strengthen market supervision in that sector,” said the Council in a statement.

Goals of the new EU railway directive. Goals of the new directive include:

  • All companies having equal access to rails.
  • Greater cooperation between regulatory bodies on cross-border issues.
  • Improved financing as a result of long-term planning/stability.
  • Incentives to modernize railway infrastructure.

In particular, the agreement reinforces the independence of railway infrastructure. This includes:

  • Railway stations.
  • Freight terminals.
  • Maintenance facilities.

The idea is to get to operational independence from the companies that use that infrastructure. The separation could be critical to allowing all companies to have nondiscriminatory access to railway-related services.

The agreement last week means that the Council agreed on basic rules for European railway and railway infrastructure companies. The basic rules would enhance investment and improve market supervision and — in theory — increase competitiveness.  The new legal act aims at improving competition between railway undertakings by making rail market access conditions more transparent.

Innovation vs. competitiveness. To wit, last month the U.S. Federal Railroad Association and U.S. Transportation Secretary Ray LaHood announced $2 billion in high-speed rail funds which would serve as an unprecedented high speed rail investment.  The money is intended to:

  • Speed up trains in the Northeast Corridor.
  • Expand service in the Midwest.
  • Provide new, state-of-the-art locomotives and rail cars.

In the first quarter 2011 there was a lot of rustling in Europe about innovations and vision, especially regarding for the railway (see High Speed Rail from London to Beijing in 19 Hours).

Suddenly the buzz has shifted in Europe to the subject of competitiveness.  In fact, on June 27, 2011 there will be an Extraordinary Council meeting on the subject of Competitiveness in the Internal Market, Industry and Research and Space. The meeting will be in Luxembourg (view agenda).

The new rail directive agreement: on the right track. Under the new Railway agreement, the rails would be more competitive with other transport options and national regulatory authorities would have more power. Specifically, regulatory authorities would have the power to impose sanctions/penalties and to audit implementations of the railway directive. Cooperation between regulators on cross-border issues would be a goal, not an exception.

This type of longer-term planning is the cornerstone of improving financing of rail infrastructure, as it will offer more certainty to investors. The directive will provide incentives to modernize infrastructure, which is the best way to make sure it happens — no one spends multiple-million euros unless provoked — at least, I probably wouldn’t.

The Recast is known in e’er-pleasant-but-airy EU-speak as the “general approach.” Last week’s agreement by the member states enables the Council to start negotiations with the European Parliament.

The European Parliament, whose approval is required for the adoption of the directive, has yet to establish its position. Parliament is expected to convene on this subject in July and September.

Again: in the last quarter there was a lot of rustling in Europe about innovations and vision, and there is now a lot of rustling on the subject of competitiveness in Europe. Are the two complementary? We’ll find out.

*For specifics on the three ingredient directives, see directives Nos. 12, 13 and 14 of 2001.
For more see http://www.consilium.europa.eu/uedocs/cms_data/docs/pressdata/en/trans/122809.pdf

Europe Gets Serious about Standards

Posted on by

Consumers should not be obliged to change several chargers for their electronics devices. And a mass diffusion of electric cars will not happen without common standards for their recharge. Mobile phone or software companies are publicly showcasing their battle for the leadership of their respective standards.

In an era of increasing global competition, European competitiveness depends on the EU’s ability to foster innovation in products, services and processes and fully exploit the potential of the Internal market.  Standards are a decisive tool in international competition, a cornerstone of industrial policy and — sometimes — innovation.

We say “sometimes” because of the Great Operating System (OS) wars of the 1990s in Silicon Valley, where Unix, Apple’s Mac OS, and IBM’s OS2 battled it out. And those of us using the products would grumble constantly about a standardized platform (remember when your Windows Word doc wouldn’t open on a Mac?).

We were right to grumble. But you can’t say that innovation suffered for those lack of standards — in fact, arguably innovation flourished there.

Standards in manufacturing. But when you try to sell me a $30,000 electronic automobile and tell me I can’t use half the recharging stations on my route from here to Los Angeles because of lack of standards on the equipment, we may have a deal breaker.  Truly, in a B2C market, standards become more compelling.  (The race for market share for the Computer OS’s was largely fought in terms of corporate contracts.)

Or more accurately, in the B2C market, standards become more compelling more quickly.  One IT fix can solve a dual-platform problem for an entire company or 1000 employees, but 1000 individual consumers have no fix, and therefore, end up struggling to see the value.

In Europe, now, in a time of:

  • increasing global competition
  • an ageing European population/workforce
  • fiscal restraint.

European competitiveness may depend on their ability to foster innovation in products, services and processes and then to drive those innovations forward. A systematic approach to research, innovation and standardization adopted at European and national level would likely help best ideas to reach the market and achieve wider market audience quickly.

