The Power of a Long-Term Compliance Strategy — With Full Materials Declarations

With voices louder than ever, governments and the general public are pressuring manufacturers to develop products that meet increasing regulations, as a means to protect the environment and people.   

Regulations spanning conflict minerals to REACH to Prop 65 and more require suppliers and manufacturers in industries such as automotive, aerospace, electronics, heavy equipment, outdoor power equipment, recreational vehicle and more to comply.  

Many manufacturers react to these calls for compliance. They send material declaration requests to their suppliers and fight tooth and nail to get the response they need to prove their compliance. Oftentimes, this amounts to suppliers providing a “no, the component does not include the substance on the list” type of answer.  

These case-by-case responses work in the moment. But then a new REACH, RoHS or Prop 65 substance list comes out — and the manufacturer once more must tap into its supply chain, and inquire about these new substances.  

While we cannot predict future new regulations or modifications to regulations, at this time, we can agree:  

  1. As a manufacturer, you will need to prove your compliance to regulations on a regular basis.  
  1. These regulations will continue to update and change, as well as some new regulations being introduced, on a regular basis.  
  1. The components that make up the product you manufacture generally do not change in composition on a regular basis.  

There is an opportunity for manufacturers, no matter the markets, the size or end application, that arises from the above known factors — and that is to embrace a long-term strategy for managing compliance.  

Gather All Material Data Once — and Update as Needed 

Rather than the “yes/no” response from your supplier, work with them to gain a composition-level breakdown of the components that go into making your product whole. This full materials declaration is not an easy undertaking, but it is fulfilling and pays off over the long-run, when you will simply have to get updated data when a component changes or a supplier or raw materials provider changes.  

Once you have all this data, next you must store it in a way and with a tool that transforms it into something useful.  

Input and Store Your Data in a Powerful Turnkey Solution 

Data can be cumbersome. Your suppliers may have told you that your product has disodium octaborate and lead in it, but if you are not sure whether or not disodium octaborate and lead need to be reported for one of the regulations, it proves burdensome to cross-reference current substance lists. This is especially true as many manufacturers’ lists span thousands of substances of strange-sounding metals, chemicals and more.  

There are a number of software applications that can store data and turn it into useful information. Technologies such as IMDS, CDX and others will not only contain your information but can track continuously updated regulation guidelines so you no longer need to cross-reference substance list sheets. 

Make it a Seamless Process — Get Support 

A long-term compliance strategy using full materials declarations is a must for a manufacturer who does not wish to scramble at the first sight of a new substance list or the first word of a new material regulation. Yet, gathering  correct data and managing that data presents its own challenges.  

Set yourself up for success. Tetra Tech can provide your team with the training they need to realize the results needed from this process — and our experts can even manage your supply chain querying and entire turnkey implementation.  




5 Ways to Ensure Your Emergency Generator Is Compliant

Companies often overlook the proper air permit and maintenance logs for their on-site emergency generators. After all, they’re used so infrequently they become an afterthought.

Sometimes, we mistakenly believe the vendor that installed the equipment was also responsible for the air permits. To further confuse matters, each state has its own requirements for the permitting of emergency engines and sometimes even counties, townships or cities may adopt their own more restrictive requirements. Regardless of the reason, it is always better to own-up and ensure compliance.

Here are five things you can do to determine whether your emergency generator is compliant.

1. Perform an Online Permit Search

Records more than a few years old have a nasty habit of disappearing. The Freedom of Information Act requires all air permits to be publicly available for review, upon request. Many agencies have taken steps to ensure all permits within their region of authority are readily available online for download. Search your local environmental protection agency’s website for a database or listing of active permits for your own facility so you can be sure the most recent version is on file.

2. Read Your Permit

Chances are, no one has reviewed the content of your air permit since it was issued. Take a few minutes to read your air permit and relevant regulations and compare what they require with your current compliance plan. Here are some additional resources to assist in your understanding of the federal requirements:

3. Check Your Records

A properly maintained emergency generator will have records of when it was operated for testing and maintenance and for how long. There will also be records of how much fuel is consumed, the reason for operation and what maintenance was completed on the unit.

If your company doesn’t have these records, check to see if you’ve hired a third-party to perform these maintenance checks for you. If no records exist, it’s never too late to start. Remember, always refer to the manufacturer’s recommendations when establishing your maintenance plan.

Download our free Generator Maintenance Documentation template to get started.

4. Properly Classify Emergencies

Federal regulations restrict emergency generators to 100 hours per calendar year for testing, maintenance and other non-emergency reasons. Some states are even more restrictive. Emergency operations are typically unrestricted (although, again, some states do put limits on this). A common mistake in the logbook is to track emergency operation as non-emergency.

5. Call Tetra Tech

Whenever you have a question, don’t be afraid to reach out to Tetra Tech. Our experience in obtaining permits for and reporting on emergency generators spans the U.S. We assist our clients in getting into and maintaining compliance with federal, state, and local regulations while fostering strong relationships between them and their local regulatory agencies.



ECHA Promises Insight to the Forthcoming Waste Framework Directive Database Requirements

After resource negotiations with the European Commission, ECHA is on its way to creating the Waste Framework Directive SVHC database prototype.  

As a refresher, the database is the result of ECHA revising its Waste Framework Directive, which officially went into effect July 2018. It will exist for companies importing, producing or supplying products to input any articles that contain candidate list substances.  

>>You can follow the timeline of expected key dates that will affect your company and reporting here 

As for the database, ECHA will start with a prototype to be finished by January 5, 2020, to allow for piloting and testing.  

A Real Possibility of Delays 

The database creation has already experienced months of delays due to a lack of resources for ECHA to start its creation.  

According to Chemical Watch, ECHA believes the January 5, 2020, deadline looks to be a challenging one to meet. However, the agency has committed itself to making the database available for testing in “early 2020,” with information submission tools fully operational in advance of the 2021 deadline of the full database implementation and for companies to start inputting data.   

 The Question We Are All Left to Ask 

As we wait for the database prototype to be created, we still have little insight into the information ECHA will request manufacturers to input for compliance and what this will look like. ECHA has acknowledged this concern, however, and has said it will publish the information requirements on its website by Summer 2019 

In the meantime, check back here for any updates we receive and more word on what to expect in the coming years for your European chemicals reporting requirements.