PROGRAM GUIDELINES & FREQUENTLY ASKED QUESTIONS

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1 The document provides additional RTM program guidance via a listing of frequently asked questions (FAQs) and corresponding answers. The FAQs are categorized according to the following areas: RTM Applicability and Scoring System Interaction with Supplier Facilities Consideration for Management Systems Implementation RTM Verification Process I RTM APPLICABILITY AND SCORING SYSTEM Questions regarding membership requirements for RTM Certification. Q: Who is required to complete the RTM Certification Program? A: PSTC Manufacturer Member Companies are required to complete the RTM Certification. PSTC Affiliate Supplier Member Companies do not manufacture tape, and therefore do not apply for RTM Certification. However, Affiliate Supplier Members may be asked (by a Manufacturer Member with whom they do business) to provide information that relates to RTM Certification. Companies who are not PSTC members are not eligible to apply for RTM Certification. Q: What are the PSTC membership requirements for RTM Certification? A: PSTC Manufacturer Members are required to maintain their RTM Certification. All PSTC Manufacturer Members are currently RTM certified, and will re-certify every three years (or as required by the Program). Regarding RTM coverage, note that only pressure sensitive adhesive (PSA) tapes are represented by PSTC and are in scope for RTM. Q: My products use the same materials of tape, only different by application and dimension (e.g., adhesive shelf liners, correction tape on a roller, and friction tape or similar tape used for safety purposes. Are these considered in scope for RTM? A: These examples do not represent the definition of PSA tapes and are not in scope. Q: My tape products have a function outside of standard masking/duct/electrical tape functions (e.g., rolls of adhesive-backed foam used to provide cushion to seal windows, decorative tape, and sheets of tape). Are these considered in scope for RTM? A: These examples do represent the definition of PSA tapes and thus are in scope for RTM. Q: My products adhere like tape but do not come on a roll or look like tape (e.g. adhesive lined door bottoms, roll on window kit film). Is this considered in scope for RTM? PSTC RTM Certification Program Page 1

2 A: These examples do not represent the definition of PSA tapes and are not in scope. Note that a separate roll of masking tape included in the box represents a PSA tape, but adhesive coated onto the top of the film does not. Q: My products adhere like tape but do not have the same materials as most tapes (e.g. rope caulk decals, stickers made from tape, correction tape on a roller). Are these considered in scope for RTM? A: These examples do not represent the definition of PSA tapes and are not in scope. Q: My products contain tape as a component, (e.g. window kit with film and tape, craft kits, packaging tape with dispensers, insulation kits). Are these considered in scope for RTM? A: The tapes in these examples do represent the definition of PSA tapes and thus are in scope. The final kit product does not represent the definition of PSA tapes and are not in scope for RTM. Q: Does RTM apply to all products made/distributed by the facility, including non-tape products? A: Non-tape products are not included under RTM. Q: How do we respond to questions where we may have a YES! for some products and not for others? Example 1: We have a traceability program for certain tape products, but no traceability program for other tape products. What would be the appropriate RTM score here? A: RTM applies to all tape products. The likely answer in response for such a facility for that question would be a 4, designating that you have a system/standard and incomplete execution. Example 2: We have reformulated some non-tape products to reduce the footprint of certain chemicals but not reformulated tape products. What would be the appropriate RTM score here? A: RTM applies to all tape products. The likely answer in response for that facility for that question would be a 4, designating that you have a system/standard and incomplete execution. Example 3: We have certain practices with products manufactured at the facility but different practices with products converted at the same facility. What would be the appropriate RTM score here? A: RTM applies to all tape products. The likely answer in response for that facility for that question would be a 4, designating that you have a system/standard and incomplete execution. PSTC RTM Certification Program Page 2

3 II - INTERACTION WITH SUPPLIER FACILITIES The inclusion of contract facilities, converters and purchased finished goods (purchased between January 1, 2016 and June 30, 2016) is determined by the definition of the manufacturing process of a PSA tape. Q: We purchase a finished PSA tape from a converter. Am I required to ascertain who the original manufacturer is and verify that company or is this product purchased from a converter outside the scope of the program? A: The converting process alone is out of scope of RTM. However, the final tape product sold by your company is within the scope of RTM. Therefore, if the converter is not the manufacturer of the PSA tape, either they should pursue on your behalf without disclosing the company or provide you the necessary contact information for you to pursue. Q: We manufacture a semi-finished tape product. We then send this semi-finished good to a converter (either overseas or in the US) who then either creates a finished good or another semi-finished good from this material. Am I required to verify the converter? What if this converter is an overseas facility, distributor or broker? A: The converting process alone is out of scope of RTM. This is true regardless of the location or ownership of the converter company. Q: We purchase a product that contains multiple components: One of these components is a tape. Is every factory that manufactures components in the kit subject to verification? A. No, only the tape component of the kit falls within the scope of RTM. The manufacturer of that tape is several steps back in the supply chain. Is that original manufacturer in scope in this program for verification? A: Yes, they are if you are selling your final product in the US. Q: Are my raw material suppliers in scope of the RTM program? A: Raw material suppliers (example paper, film, foil, chemicals) are not within the scope of RTM Raw material management is within the context of the PSTC members responsibility for managing its own facilities safety programs or is in the context of labor and chemical product stewardship practices. PSTC RTM Certification Program Page 3