We call it globalization. And here are the steps the European Commission says it will take toward this end:

  1. The Commission will establish an annual Work Programme, which will identify priorities for European standardization
  2. The Commission will demand that European standards for innovative products and services will be quickly elaborated and adopted, for example in the field of eco-design, smart grids, energy efficiency of buildings, nanotechnologies, security and eMobility
  3. The Commission will make funding of the independent European standardization bodies (ESOs) conditional on certain performance criteria. In particular European standards should be adopted more quickly
  4. When European standards with a scientific component are to be incorporated into EU policy, impartial, sound and balanced scientific evidence will increasingly be taken into account
  5. ESOs, Member States and other standardization bodies are expected to improve awareness and education about standardization
Standards (metric or imperial?) in the EU

The European Commission proposes a series of legislative and non-legislative measures to develop more and faster standards. Standards are sets of voluntary technical and quality criteria for products, services and production processes. Nobody is obliged to use or apply them but they help businesses work together and to save money for consumers.

The European Council of 4 February, in its conclusions on the “Innovation Union”, invited the Commission “to make proposals to accelerate, simplify and modernize standardization procedures, notably to allow standards developed by industry to be turned into European standards”.

European Commission Vice-President Antonio Tajani, responsible for industry and entrepreneurship said: “[S]tandards allow us all to have the best quality and sustainable products for a lower price. Standardization is also a key issue for the well functioning of our internal market.”

Here are important steps that the Commission took recently to strengthen the system of standard-setting in Europe and to implement related commitments:

  1. Europe will push for more international standards in those economic sectors where Europe is a global leader
  2. High-tech products are often sold in combination with maintenance services. Although there are many European standards for products, there are hardly any for services. Therefore, more market-driven European standards for services could be developed giving companies commercial advantages
  3. To propose a light and fast way to recognize the increasingly important ICT standards developed by global ICT standards development organizations, such as those underpinning the internet, to be used in public procurement, EU policies and legislation. This will stimulate innovation, cut administrative overheads and build a truly digital society by encouraging interoperability between devices, applications, data repositories, services and network
  4. The Commission will enhance its cooperation with the leading standardization organizations in Europe (i.e. CEN, CENELEC and ETSI) so that their standards will be available more rapidly. Businesses using these standards can make their products more compatible with other products so that consumers will have a broader choice at a lower price
  5. European standards will be drafted with the help of organizations representing those most affected, or most concerned – consumers, small businesses, environmental and social organizations
  6. The new standard for a universal mobile-phone charger to fit all models is a perfect example of the tremendous value of European standards for our daily lives
  7. Some of the proposed actions can be implemented immediately while the others require the approval of the European Parliament and the Council.

Good thing to keep an eye on.

India’s New Manufacturing Policy

Posted on by

The Indian government said in April it will soon unveil a national manufacturing policy, which aims at attracting overseas investments and increase the share of the sector in the economy. “India will come out with a national manufacturing policy within this year, hopefully before June,” Indian Commerce and Industry Minister Anand Sharma said recently. The country will also be taking other initiatives along with states to promote the manufacturing sector, Sharma also said.

“I hope, we will be able to do it soon,” Sharma said at a CII function in New Delhi.

The Indian government aims at increasing the share of manufacturing sector from 16-17%  to 25-26% of the GDP by 2020. It’s said that over 80% of the country’s overall industrial production is from manufacturing.

Sharma said that India’s first National Manufacturing Policy is in the works. It will likely include integrated “green-field” mega-investment zones to attract global investment and cutting-edge technologies.

India 2.0. Millions of skilled workers are expected to join India’s manufacturing segment in the near future. A good new policy would help attract those individuals as well as increased foreign direct investment into the country.

India’s exports this fiscal are likely to increase to $235 billion, from $178.6 billion in 2009-10. The new export strategy aims at doubling India’s exports to $450 billion by 2014.

On the proposed Anti-Counterfeiting Trade Agreement (ACTA), which is a new international treaty being framed by a group of developed nations, the minister Sharma declined to pursue that line of thinking.  He said India would not accept any such attempts to discuss intellectual property rights outside the multilateral WTO framework, as reported multiple journals in India. India is opposing ACTA, saying that it would have far-reaching implications for non-members of ACTA. The countries such as the US, EU, Japan, Australia, Canada and New Zealand are still evaluating the agreement.

“Few countries will group together and try to change what is and will always be a multilateral regime called the TRIPS agreement. If it has to revisited in any stage in future, it will be only in multilateral forum — the WTO — it cannot be done outside,” he added.

For reference, make a note of these links:

Confederation of Indian Industry: www.cii.in

Federation of Indian Chambers of Commerce and Industry: www.ficci.com

National Manufacturing Competitiveness Council: http://nmcc.nic.in

Useful Web Page for REACH Compliance

Posted on by

ECHA CHEM is a web page on the ECHA web site, itself notoriously difficult to navigate. However, it must be said that improvements are appearing. The ECHA CHEM page is nearly comprehensible!  While intuitive may still be some ways off, at least extracting information about REACH on this page is not painful. For readers interested in REACH news and REACH compliance tools, we are running this breakdown.

