Case Study: SVHC management with the DEKRA "Product Chem Risk" tool. Jochen Dettke, DEKRA Assurance Services

Transcription

1 Case Study: SVHC management with the DEKRA "Product Chem Risk" tool Jochen Dettke, DEKRA Assurance Services

2 SVHC Information Obligation Art. 33: The supplier of an article has to inform the recipient, if > 0,1 % (w/w) of a candidate list substance is in the article. Old understanding: The object that is supplied is the article. The threshold refers to total weight of this object. EUCJ decision ( ): Once an article always an article The object that is supplied usually is a complex product, containing a number of articles. The threshold applies for each article in the product. 2

3 Case Study: SVHC Management in Tool Trading Firm Outline: 1 product line with articles 1 product line with articles Bad experience: client has found SVHC in a product in the past Decision: No SVHC in our products! How can this be handled? 3

4 How to Obtain Information on SVHC Laboratory Testing Supply Chain Communication Databases 4

5 How to Focus SVHC Testing Mixed samples All articles of a product All candidate substances All materials All candidate substances All materials Candidate substances choice driven by material. Candidate substances choice driven by material Screening 5

6 Laboratory Testing Risk Based Screening Module 1: Inorganic Metal Compounds Pb, Cr(VI), As, B, Sn, Cd, Co for the largest part of materials (e.g. alloys, polymers) Module 2: Abundant Organic Compounds e.g. Softeners, Nonyl phenols, Flame Retardants, PAH, etc. for polymers, textiles, etc. Module 3: Colorants Azo-dyes Dispersioncolorants Module 4: Solvents Alkanes Other Solvents Module5: Coatings Fluoride Optional: Fluor carboxylic Acids Module 6: Polymers Polymerization Educts Module 7: Special Substances Fragrances, Hydrazine, etc. For colored textiles For liquid samples For coated materials In raw substances Special cases 6

7 Supply Chain Communication Signed Declaration Supplier Evaluation Supplier Development 7

8 Case Study: SVHC Management Process Product description no No testing, no supply chain communication necessary Risk assessment: SVHC > 0,1 % yes Ask supplier for test report and on SVHC management Test report Statement on SVHC management No reply from supplier Evaluate Evaluate No laboratory testing yes OK? no Laboratory testing SVHC-Risk < 0,1 % no SVHC yes Drop product or change supplier > 0,1 % 8

9 Risk Assessment with a SVHC Database 9

10 DEKRA Tool: SIM Database Substances: REACH candidate substances Material groups: 11 elastomers 21 thermoplasts 13 duroplasts 13 colours 16 natural products 11 stone, glass and ceramics types 17 metals 30 groups for electronics parts and materials Special materials Data generation: Annex XV Dossier Public databases Expert judgment Observations from the DEKRA laboratory 10

11 ipoint User Interface ipoint: Well-known IT-solution provider in the IMDS context Sustainhub as cloud-based portal with specific apps Conflict minerals reporting tool, etc. Product Chem Risk Cloud based Database module Reporting module BOM module 11

12 Pro s & Con s in Case Study + SVHC information for each article + Suitable for products of medium complexity + Supports zero SVHC goal + Supports materials choice in the design phase + Supplier information can be included + Testing minimized Time and effort for frequent changes in the product portfolio Time and effort for supply chain communication and evaluation 12

13 Summary PCR Tool Material based Focus on high-risk parts Reporting for customer communication Comes with updates of candidate list More regulated substances to be included (POP, etc.) SVHC management approach pragmatic efficient Improves compliance status 13

14 Links PCR Freemium license: 6 materials Request quotation for PCR full license: Additional information on DEKRA & REACH: Information on Process safety: 14

15 Contact: Jochen Dettke Product Manager Chemical Regulations and Product Sustainability DEKRA Assurance Services GmbH Tel.: 0711/