|
By Russ Thornton
Imagine you are a U.S. manufacturer with more than 1,000 items that you make and ship all over the world. One day a “request” arrives entitled "Restricted and Reportable Materials Disclosure" asking your organization to disclose numerous elements, compounds, and materials that may be contained in your manufactured items or used in your manufacturing process. There are 109 entries listed.
Now imagine that this is happening every day within most organizations and across all industry spectra.
As environmental issues continue to grow in importance, companies are feeling increasing pressure to "detoxify" their products. Many are in turn putting pressure on their suppliers to use fewer toxic and hazardous materials. As this trend continues, more and more facilities are likely to be faced with lengthy requests for details about the ingredients they use in their products and processes.
Dealing with such requests will always be challenging. But having an organized environmental management system (particularly one that is integrated with your company's quality, health, and safety functions) can provide a good headstart.
BACKGROUND
Interest in the chemicals and ingredients that manufacturing facilities use is not new. Material Safety Data Sheets (MSDSs) have been utilized in United States since the early 1980s. In addition, customers have often used questionnaires to elicit information on materials and chemical compounds used in a company's manufacturing process or incorporated into its manufactured products.
More recently, however, this information-gathering trend has been expanding, and U.S. industry is facing a much wider array of questions. To some companies, it seems as though everybody wants to know what you are doing and what you are doing it with.
This new trend first became a talking point within the semiconductor industry, largely because the industry is so fast moving. Requests from European customers for specific information about the chemical make-up of particular products were the most frequent types of inquiries in the beginning, but requests from all areas are now becoming more prevalent.
UNDERSTANDING INGREDIENT LIST REQUESTS
Ingredient list requests often address specific elements, such as lead or arsenic. They also frequently address complex organic compounds, such as gasoline.
Each inquiry generally is unique--making it more difficult for the responding manufacturer to formulate a "generic" reply. Two different customers may forward inquiries, each requesting information on 50 substances, but the substances, but the substances on the two lists may be quite different. Even if the requests have 20 substances in common, it still leaves 30 additional, nonoverlapping substances on each list, for a total of 80 different substances altogether.
In some industries, these "ingredient list" requests are perceived as a serious problem. Herb Robertson of Fairchild Semiconductor summarizes the situation:
We are spending lots of time communicating, mostly to European customers, the elements and compounds in our products. Sometimes, it is not just our product, but the parts in the product and the quantities of everything present. Now, we are starting to see this type of thing from American customers.
Bob Lowry, a senior scientist at Intersil (formerly Harris Semiconductor), notes that there are substantial variations in the contents of these lists and requests. In general, however, many of the substances on which information is sought can be placed in one of four categories:
Ozone depleting chemicals (ODCs),
Toxic metals,
Volatile organic compounds,
Anything from the halogen family; things that have been halogenated.
Arsenic, lead, and antimony are particularly troublesome in semiconductor manufacturing because they are widely used. Other elements or compounds create "trouble spots" for other industries.
Ingredients list requests often are accompanied by a list of chemicals and substances that the customer prohibits. These customer "ingredient bans" frequently extend far beyond what is required by the applicable regulations.
European customers tend to inquire about a long list of items because Europe uses incineration to clear waste. Because no one knows what happens to, for instance, arsenic or lead at high temperatures, these customers often are concerned about the presence of these ingredients.
Pat Kinsala, a senior process engineer with Jacobs Engineering in Dublin, Ireland, has had considerable environmental and regulatory experience, including obtaining environmental permits. At the time we interviewed him, he was not aware of any specific European Union standard that limits or prohibits most compounds. According to Kinsala, the only chemical families that have restrictions are CFCs (chlorofluorocarbons) and PFCs (perfluorocompounds), based on the Montreal protocol.
Some customers have begun marrying these ingredient list requests to the procurement/bidding/contracting process; the requests enter the business flow as opportunities to simultaneously bid and answer questions concerning your manufacturing process.
Why Are These Requests Becoming More Prevalent?
Although they frequently are couched in terms of informational inquiries, ingredient lists requests ultimately are intended to encourage toxics use reduction among manufacturers.
