Get Ready: IMDS Recommendation 019 Will Be Deactivated Soon

IMDS Recommendation 019 (REC 019) was created to ease the data submission process for electronic components in the automotive industry and has long been in place. In September of this year, the IMDS Steering Committee voted unanimously to make REC 019 obsolete. While the timeline for the deactivation of REC 019 is still undetermined, you can begin preparing for the changes now.

The Challenges IMDS REC 019 Met

Section 3.1 of IMDS Recommendation 001 requires all materials used throughout the automotive supply chain to be disclosed accurately. To do this, companies must collect material data from all suppliers and then incorporate that data into the final assembly in IMDS.

Prior to development of REC 019, this posed challenges to electronics suppliers. Because of the complex material compositions and the very small weights of the components in an electronics assembly, the reporting of these materials was no easy feat. Also, only a small portion of electronics suppliers are automotive; therefore few are accustomed to the IMDS reporting standard.

In 2003, the IMDS Steering Committee developed IMDS REC 019, intending to ease the burden of reporting the necessary data for electronic components. It has allowed IMDS users to employ standard modules, which were published as semi-component datasheets with fixed materials and weights. This saved a significant amount of time for IMDS users who had previously been creating these datasheets.

The Imperfections of REC 019

REC 019 states that, “Any use of standard materials does not substitute the supplier’s mandate to track and gather all necessary material information along the total sub-tier supply chain.”  Although REC 019 cut down the time an IMDS user spends creating datasheets for reporting, electronics companies still needed to gather the required information on substances and materials from upstream suppliers.

Based on that gathered data, electronics companies needed to determine if a REC 019 Flat BOM approach could appropriately represent their product. If there was evidence that substances on the Global Automotive Declarable Substance List (GADSL) were present in the electronic component that were not included in the REC 019 module, then the suppliers would have to supplement the standard module with additional substance data.

Preparing for the Impending Deactivation of REC 019properly investigated and REC 019 modules were sometimes being used to hide prohibited substances such as lead.

In September of this year, the IMDS Steering Committee voted to deactivate REC 019 because material compositions were not properly investigated and REC 019 modules were being used to hide prohibited substances, such as lead.

While the timeline for the deactivation of REC 019 has not yet been determined, there are things your company can do to prepare now. First, electronics suppliers can begin performing internal reviews of material data in order to document the evidence of the material compositions of their products is comprehensive for compliance. This will better situate suppliers if the decision to move towards Full Material Declarations (FMD) is favored.

The deactivation of REC 019 will have consequences across the automotive industry. Suppliers of electronics materials will likely need to obtain an FMD. And it is possible there will be delays in data submissions in IMDS.

For guidance on the next steps for your company given this new decision, turn to Tetra Tech for IMDS training, assessments and further advisement at IMDS@tetratech.com.

 

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Comprehensive Building Equipment Information — Available at a Click

People often think of buildings as a singular unit. In their completion, in fairness, they look that way. But as building owners and managers, you know there are hundreds of individual systems that make a building functional.  

And when one of those systems breaks down or needs maintenance, it can be a headache tracking down the data, right material, and information needed to bring the piece of equipment up to operationNot having accessible maintenance data at your fingertips can keep your systems from running at their optimal efficiencies. It can limit your capital planning and waste time for maintenance personnel. Ultimately, it can threaten your bottom line. 

Having easily accessible data is even more important if you are managing a large portfolio at multiple locations. Wouldn’t it be nice for your maintenance and repair staff to understand how the particular system functions, what size filters, what size belts, what size impellers are needed before they leave the “shop”?  How much time is wasted looking up manufacturer data, calling suppliers, and looking for detailed views of the failed equipment? 

Wouldn’t it be nice to have all that information at your fingertips, to have it on handheld tablets and phones, and to have it easily searchable? 

A Better Way to Store Equipment Data 

At Tetra Tech, our architects and engineers use a software program — Revit — to create three-dimensional building designs that capture data about the systems we draw. With an air handling unit on the roof, for example, we include the comprehensive data such as belt sizes, filter sizes, pounds of refrigeration, its OEM user manuals and more. And we do this level of information-gathering for every piece of equipment that makes up your building.  