4 Q: The program document says that purchased raw materials are outside the scope of the RTM and that only manufacturing operations are subject to the program but then there are specific questions in the verification around these raw materials and facility-wide conditions. Can you clarify? Example 1: In the Chemicals section, there is the following question: The facility maintains a comprehensive inventory of all hazardous chemicals onsite. A. This question is specific to the PSA tape manufacturing operation s safety. It does not require you to verify your raw material supplier. It does require you to have a robust safety program. Example 2: In the Chemicals section, there is the following question: Does the facility maintain a chemical inventory of ALL chemicals utilized at the facility including trace quantities of chemicals in ALL raw materials? A. This question is specific to the PSA tape manufacturing operation s compliance with chemical inventories. It does not require you to verify your raw material supplier. It does require you to have a robust chemical inventory program, e.g., TSCA compliance. Example 3: In the Product Stewardship section, there is the following question: The components of facility products are sourced legally, in accordance with applicable governmental laws, conflict minerals, heavy metal content (CONEG in the US). A. This question is specific to the PSA tape manufacturing operation s compliance with regulations specific to chemical content laws of finished products. It does not require you to verify your raw material supplier. It does require you to have a robust program that either obtains certifications from your suppliers and/or product testing. Q: Several references are made to Suppliers in the RTM Document: Do I need to have each supplier comply with RTM? A: This depends - If supplier manufactures, produces or supplies tape or tape products, then Yes. - If supplier supplies or provides adhesive, solvent, paper, film, cores or packaging materials, then No. PSTC RTM Certification Program Page 4

5 III - CONSIDERATION FOR MANAGEMENT SYSTEM IMPLEMENTATION Information regarding ISO 9001 and TS Q: Is a company s ISO 9001 or TS certification considered sufficient proof of conformance with the quality and laboratory elements on the scorecard? A: ISO 9001 is a program that requires effective management of quality and laboratory environmental issues. The program requires that an organization develop and maintain practices and procedures that support quality and laboratory practices. It is PSTC s judgment that an ISO 9001 certification would allow a site to achieve full credit (100%) for the following RTM elements: Manufacturing Guidelines and Laboratory Guidelines. A current copy of the certification as of the date of submission of the scorecard must be provided. Information regarding ISO Q: Is a company s ISO certification considered sufficient proof of conformance with the environmental elements on the scoresheet? A: ISO is a program that requires effective management of environmental issues. The program requires that an organization develop and maintain practices and procedures that support environmental stewardship. It is PSTC s judgment that an ISO certification would allow a site to achieve full credit (100%) for the following RTM elements: Air, Waste, Water, and Chemical. A current copy of the certification as of the date of submission of the scorecard must be provided. Information regarding OHSAS Q: Is a company s OHSAS certification considered sufficient proof of conformance with the workplace elements on the scoresheet? A: OHSAS is a program that requires effective management of occupational health and safety issues. The program requires that an organization develop and maintain practices and procedures that support workplace stewardship. It is PSTC s judgment that an OHSAS certification would allow a site to achieve full credit (100%) for the following RTM elements: Safety and Industrial Hygiene. A current copy of the certification as of the date of submission of the scorecard must be provided. PSTC RTM Certification Program Page 5

6 Information regarding ISO Q: Is a company s ISO certification considered sufficient proof of conformance with the laboratory guidelines element on the scoresheet? A: ISO is a program that requires effective laboratory testing and calibrations. It is PSTC s judgment that an ISO certification would allow a site to achieve full credit (100%) for the following RTM element: Laboratory Guidelines. A current copy of the certification as of the date of submission of the scorecard must be provided. PSTC RTM Certification Program Page 6