In many industries, product life is a short time. At the end of product life, there must be disposal. This disposal process is much simpler if there is no classified hazardous waste involved. When this is the case, the company can simply landfill or recycle.
At their inception, MSDSs were designed in part to identify (and help eliminate) those portions of manufactured products that would place the product in a hazardous waste category at time of disposal. The reason for this strategy is really quite simple: It makes end-of-life management for a product much less risky.
If a product contains a toxic or hazardous component, the customer must enter the world of hazardous waste disposal. The presence of hazardous waste requires more complex and expensive recordkeeping, reporting, storage, and transporting. It simultaneously increases costs and raises liability exposures.
PROBLEMS WITH INGREDIENT LIST REQUESTS
The whole question of what to do and how to respond to ingredient list requests is of concern to an ever-growing number of industries.
Many companies must expend considerable effort categorizing ingredient information requests and then considering how to draft a response. Often, the elements and compounds on the list are considered "irreplaceable" under present manufacturing technology, with no substitutes or new technologies on the horizon.
Most organizations have not yet developed formal response models for the information requests they receive. Most still handle each request on an individual basis.
Responding to such requests can be difficult and time-consuming. According to Lowry:
We are truthful, but we cannot indiscriminately give out proprietary information or provide a recipe and ingredients list for some 1,000 products. In addition, some situations can be excruciating. For example, not one atom of mercury is included in our products, and yet because we use mercury probes, we have disclosure issues relative to mercury.
THE PUSH FOR GREATER ENVIRONMENTAL AWARENESS AND PROACTIVITY
Behind many ingredient list requests are European "take-back" legislation and Design for the Environment movement that is now entering the industrial mainframe. The growing importance of initiatives such as these means that everyone and every organization must exhibit (and function with) a higher environmental consciousness.
Many industries are attempting to be environmentally proactive. The semiconductor industry, for example, has an excellent reputation for protecting worker safety and health. The federal Bureau of Labor Statistics consistently ranks the semiconductor industry in the top 5 percent of manufacturing industries in terms of worker safety since it has one of the lowest rates of work-related injuries and illnesses.
As early as 1985, the industry began sponsoring research into chemicals that might be linked to miscarriages, and acted on the results of that research by phasing out those chemicals. Semiconductor companies have also practically eliminated the use of ozone-depleting substances in manufacturing. Environmental Protection Agency (EPA)-measured releases and transfers of chemical waste have decreased, while production of microchips has increased.
Other sectors have also shown significant environmental improvement. In fact, almost every sector of industry, even oil and natural gas exploration, has dramatically increased its environmental awareness and continues to search for ways of minimizing its impact on the environment.
"HARMONIZING" YOUR MANAGEMENT SYSTEMS
Following the lead of many large manufacturing operations that are looking to maximize available resources, companies of all sizes are now trying to "harmonize" their management approach by integrating quality management systems (QMS), environmental management systems (EMS), and environment, health and safety (EHS) departments into one common management system that considers the needs of each business unit within the organization. This harmonized system is referred to as quality, environmental, safety and health (QESH). Such an integrated system could help companies deal efficiently with issues such as ingredient list requests through using shared resources.
Companies expend substantial resources responding to ingredient lists in order to satisfy their customers’ demands. To produce what top management wants (namely, satisfying the needs of customers), while remaining in compliance with all environmental regulations, and striving to continuously improve as an organization, companies must continue to find new approaches. Improvements must come in terms of operational effectiveness and lower costs. These improvements are much easier if an organization uses common measurements or metrics to gauge improvement, and employs common systems to track and record results and common audit methodology throughout the scope of operations.
A Better Pathway
Ingredient list requests represent a significant problem for many industrial sectors, especially since there is no real commonality in the requests, at least not at present.
Most of the requests are either generated from field marketing representatives (who receive requests directly from the customer) or are introduced as part of the paperwork that routinely accompanies procurement or purchasing communications.