Yet, most building owners don’t know how to use Revit, and you probably aren’t eager to shell out funds for its licensing or to dedicate staff to manage such a system. That’s why we’ve developed the capability to export our Revit models and convert them into PDFs, complete with all equipment data information.  

 

 

The equipment information highlights within the PDF and links to a component-level PDF that contains specific systems information and data that is customizable to any owner’s needs.  

Building owners and maintenance crews alike can access their building data information at a click of a PDF link, nearly instant and accessible to any user. Maintenance crews can work from tablets, taking the entire building’s system information with them, in all one place.   

 

 

 

 This electronic capture of your entire facility’s equipment data is available at the completion of a design or build project. Tetra Tech has developed a process to seamlessly transfer the data from Revit models into usable PDFs, but we can also take existing drawings and systems and develop the same usable data rich PDF documents. The “usable data” or “maintenance data” can be gathered from existing files or collected in the field and populated into a data rich PDF. 

Learn more about the other long-term benefits of working with Tetra Tech’s architects and engineers 

  

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Is the Automotive Industry Prepared to Comply with the SCIP?

ECHA is moving towards using the Substances of Concern in articles or in complex objects [Products] database (SCIP) to regulate the gathering of information regarding hazardous materials, but the automotive industry already has a system in place to do the same thing: International Material Database System (IMDS).

Will this help the automotive industry be more prepared to comply with the SCIP?

IMDS and IDIS

Under the End of Life Vehicles (ELV) Directive, vehicle manufacturers are already required to restrict the use of hazardous materials in new vehicles and meet certain targets for re-use, recycling and recovery when their vehicles become waste. When the ELV Directive entered into force in 2000, the automotive industry decided that the best way to comply with the directive was to develop a centralized system to gather materials data from their supply chain.

The result was IMDS, the system that is still used today to enable the automotive industry to gather materials data from all tiers of the supply chain for all parts used in the vehicle. This is used to comply with the ELV heavy metals restrictions in new vehicles and also to provide reuse, recycling, and recoverability data in order to demonstrate that the vehicle can be processed at end of life within the stipulated legal targets (currently 95% by mass, 10% of which can be energy recovery).

Data gathered by IMDS is also used in part to populate the International Dismantling Information System (IDIS), which is used by recyclers to help in the processing of scrap vehicles. For example, by using the IDIS system to gather information about hazardous materials, recyclers can remove fluids and parts containing hazardous substances (e.g., batteries) as a first treatment step and therefore reduce any contamination of recycled materials during subsequent steps such as shredding.

But all of this has come at a considerable cost.  The European Automobile Manufacturers  Association — ACEA estimates that the industry has invested 10 billion EUR to date in the development of IMDS data collection efforts.

Because automotive manufacturers cannot sign off on their Production Parts Approval Process (PPAP) or place parts into production without IMDS, they have strong incentive to meet the IMDS data requirement at each tier of the supply chain. As a result, this data collection has become deeply ingrained into every part of the automotive business processes, and because the automotive supply chain is global, so is the IMDS user community. There are over 100,000 company IMDS accounts and around 300,000 users worldwide.

SCIP in Comparison

At first glance, the SCIP is similar to IMDS and IDIS in many ways:

  • Like the SCIP, IMDS captures data from all tiers of the supply chain. In fact, IMDS goes one step further, as it also includes material producers in scope.
  • Like the SCIP, IMDS captures the complete Bill of Materials (BoM) of parts and assemblies, but does so to include hierarchy and quantities rather like the linked article and number of units required by the SCIP.
  • IMDS captures the substance within a material using percentages rather than the concentration ranges required by the SCIP.
  • IDIS provides recyclers with information on the treatment of the product at end of life, including the presence of hazardous substances.

