Will the Waste Framework Directive Waste Automotive’s Data?

Long before the revised Waste Framework Directive’s (WFD) database was being developed, the automotive industry had generated tens of millions of datasheets reporting on material chemical composition, via the International Material Reporting Database (IMDS). Over the past two decades, automotive companies have invested substantial resources into IMDS reporting.

While IMDS was created primarily for addressing the requirements of the EU’s End of Life Vehicles (ELV) Directive, it continues to add features for facilitating compliance with other global regulations which require material content data.

Now with the WFD database scheduled for user testing in early 2020, questions remain: Will automotive manufacturers be required to manually input data into the WFD database despite much of that data being already available in IMDS? Will the WFD inadvertently contribute to a waste of resources and squander the opportunity to capture useful material content data?

Time Is Running Out on Efforts to Prevent This Waste

One major benefit of having many millions of datasheets stored electronically is that they are virtually “on-tap” for electronic transfer if a convenient format for transfer can be established. Indeed, that is exactly what many automotive OEMs and Tier 1’s do every day, as they have invested in technology for uploading and downloading data between IMDS and other software applications.

In an ideal scenario, any future major regulatory databases would allow convenient electronic import of the vast amount of material content data residing in IMDS. However, with 2020 now six months away, there is very little certainty about what, if any, electronic data transfer mechanisms will be available for the industry.

In fact, as matters currently stand, automotive manufacturers would have to manually re-enter much of the data that they have worked so hard to collect. Automotive stakeholders, both within the EU, and also globally, have been commenting and advising on measures that the EU could take to enable the mountain of data to be used, rather than tossed aside.

IMDS

But they are working against the clock and fighting an uphill battle. If they are successful, they may prevent this still-avoidable outcome. If they are not, we may witness the irony of a waste regulation contributing to a wasted opportunity.

Take Action Now to Protect Yourself

While much of the ongoing effort to facilitate transfer of existing data is now outside of your control, there are actions you can take now to preserve your ability to use your IMDS data to support the new WFD database requirements. Tetra Tech can assist you in understanding what those actions are and can help you with any of the steps with which you may require assistance. Please contact us if you have any questions; we would be happy to walk through any of your concerns with you.

 

PREPARE FOR THE WFD DATABASE

 

You Might Want to Review Your REACH Dossier: ECHA to Step up Compliance Checks

In May 2019, ECHA, with support from the European Commission, announced it will take increased action against REACH non-compliance. This comes as an urgent response to the high numbers of missing or inaccurate data in the registration dossiers.  Data accuracy is vital to achieve its mission to provide information on the substances within the EU market.  

With ECHA increasing dossier checks from 5% to 20% across all registrations, not just lead registrants, it is imperative that chemicals importers review their REACH registration dossier now, to ensure all information is complete, accurate and up-to-date. This is especially pertinent to those who have expanded in the market and may now have new uses to consider adding.  

Proper REACH registration provides your access to the European market; without it, you risk lost business and potential ramifications from EU manufacturing and end-user customers.  

The ECHA Compliance Check Process 

If your dossier is flagged and enters the compliance check process, there is limited opportunity to update your information to ensure compliance during the review. 

With tightened data requirements and increased quality control, any data exemptions and their  explanations will be under scrutiny and may no longer pass ECHA’s revised standards. In this review process the automated data check system is being replaced by a manual process with human eyes sifting through answers to ensure accuracy and compliance.  

ECHA will request any unsatisfactorily answered or missing components of your dossier. If you can provide that information upon request, great. It will be business as usual.  

If you still lack the information that you were not prepared to answer years ago in your initial chemical registration, then it is better for your business and your customers’ businesses now if you make moves to resolve that information.    

Plan for Compliance Now — Review Your Dossier 

As the quality requirements have tightened, we recommend all registrants to review their REACH dossiers to confirm they meet the requirements. 

Tetra Tech’s team of regulatory experts is available to help review your REACH dossier and to run it through the set of ECHA requirements. We can also help you resolve any issues that arise, so if you do find your dossier in the ECHA review process, Tetra Tech will be there to help you navigate the waters.  

Please contact us to start your REACH dossier assessment.  