7 IV - RTM VERIFICATION PROCESS Questions regarding the third-party verification and overall administration of this program. Q: What is the schedule for completion of RTM Version 3 conformance requirements? A: RTM Version 3 documentation will be available for access from the PSTC website beginning January 2016 with completion of conformance demonstrated by November Refer to the RTM Program document for a detailed schedule of milestone dates. Q: How much documentation do we need to obtain from facilities (particularly supplier facilities) to substantiate their scores? A: PSTC s motto is A bond you can trust. The amount of supporting documentation is a decision of trust based on the company s relationship with each facility. A company is expected to be diligent as it evaluates and substantiates scores. With that said, PSTC members should consider themselves to be in the role of the third party verifier when evaluating facilities. Members need to understand their suppliers basis for scoring (via explanatory Notes) and examine sufficient objective evidence to support the scorecard information, including searches for publicly available compliance documentation if required. Q: What would constitute sufficient objective evidence? A: PSTC members are not expected to conduct an exhaustive examination of all documentation that signifies RTM conformance. Rather, member companies need to review the background information thoroughly enough to ensure that Environmental, Workplace and Quality practices meeting RTM criteria are in place. This would entail viewing such items as cover pages and tables of contents for environmental permits, EHS/Quality procedure documents, monitoring summaries, and other program plans. Please refer to the successfully completed scorecard attached to this FAQ and to table A1 & A2 in RTM program document. Q: Will the third party verifier visit each facility? A: No RTM is a self-verification process. Each facility is responsible for completing its own scorecard. Q: What happens if a facility isn t able to achieve a passing score by the target conformance date? A: The following options are available PSTC RTM Certification Program Page 7

8 Compose a Corrective Action Plan that will allow additional time to work toward conformance (likely 1-2 months for example); or Stop using this facility; or Forgo RTM certification and the corresponding benefits RTM provides Q: What is PSTC going to do with the completed scorecard and Corrective Action Plans? A: Scorecards and Corrective Action Plans are not to be sent to PSTC. Scorecards and Corrective Action Plans are company confidential. PSTC will receive only the member company s Declaration of Conformance. Information regarding PSTC manufacturer members who do business with other PSTC manufacturer members. If you do business with a PSTC member company (i.e., Member to Member), you may elect to provide a complete score card with supporting documentation or you may elect to provide a signed scorecard only to the requesting company. When providing only a signed scorecard to the requesting company the following steps must be followed: 1. Member requests scorecard from Supplying Member Company 2. Member Company provides scorecard to requesting Member Company. 3. Requesting Member Company now has sufficient information to complete conformance declaration. 4. Requesting Member Company and Supplying Member Company both advise third party verifier of business interaction. 5. Supplying Member Company provides Requesting Member Company Final scorecard signed by third party verifier. Definitions Data is complete if it is sufficient to substantiate the score claimed by the supplier, or that the supplied company is willing to accept PSTC supplying is defined as each of your facilities that provide to other PSTC member companies. Questions regarding documentation that is not in English Q: What do I do if the documentation I receive is not in English? A: Any non-english language documents should be either be translated into English (not mandatory), or have explanation of the document contents PSTC RTM Certification Program Page 8

9 Information regarding a Corrective Action Plan (CAP) Your company may be utilizing a CAP if: A facility of your own does not meet the required score and is taking actions to correct this in order to reach that score; A tape supplier you do business with does not meet the required score and is taking actions to correct this in order to reach that score Your Review Meeting reveals a need for a CAP. This is to be identified directly with the review company with the plan detailed and the deadline for completion is established. Upon completion of your CAP, you should communicate directly with the third party verifier so that they can conclude your Review. Questions regarding the Review Meetings You will be able to set the Review Meeting when: You have prepared the scoresheets and supporting documents for your tape manufacturing locations; You have gathered the scoresheets and supporting documents from the manufacturing facilities that you purchase tape from (suppliers). Remember: If you purchase tape from another member company, see attached for a description of your options. You have sent PSTC a copy of your signed Declaration of Conformance indicating that you have met the criteria of the program and are prepared to schedule your Review Meeting. If you are still awaiting information from a tape supplier and expect it before your Review Meeting, or if you are making corrective actions with a current facility, you can still schedule your Review Meeting. Be prepared to describe the Corrective Action Plan and timelines with the reviewer. Information regarding final certification/re-certification You are re-certified as a Responsible Tape Manufacturer when: The manufacturing facilities for all of the tape you sell in North America have obtained the minimum required score as verified by the reviewing company. All members are encouraged to attend the RTM training sessions schedule for May 2016 for an open discussion/questions that are not addressed in this document. December 2015 Pressure Sensitive Tape Council (630) PSTC RTM Certification Program Page 9