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:
- As a manufacturer, you will need to prove your compliance to regulations on a regular basis.
- These regulations will continue to update and change, as well as some new regulations being introduced, on a regular basis.
- 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.