ECHA CHEM in a nutshell. The REACH Regulation (or REACH pandemic?) provides that various types of information submitted to ECHA or documents that are produced as an outcome of different REACH processes are to be published on the ECHA website. Under the ECHA CHEM web section you will find public information and documents from REACH processes as they become available.

Registry of intentions. This Registry provides information on the Intentions of the Member States to submit proposals for harmonised Classification and Labelling of substances, proposals for identification of Substances of Very High Concern, and proposals for restrictions.

List of pre-registered substances. The REACH Regulation requires that ECHA will publish by Jan. 1, 2009, a list of substances which have been preregistered between June 1 and Dec. 1, 2008.

Authorisation. The two first steps of the authorisation procedure are the identification and inclusion in the “Candidate List” of Substances of Very High Concern, and the prioritisation of substances to be included in Annex XIV of REACH (the “Authorisation List “).

Candidate List of Substances of Very High Concern for Authorisation. In the framework of the authorisation process, Member States Competent Authorities or the ECHA, on a request by the Commission, may prepare Annex XV dossiers for the identification of substances of very high concern. The outcome of this identification procedure is a list of substances (“the Candidate List”), which are candidates for eventual inclusion in the List of Substances Subject to Authorisation (Annex XIV of REACH).

Annex XIV recommendations. The REACH Regulation requires that ECHA identifies from the “Candidate List” priority substances to be included in Annex XIV of REACH (the “Authorisation List”) and then recommends Annex XIV entries for these substances to the European Commission. ECHA submitted its first recommendation to the European Commission on June 1, 2009.

Information from registration dossiers. ECHA is publishing information on substances and their properties from the registration dossiers submitted to ECHA.

Transitional measures regarding existing substances. The REACH Regulation provides transitional measures for certain existing substances under Regulation (EEC) No 793/93. These substances were prioritized due to being produced in large quantities or having possible persistent, bioaccumulative and toxic properties.

ECHA publishes the Annex XV transitional reports on priority substances submitted by the EU Member States. For some substances, manufacturers and importers need to submit additional information to the Member State Competent Authority in charge. Updated assessments and so-called “voluntary risk assessment reports” will also be published there.

See it all:  http://echa.europa.eu/chem_data_en.asp

Green Chemistry: Sleeper Hit in Supply-Chain Compliance?

Posted on by

These days, environmental regulations are changing the rules of the game in terms of how things are made, sourced and distributed in manufacturing and supply chains. The rules define the product and the process. More so than ever before.

Green Chemistry might be the sleeper key to compliance

Regulations make the brand? Regulations such as REACH, RoHS, “China RoHS,” “China REACH” and WEEE have huge impact on finished goods as they move through a supply network.  The impact of regulation is felt in all stages:

  1. design
  2. procurement
  3. storage
  4. manufacturing processes
  5. waste procedures and
  6. product distribution.

This is true in aerospace, automotive, packaging — but especially true in electronics, ever more so as the electronics industry becomes increasingly plastic-oriented.

We’re talking about products increasingly defined and designed by environmental interests.

Electronic paper. Of course, late last week the electronics industry became paper-based, or paper-esque shall we say (origami telephones, anyone?) when BBC London announced the debut of the paper cell phone.  Yes, you read that right. It’s a cell phone made of electronic paper. You could make an airplane out of it and try to get your friend’s attention — rather than call.

Increasingly we see more regulations and faster creation to disposal cycles. So how can the electronics industry cope?

E is for Electronics, Environmental, and EHS. Regulations are usually either strictly Environmental regulations or Environmental, Health & Safety (EHS).  Categories of regulations in electronics manufacturing and supply include:

  1. fire safety
  2. toxic substances
  3. product end-of-life
  4. air quality.

The last one, air quality, is a hot topic right now but is no more important than toxic chemicals, end-of-life or fire safety in electronics manufacturing.  Air quality typically comes down to Hazardous Air Pollutants (HAPs).  HAPs as a class cause serious environmental fall out.  HAPs include:

  1. sulfur dioxide
  2. nitrogen oxides
  3. volatile organic compounds (VOCs)
  4. hazardous air pollutants.

Green chemistry might be key. Action to reduce emissions can be done either by converting the waste itself or by using cleaner ingredients to begin with.  The latter is at the heart of green chemistry.  Green chemistry in fact addresses most environmental regulatory concerns:  the greener the chemistry, the fewer the environmental regulatory concerns.

To find out about Green Chemistry without the struggle of navigating the California.gov web site, try GC3 or Green Chemistry Council out of University of Massachusetts-Lowell.  Under the “Publications” section there are some helpful documents, including case studies by big companies like HP and Seagate who are seeking environmental regulatory compliance worldwide through greener chemistry.  Read up, go green, and as always: track, track, track your data.

Because it’s critical to be compliant, it becomes key to be green.  Remember:  there is no substitute for year-over-year tracking data for demonstrating to shareholders just how green you’ve been.

Green Chemistry image (top) courtesy of Actio Corporation Communications, used by permission.