In many organizations, where the request goes next is anybody’s guess. Some employees ask their superior for direction. Some refer it to an environmental officer, while still others send it to a materials handling person.
Organizations that have been ISO 14001 certified or that have instituted another environmental management system should already have identified any chemicals on the list that they handle or have present in their final product. Under ISO 14001, this would be considered a "safety aspect" (hazards and risks) and should be identified in a process similar to that envisioned in section 4.3 of the standard. Once hazards and risks are identified, the harmonized QESH approach would allow for development of objectives and targets to reduce and eliminate those hazards and risks whenever possible.
Well-managed companies should remember to consider all hazards, including those related to materials handling, process design and monitoring, and effective control of routine processes. Doing so will allow them to respond quickly when a chemical or element that they use appears in an information request or with a purchase order.
Many organizations have found valuable to organize the elements and compounds they use into a list format. They can then use the list in responding to information requests by stating why a particular element or compound is used, in what quantities, whether there are alternatives, whether alternatives are being sought where none exist, and what options are available, if any.
In some cases, customers express concern about elements or compounds for which no reasonable alternatives are available. For example, states Dave Bock, of Intersil, "A number of organizations are pushing so-called ‘lead-free initiatives’ and demanding products ultimately sold to the public be lead-free. Tin/lead solder is the standard electrical lead finish in the semiconductor industry. Right now, there are no alternatives to the lead put in solder."
In dealing with ingredients list requests, organizations can sometimes seek help from third-party registrars, some of which are able to assess a facility’s safety system concurrently with conducting ISO 14001 audits. Det Norske Veritas (DNV), for example, can issue a letter of conformance or unaccredited certificate indicating that an organization conforms to requirements of accepted safety system standards. These standards could be internal, company-created requirements. They might also be DNV standards, such as Occupational Health and Safety Management System (OHSMS), or other standards like BS 8800 or OHSAS 18001. Even ISO 14001 provides a basic framework for safety system requirements.
Any company that is working toward the harmonized, integrated pathway of QESH should note that several elements must be present in order for such an effort to be successful. They are:
- Commitment from top management. This commitment must be visible and must be backed up with sufficient resources (in terms of both personnel and money).
- An EHS policy. If one is not in place, it must be created and implemented.
- Safety aspects (hazards and risks). These should be identified through process 4.3 of ISO 14001, or through a similar process.
- Safety objectives and targets. As these objectives and targets are developed an put in place, the organization must consider all real and potential hazards and risks that have been identified, including ergonomic issues, process safety, hazardous operations, fire, explosion, and handling of hazardous materials. Approaches for dealing with hazards should include procedures related to process design and monitoring, effective control of routine processes, and basic first aid.
Organizations should also remember that the behavioral aspects of safety activities may need to be considered. In order to effectively address this facet of safety, the company may need to "test" the system more comprehensively or more frequently and ensure that is has excellent document and data control.
SUMMARY
Ultimately, ingredients list requests are designed to encourage manufacturers to continuously reduce the toxicity of the materials they design into their products, and to improve their ability to recover and recycle such materials without a negative environmental impact. The product design requirements necessary for customer satisfaction are continually evolving and are moving beyond just considering cost, time to market, and performance.
With ever-tightening legislation in Europe and elsewhere, manufacturers must accept a reasonable amount of the responsibility for ensuring the marketplace that their products are designed and manufactured with full consideration of environmental implications and effects. A first step in this direction is to eliminate toxic and harmful materials from both products and processes whenever possible. As toxics are removed, ingredients lists will become shorter.
Since most ingredient list requests originate from government, customer, and private label requirements in concert, prudent organizations should already be searching for alternatives to the items that frequently appear in these lists, and should be seeking to minimize related environmental objections whenever possible.
As customers face increasingly stringent requirements relating to the disposal of products at the end of their useful life, suppliers are going to face equally stringent requirements relative to their products and processes. If suppliers want to avoid barriers to commerce, they should recognize the concerns that give rise to these ingredient list requests, and see them as warning signs. They should also consider the obvious benefits of integrating and harmonizing quality, environmental, health and safety systems whenever possible.
|
