For those of you who have been following these REACH Best-Practices articles, I have been doing my best to be as comprehensive as possible in the overviews. Recently, I met with the staff of GreenSoft Technology and was treated to a demonstration of its services and software product, GreenData Manager. GreenSoft specializes in environmental compliance document retrieval and has developed software to manage the data.
GreenSoft notifies its subscribers when documents are updated or new specification files are sent from the manufacturer of the components of interest. It has 45 full-time data-source engineers tracking document changes and retrieving material declarations. They document every chemical mentioned on the materials disclosures and enter the relevant parametric data against the manufacturer’s part number for every article. By referencing the CAS number with the corresponding ppm and by using a fully relational database, they are able to roll-up chemical content and volume -- not just at the article level, but right up through the BOM, inclusive of the top-level hardware and assembly materials for a company’s product.
This top-level roll-up capability facilitates the rapid, automatic creation of certificates of conformity that are sufficient to present to EU member states as full declarations for REACH compliance. This is a significant advantage over other REACH provider services that only supply the service subscriber with blanket-level PDF documents generally released by the manufacturer. These documents state that “none of our products contain any of the Substances of Very High Concern as noted on the dated list attached.” What GreenSoft so simply and elegantly brings to the table is actual data for the chemicals, provided in a format that is easily retrieved, sorted, and reported.
The various levels of chemical roll-ups provide an even greater advantage by displaying both the chemical name and CAS numbers by mass, weight, and volume. To that end, a company may uncover a non-compliant part but will then have the option of achieving product compliance when the part is rolled in and up to a higher-level assembly where the single part has a lesser chemical-ppm-to-weight ratio.
The offending chemical’s contribution to the overall product’s composition more or less disappears because the stated regulation stipulates that an assembly can be considered an article (therefore, the volume of a chemical is related to the total weight of the product). So, where 0.15 percent of a 1-ounce connector will stop the presses, that same connector in a five-thousand-pound automobile, top-level assembly is now acceptable.
The question may be a matter of interpretation: "What is the article; the whole car or every single tire?" The European Commission’s legal interpretation of REACH is "the whole car." Seven EU member states disagree, however, including Germany and France. They argue that every nut and bolt is a separate article. It is possible that this issue will have to be decided in the European Court in Luxembourg. Either way, GreenSoft has the technical data covered at every level of the bill of materials.
As a service subscriber myself -- and after having reviewed several regulatory environmental data providers, looking for up-to-date compliance information for REACH, RoHS, and other chemically-directed mandates -- I have now been able to compile a must-have list of services that I would consider comprehensive.
- Chemical information on every part, with full material disclosures sortable by CAS number, ppm, mass, and volume data per part and per product listing.
- Coverage for all materials used in any part or assembly, including hardware, fasteners, adhesives, thermo paste, lock-tites, tapes, hold-downs, etc.
- The ability to search up and down in a nested BOM for pinpoint accuracy of chemicals with where-used detail.
- Top-level assembly roll-ups, including cartons, packaging, and other shipping materials.
- 100 percent coverage for custom-machined and sheet metal components, including plating, ink, and paint compositions.
- One-click generation of compliance reports.
- An alert service guaranteeing that the most recent regulatory changes are folded into all registered BOMs.
The above list will assure that there isn't a lot of additional effort required by your company to provide the confidence and proof that you and your customers need to validate the compliance of your products. When you are shopping for a service provider, consider referencing this list to qualify its offerings.