How should I approach REACH, CM, etc. as a job shop?

[Tagin]

I think for now, my approach will be to request safety data sheets from my vendors, screen the chemicals by CAS number, and report any SVHCs that are used in raw materials or SVHCs that are added in coating/finishing processes. Thoughts?

What regulations are there enforcing disclosure of SVHCs in safety data sheets? I see that the EU has some, but not sure what the SDS disclosure requirements are in other countries.

 

[Ninja]

In the US (OSHA GHS, 1910.1200), it is case by case...

The hazards must be listed, but there is some flex in calling out specific materials or simply calling them "Trade Secret" or equivalent.

That said, Regulatory information (OSHA GHS SDS requirements for Section 15) requires regulated materials covered under SARA or State's "right to know" to be called out in specific, but does not require quantity information.
Here in the US, we don't have a category for SVHC outside of interactions with REACH.

Code is here if you want it...it's long...HTH

 

[Tyler]

Hmm. The deeper we go, the worse it gets.

While it would be nice to rely on safety data sheets, it sounds like you are saying they may contain omissions. If I can't rely on safety data sheets then I don't know how I could determine REACH compliance before manufacturing the product. =(

 

[Ninja]

Please forgive me using lawyer speak (I am not one)...but ... "asked and answered"

work together with your customer, the solution is likely easier than you currently fear.

as long as you don't intentionally add stuff that crosses the line, and perhaps spot test areas of high risk

The one thing I can guarantee is that if nothing you put into the product violates REACH, the final product won't violate REACH.
SVHC's do not spontaneously appear.

This is a risk/benefit proposal...weigh the risk, mitigate the risk by involving your customer, test the stuff at highest risk before including it in the product, then make it and bill it out...this is fairly simple math...

 

[Tyler]

...test the stuff at highest risk before including it in the product...

Could you provide a little more context about the organization you worked for. It sounds like you worked for a design/engineering company. I really don't think your approach fits our organization. We are a small, high mix, low volume, built to print job shop.

Testing certainly is the only foolproof way to know if the end product is REACH compliant, but it has the following significant drawbacks for our company.

• We wouldn't be able to test the parts before manufacturing them.
  • Since we are a high mix, low volume job shop, it wouldn't make sense to run a single part through production for testing before manufacturing the full lot quantity. That would be a huge waste of time. If we had an extended contract for a product and were setting up a production line then that would make sense, but that is not the case. Thus, we would only be able to tell if the parts are compliant after manufacturing them.
• It would add to our lead time.
  • If we were to ship the parts along with their cert then we would have to wait on the test results. That would probably add a week or two to our lead times. Lead times play a significant role in whether we win our bids.
• We don't get to choose what goes into the product.
  • We are a build to print manufacturer. If the drawing says chem treat per MIL-DTL-5541 Class 1A (not REACH compliant), then that is what we have to do. If a product is not REACH compliant per its design, then there is nothing we can do about it.

As it stands, these are the options that I see.

1. Tell the customer that we can have the parts tested but that we cannot guarantee REACH compliance.
2. Flow down REACH requirements to processors and hope that they are honest.
3. Gather information about the processes and materials commonly used and determine their compliance status.
   • We manufacture hundreds of distinct part numbers a year. However, most of these parts share the same processing requirements. If I determine the compliance status of all my processes then I could probably determine the compliance status of 90% of my products.

Seems to me like the best option for us is a combination of options 2 & 3. If we do option 3, then we have a good idea of whether a product is compliant before accepting an order. And we would need to do option 2 no matter what; some special processes allow for the use of both REACH compliant and non REACH compliant materials, so we would need to make sure our processors use the right stuff.

 

[Ninja]

We wouldn't be able to test the parts before manufacturing them.

...but you can test samples of the incoming material before you make the parts.

It would add to our lead time

Well, yeah...most customer mandates do.

We don't get to choose what goes into the product

Well, not sure that's true. You have to make part X according to print ABC out of 304 stainless...you can choose where you get the 304 stainless from, right?

We were a formula based manufacturer, typically making customer specified powders into intermediates or final parts.
We tested the incoming powders...not the final part (with a couple of exceptions).

 

[Golfman25]

Could you provide a little more context about the organization you worked for. It sounds like you worked for a design/engineering company. I really don't think your approach fits our organization. We are a small, high mix, low volume, built to print job shop.

Testing certainly is the only foolproof way to know if the end product is REACH compliant, but it has the following significant drawbacks for our company.

• We wouldn't be able to test the parts before manufacturing them.
  • Since we are a high mix, low volume job shop, it wouldn't make sense to run a single part through production for testing before manufacturing the full lot quantity. That would be a huge waste of time. If we had an extended contract for a product and were setting up a production line then that would make sense, but that is not the case. Thus, we would only be able to tell if the parts are compliant after manufacturing them.
• It would add to our lead time.
  • If we were to ship the parts along with their cert then we would have to wait on the test results. That would probably add a week or two to our lead times. Lead times play a significant role in whether we win our bids.
• We don't get to choose what goes into the product.
  • We are a build to print manufacturer. If the drawing says chem treat per MIL-DTL-5541 Class 1A (not REACH compliant), then that is what we have to do. If a product is not REACH compliant per its design, then there is nothing we can do about it.

As it stands, these are the options that I see.

1. Tell the customer that we can have the parts tested but that we cannot guarantee REACH compliance.
2. Flow down REACH requirements to processors and hope that they are honest.
3. Gather information about the processes and materials commonly used and determine their compliance status.
   • We manufacture hundreds of distinct part numbers a year. However, most of these parts share the same processing requirements. If I determine the compliance status of all my processes then I could probably determine the compliance status of 90% of my products.

Seems to me like the best option for us is a combination of options 2 & 3. If we do option 3, then we have a good idea of whether a product is compliant before accepting an order. And we would need to do option 2 no matter what; some special processes allow for the use of both REACH compliant and non REACH compliant materials, so we would need to make sure our processors use the right stuff.

My opinion is don't over do it. You'll drive yourself crazy. As you said, you are a contract manufacturer -- your customer tells you what material, what special process (ie; plating), and what dimensions. You're expertise is putting it all together into a complete part. And as you say, your customer is the one responsible for selecting compliant process and materials -- it is truly their problem. So what we do is flow everything downhill. Our raw material suppliers are pretty good -- they have letters with the appropriate language, the mills also have similar. Our special process providers, mainly plating, are good as well and can provide a similar compliance letter. It's kind of commonplace for them these days if they do any volume business at all. If we have someone who can't or won't provide a compliance letter, then we flow that back to the customer as well (and we may have to find a supplier who can). We compile all that together, put our own letter together and drop it all in the customer's lap. So far, so good. Good luck.

 

[Tyler]

Just wanted to follow up to see if anyone had suggestions for a training services provider. I think I would like to get some formal training on the subject matter.

 

[psp1234]

Tyler,
I am working in a CM company as well. I agree with all the people that suggested to not over-think it.
What I did:
1. Contacted all major suppliers and asked them to confirm that their parts are RoHS/REACH compliant (I sent them a prepared form).
2. Added a blanket requirement on every PO to comply with RoHS/REACH (and to contact our buyers if not).
3. Trained all buyers to request compliance with every purchase (in writing).
4. Wrote a procedure that describes our policy.
5. Wrote in the "compliance statement" that my compliance "is based on supplier certifications and statements", and added "testing is not implied". Added that "customers are responsible for material selection and expected to verify compliance".

So far no customer has rejected this approach.
Good luck
Sue