 

PREPARE FOR COMPLIANCE NOW

 

SVHC Reporting in 2020 — Get Ready to Find the Needles in Your Data Haystack

When the Waste Framework Directive (WFD) entered into force in 2018, its associated WFD chemical reporting database was almost an afterthought to many observers. Compared to REACH, WFD appeared to have a fairly limited regulatory impact and the proposed database did not gain widespread notice at the time.

By late 2018, it became clear to industry stakeholders that the EU’s ambitions regarding the database were far greater than had been realized. The WFD database is now emerging as the potential vehicle for greatly expanding REACH’s chemical reporting requirements.

REACH Reporting Practices in the Past

REACH Article 33 Communications have been required since 2008. However, since the first set of Candidate List substances was published, the requirement has been mainly driven by customer requests. Very few suppliers made the effort to proactively report chemical content for all their products unless a customer first asked them. Many customers never asked, because they didn’t have the bandwidth to make the requests for every purchased component and review all the incoming data.

One of the lessons learned from REACH (and RoHS) reporting is that relying upon industry to ask the questions without a credible driver for enforcement often results in low conformance. It’s not as if no companies were asking their suppliers for data; it’s just that many times the request was for the supplier to send a single statement declaring, “We have no SVHCs.”

This is like asking someone “Are there any needles in your haystack?” Then they open the barn door, peer in at the mountain of hay and conclude, “Nope, we didn’t notice any needles in that pile, so everything is good.”

The Shift to Comprehensive Substance Data

This fact has not been lost on ECHA as it has watched this all play out over the past 11 years. Now, the EU is developing a vehicle that may profoundly change all of this. If the WFD database continues on its current trajectory, it will force companies to actually take more than a quick glance at their data haystack and report on every single individual straw in the haystack. The WFD database would facilitate component-specific requests uniquely identifying each part by bar code (or by some other identifier) and companies would have to respond individually to each consumer request.

And thanks to the technologies now available in 2019, millions of consumer-initiated requests will soon be coming at you as fast as the speed of light. For example, look at how rapidly our team was able to generate REACH SVHC Article 33 Communication requests using one of the many smartphone apps that are being rapidly developed in anticipation of the new requirements:

Within 10 minutes we were able to upload a free app and easily generate one SVHC request per 6 seconds at local retailers. Doing the math, this means any interested stakeholder on earth can now create 1,200 legal obligations per hour, or almost 10,000 SVHC requests per workday. Each of these consumer requests must be answered within 45 days for any of the targeted products to legally remain on the EU market.

The details are still being refined so the database may allow for more flexibility in reporting than its currently envisioned state permits. But as 2020 is now only six months away, the time remaining to influence the reporting process is very short and the technology for creating an unprecedented deluge of legally binding requests is already available.

It’s vital you act now — and our team of regulatory compliance experts are here to help. Contact us for help with your REACH SVHC reporting.

 

Contact Us

 

Note:  In preparation for this new requirement and its global implications, there are least a dozen European and North American developers working on rapid product data acquisition systems.  The above video featured ToxFox in a toy section.  We will also be posting videos of SVHC requests being generated for automotive, electronic, aerospace and medical device components.  Some of the applications used include:

  • ToxFox   Downloaded by over 1.2 million smartphone users. 20 Million product scans (17,000/day). 143,000 Protest Emails from Consumers (120/day).
  • CodeCheck   Downloaded by over 1 million smartphone users and allows consumers real-time product chemicals and detailed chemical information that can influence purchase decisions.
  • DeTox  10,000+ downloads. Provides tips about buying products to avoid harmful chemicals, either by search or product scan. The app uses game-ification features such as badges and notifications to ensure consumers engage.

 

Saving Money Through Routine Maintenance: Why Your HVAC System Needs Regular TLC

There is no question that energy-efficient facilities save building owners money on their bottom line. Yet, out of all the systems that contribute to an energy-efficient building, rooftop units — specifically HVAC systems — oftentimes go ignored after the installation and until there is a catastrophic failure. 

Between regular maintenance budgets being slim to non-existent, to a lack of compelling reason to worry about the systems over our heads, there are many reasons routine maintenance goes unperformed. “The air feels fine in here” mentality is an easy answer to potential problems being ignored.  