But there are some crucial differences when comparing the SCIP with IMDS and IDIS:

  • In IMDS data is kept highly confidential whereas the SCIP is a publicly searchable system that includes not just individual parts but product structures and supply chain details.
  • IMDS does not contain the complete vehicle BoMs, but rather includes only the top-level parts from a given vehicle BoM. The complete vehicle BoM remains in the vehicle manufacturer’s in-house system. In order to comply with the SCIP, the vehicle manufacturer would have to export that BoM into the SCIP. This would not be the “150% BoM” that is analysed for type approval of a given vehicle platform — a conglomerate of all variants — but rather would be BoM generated for each model variant, potentially at the VIN level.
  • IMDS is not constrained by the boundaries of the EU. IMDS is not a legal requirement, rather it is a business to business agreement embedded into automotive business processes such as the Production Parts Approval Process (PPAP). The automotive supply chain is global, and so is the user base of IMDS. The SCIP will be a legal requirement in the EU, but will not be legally enforceable outside the EU.  Importers of articles into the EU will have to rely on their non-EU supply chain to provide them with the data they need to comply with the SCIP data requirements, which could be extremely challenging given the level of detail required.

Other Concerns About the Usefulness of SCIP

There are also some more general concerns about the usefulness of the SCIP to its target users (the waste operators and consumers). The European Recycling Industries Confederation (EuRIC) position paper on the WFD Database points out that many articles reach the waste phase many years after being placed on the market (e.g. 15-20 years for cars, much longer for aircraft).

By the time those articles reach end of life, the data in the SCIP database would likely be out of date.; it would not contain information about the REACH Candidate List that is current at that time of recycling, but rather would include only what was current when the product was last placed on the market.

EuRIC also makes the point that the data in the database may be overwhelming. Complex objects such as cars and aircraft contain hundreds of thousands of components. Knowing that there is an SVHC in the jacket of a resistor on a printed circuit board found in a particular model variant, for example,  is irrelevant to end users, even assuming that the component was not repaired or replaced during that product’s lifetime. As recycling processes are highly automated and applied to product categories rather than individual products, having such detailed information on the potentially thousands of parts of individual products would not add value to those processes.

Consumers similarly would be overwhelmed by the level of detail.  A vehicle, for example, would likely comprise many hundreds of pages of documentation, rendering it impractical for the general consumer. And beyond that, many consumers do not have the level of in-depth knowledge to understand substances and their effects without further research.

Despite numerous rounds of engagement between ECHA and automotive industry stakeholders, there remain significant concerns as to how the industry can meet the requirements of the SCIP. ACEA have expressed concern to the European Commission that the automotive industry’s investment in IMDS and IDIS will be undermined by the SCIP database, viewing it as a parallel database duplicating workstreams and data already in place at great cost.

What next?

Earlier this year the Chemicals-Articles-Waste Cross Industry Platform ran a workshop to discuss the WFD DB information requirements. Following this event, they issued a Letter of Very High Concern to the EU Commission summarising the problematic issues and calling instead for a waste stream approach (i.e., rather than using a one-size-fits-all database) built on existing systems and infrastructure already developed and present in different industries.

In the case of the automotive industry, this could be achieved by adapting IMDS and IDIS. For example, adding a requirement for more information on the SVHC content of automotive materials and potentially other substances of interest such as critical raw materials.  This would increase transparency about SVHCs in the same spirit as the SCIP, without dismantling reporting requirements the industry is already accustomed to. Such information could be aggregated to a level that would better equip recyclers to handle materials and components safely and minimise hazardous substance content in secondary materials.

There are also calls for the development of the SCIP to be halted until the EC Feasibility Study “on the use of comprehensive tools to manage information flows from product supply chains to waste” is finalised. Controversially, plans for the SCIP database were approved without a formal impact assessment.

There is no doubt that there is a need to realise a more circular economy, and industry is supportive of this objective. But it seems that the ‘one-size-fits-all’ approach of the SCIP database has many shortcomings and may be impossible to implement or enforce in its current guise. Industries are instead advocating a more tailored, industry specific approach that can leverage processes in place. It remains to be seen however if the European Commission is willing to change course.

For support in preparing for future materials database requirements — and how your current IMDS data can be leveraged for future requirements, contact our REACH experts.

 

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