Streamline Compliance with Full Material Declarations
When regulators restrict a substance, manufacturers turn to suppliers for reassurance that the substance isn’t in their products. When the list of substances was small, that wasn’t a problem, but now the list of chemicals that are flagged by regulators and the number of directives that regulate them continue to grow annually.
For example, the list of REACH restricted substances is nearly 200 and shows no sign of stopping. “Companies are finding it very hard to keep up with this list, because roughly every 6 months the EU adds another six or more substances to the list, they have to ask every supplier ‘is this in your product,” says Tord Dennis, practice leader at WSP | Parsons Brinckerhoff. “It’s the equivalent of doing an itemized version of your taxes every six months. They have to go through all their records and find everything that went into the product.”
Dennis suggests a different approach. Rather than ask suppliers for certificates of compliance, (CoC) he recommends suppliers should provide Full Material Declarations (FMDs). “Instead of me giving you a quiz and saying check the check box on this, I'm going to give you an essay question and say, tell me everything that is in this product,” he says. “Then I will go through the list whenever the regulations change and determine what is allowed or not.” Then instead of returning to every supply chain partner, companies will only go back to the ones who they know are using restricted substances.
FMDs streamline the data collection and recordkeeping process. But what about suppliers who don’t want to share that information? Dennis says it’s important that they see how their business and their customers’ are intertwined. Products with restricted substances can’t be sold. “No data means no business. If I can't sell the product, I can't buy products from you. I can't pay for your products,” says Dennis.
He also notes that sharing materials doesn’t necessarily mean sharing proprietary information. “What I want to know is what's in it? I didn't ask you how much of each did you put in and how long did you bake it and when did you flip it. I'm not asking for the recipe. I just want the ingredients. Or the contents after it’s baked”
Dennis will talk more about this topic during Best Practices for Environmental Data Collection in the Supply Chain at Stewardship 2016.
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