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.
One of the statements GreenSoft Technology made was that they find that their subscribers are coming to them indicating that the whole REACH compliance effort is Sales driven. The way I understand that is like when I was working at a company that had a high option, low volume mix product. We found ourselves spending a lot of money in R&D customizing standard product to secure one sales order. That had to stop. We needed to be "Market" driven and not "Sales" driven. So I interpret what Greensoft as saying is that the customer's customer is demanding REACH certification before allowing any products sold to enter the EU member states. It may start as one-at-a-time compliance, but once you have the service, the sae parts are used on many products and the cross pollenation withing the company will also cross pollenate the industry as the parts being researched and approved all become compliant and in centralized databases like GreenSoft and EEContent.com. It will boil down to comprehensiveness and cost of service. I would look for a service that would offer a flat fee so my compliance cost were largely under control for any number of parts I wanted to submit for evaluation.
One thing most all of the environmental data gathering services offer is 24/7 alert notifications. That means as soon as an OEM/OCM releases a new alert coinciding with a new regulatory update, the subscriber is notified. Some services offer an API that will write the new data directly into your database, eliminating typo or other errors engendered by human error during manual key entry. I would go so far as to say that any service that doesn't offer currency on all updates from manufacturers, should be avoided. The worth of the data is that it is time triggered and time critical. Look for a flat fee service so you don't keep getting hit with additional charges. Revision control is a function of the date and referenced list on the associated documents included with the data downloads. REACH documents are updated regularly. A service like EEContent.com actually appends the number of SVHC chemicals to the document title identifier. So -53, -73 etc are added to the document number. You bring up a very good point. Anyone auditing their component database should replace old documents with new ones and these newest docs should be readily identifiable without having to open each file. Good point!
Douglas, The main assumption behind these regulations is that companies will self-monitor and control. It's almost impossible for regulators to examine all components shipped to a manufacturer to ensure compliance so the hope must be that the companies themselves would take the proactive steps to ensure their suppliers are compliant. Transferring the onus to manufacturers is just another of those steps that many complain make the life of a business exec complicated.
This is a well researched and comprehensive list of a BOM should consist of to be environment regulations compliant. I believe the system that handles such a kind of BOM should will include a snapshot of what all the regulations (along with their date of implementation and the revision number) .
As the new regulations become effective some of the old inventory which was other wise complaint will now become non-compliant. Will the system be able to declare that on inclusion of the new regulations ? I hope it will.
RFID makes it possible not only to increase the quantity and types of products streaming through the supply chain, but also to build higher-level products and services.
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Join EBN contributor Jennifer Baljko on Thursday August 23, 2012, at 11:00 a.m. EST for a live chat on how electronic manufacturers in Thailand have shored up their supply chain to reduce the impact of future natural disasters.
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