Yet, the following HVAC system failures pictured and detailed below camouflage their failures by the system over-performing, the air quality deteriorating in a way that cannot be detected and systems compromising toward emergency failure.  

… effective preventive maintenance can decrease energy bills by 15 to 20 percent.  

If nothing more, take a look at these issues and ask yourself: Is a similar HVAC system offender present on my roof?  

The Component-Level Issues That Could Be Affecting Your Rooftop HVAC System 

HVAC damper

Dampers  

Your dampers work simply enough: The top damper lets in outside air and the bottom lets in return air. The two are supposed to mix through the filter for an optimally efficient system.  

In the images above, these are similar types of systems and both dampers are supposed to be supplying approximately 10 percent outside air to the system during occupied times and closed while unoccupied. Yet, on the left, the damper is letting in outside air (while the space is unoccupied), and the system is doing extra work to cool outside air, which a tenant and building owner won’t feel in the moment but will see in increased utility bills down the line.  

On the right, there is no outside air being let into the system (while space is occupied). Likely the tenants feel comfortable with the temperature but there will be increased carbon dioxide in the air which has the potential to make tenants sleepy and less productive, ultimately degrading the quality of air.  

For these errors, either the actuator, motor, signal or linkage is broken. But no one would know it without a skilled professional assessing the system on a regular basis.  

 HVACroutine maintenance

System Materials  

Depending on the materials you initially invested in, your rooftop equipment may or may not be more susceptible to weathering and aging. Pictured are two similar systems. On the left, the system is just a year and a half old, but a cheap material was used in place of a better one. On the right, the system is five years old but is coated with epoxy and is holding up better. Depending on the materials you use, you will need technicians to check and replace parts more often.  

HVAC insect screen

Insect Screens 

Your insect screens protect the airflow from more than insects: think birds, bats, rodents. This is an incredibly easy fix and an important aspect to maintaining the integrity of your building’s air quality. Yet, it can go unattended to without proper and regular maintenance.  

HVAC linkage

System Linkage 

The linkage between the outside air and return air dampers works by closing one and opening the other to ensure the system is operating at optimal efficiency. In this instance, the linkage has broken, and the unit will not function correctly — operating at 100 percent outside air because the return air cannot open. The indoor air may still be comfortable, but your system is working in overdrive to ensure this is so, and your energy bills will reflect this.  

HVAC seals routine maintenance

Seals 

Rooftop equipment like any other piece of machine has parts that wear out over time, including seals. Here, an oil seal has broken on the fan and sprayed all over the motor. This seal is something a preventive maintenance technician would check and address before these issues arise.   

HVAC coils

Coils and Condensate 

Coils can easily become clogged and cause resulting issues. On the left coils are becoming clogged with dirt and possible biological growth greatly reducing the efficiency of the units and possibly spreading contaminants throughout the building. Tenants may not feel the effects of this, until the air stream is severely contaminated or the unit is so inefficient it cannot properly treat the air or properly dehumidify. As coils become completely clogged, debris can build up in the condensate pan, which can overflow and leak into the building. 

Invest for Substantially Increased Efficiencies and Decreased Costs 

While preventive maintenance plans for rooftop HVAC units oftentimes lose priority to other building needs, this is a major element in the system of a highly efficient building. And, as you saw above, even when a minor part breaks, your unit may be overtaxing itself to keep your building tenants comfortable — ultimately hiking up your operating costs and threatening to require costly emergency repairs.  

But you have the power to ensure your system works for your building’s efficiency, not against it.  

Commissioning is an important first step. Work with a building commissioning expert to retro-commission or re-commission your building systems to ensure they are operating as they should.  

An expert commissioner at the end of their job will provide a clear, actionable report that breaks down your systems and the components that need regular maintenance and at what intervals they need it, including those of your rooftop units.  

By following through with this operations and maintenance schedule, not only will you extend the benefits of the commissioning, you will see your energy bills decrease, your sustainability and efficiency increase, and the life of your rooftop systems lengthen.  

This is an investment that is sure to pay for itself. In fact, the National Center for Energy Management and Building Technologies has found that effective preventive maintenance can decrease energy bills by 15 to 20 percent.  

To have your building systems commissioned by an experienced professional and brought up to optimal performance you can monitor and maintain regularly, contact us for more information