Office: 4068 Overlook Trail Dr., Roanoke, VA 24018
email to: B3@bcubedconsulting.com
Product Stewardship Topics
Compliance/Legislation/Substance Bans/Material Substitutions
How do we change to a compliant material?
Since the EU passed the first sets of product legislation, companies have had to deal with material substitutions. Especially for complex durable goods, this requires analysis of alternate materials for:
reliability & performance tradeoffs
obsolescence planning and
Now, with global legislation and overlapping, and sometimes competing relability/cost concerns, it is even more important to not waste time in the evaluation phases. Essentially, do it right the first time.
Change is hard, and it is important to get Engineering, Operations and Purchasing engaged properly. Otherwise, one might pick a substitute that is becoming obsolete itself, doesn't transition into production well, or is very costly.
I've had success with eliminations of 'bad' substances such as lead in glass, hexavalent chromium in plated metal parts, mercury in displays, lead solder, and phthalates. Let me help get your team engaged to pick your best substitutes and establish processes as more change is inevitable.
"What can I say about Brenda B Baney?
Brenda is very knowledgeable in restricted materials and their regulations. She has been a strong contributor and leader in AIAG activities. An excellent team member and a pleasure to work with.
Is testing needed?
That sounds expensive!
Answers to Compliance Questions
Compliance/Legislation/EU REACH/Substance of Very High Concern
What is an SVHC?
SVHC's or Substances of Very High Concern are legislated by Europe as part of their REACH program. Under REACH all substances within imported materials must be registered by EU Chemical manufcaturing companies or importers if volume thresholds were above a certain limit. This started over a decade ago for 'pre-registration' (all companies rushing to divulge their chemical recipes?) with then mandatory, fee-based data for above 1000 tons/yr (per country) in 2010. Next was 100 - 1000 tons, and starting May 31, 2018 if your company imports over 1 ton of any chemical substance on the list, it must be registered by the material manufacturer or you. There is also a provision requiring targeted substances in use in products to provide 'safe use' information to consumers and business customers as you place the product on the market. New substances are added when EU countries submit a dossier and evaluation the substance may be banned or restricted for only authorized uses.
From the recent ECHA Downstream Users Guidance about communication along the supply chain: REACH reversed the burden of proof concerning the safety of chemical substances: it is now up to manufacturers, importers and downstream users to ensure that they manufacture and use chemical substances in a way that does not adversely affect human health or the environment.
This is a complicated process, and what is important is that the list of these SVHCs has grown from the initial 15 in 2008 to over 400. There are requirements for communication of the presence of these substances to end consumers and also to any EU customers if found above a threshold. A 2015 ruling further complicated matters by requiring consumer notifications on the individual part level(rather than for the as-sold assembly). Full guidance documents are in-progress. If you have customers selling into the EU market, it is certain that you will be required to disclose the presence of any SVHCs.
There are many other compliance questions and answers depending on your product, your market, and your customers. Do you have questions about:
EU End-of-Life Vehicle Directive
China REACH and RoHS
California Proposition 65
Establishing A Material Data Collection and Reporting Process
Meeting Customer & Industry Needs
Compliance/Legislation/Customers/Material Data Systems
What is the best Substance of Concern Software?
When a company is suddenly faced with the need to have substance data on all materials found in their products, it is tempting to go with either a turnkey solution or an add-on to an existing system. While either of these might be a good approach, it may be better to do a quick evaluation first.
The type of data collection and reporting process that will be best for your company depends on a lot of factors. Here are what I believe are the top 4:
Product type & complexity
Main customers & industry
National, Regional or Global sales
For example, if you're a smaller company to an electronics distributor, you may only need to state compliance to one legislation for all products. For many consumer-facing corporations, their suppliers must divulge detailed product and material recipes. It will depend on your product complexity, and the breadth of your product line(s). It will also depend on the types of customers, and their requirements (consumer, medical, military, etc...)
The best system for your company will opimize resources overall. If you do not take a big picture approach, it is possible that the burden may fall more heavily on one part of your business (Engineering or Purchasing) and the overall bottom line will still be costly. Let me help you design a system that satisfies your compliance data needs now and in the future, while efficiently utilizing your current structure.
Brenda is a true professional with a network that can support any technical inquiry. Her deep technical expertise shines through in every aspect of her work and her desire to support the customer is first class. She is a person that wants only the best for her customers. Reliable and intelligent with a great sense of humor
How do I respond to customer inquiries?
Sometimes your customers are also struggling with the right approach to meet their product environmental requirements. They may send you a letter asking you to state "All of my company's products meet Legislation XYZ", or to enter data into a system you've never heard of, or possibly even to have your products tested at a laboratory and provide elemental data. If your company tries to handle these one at a time without a systematic approach, it could be very costly.
The first step is usually determining what requirements were in the contract, and verifying the request. See the section above for factors determing which type of system might be best for your company in order to address all of your customers and your company's compliance needs.