Collection of chemical substance content information Revised March 1, 2012 December 12, 2008 Panasonic Corporation We deeply appreciate your day-to-day cooperation in the Panasonic Group's environmental activities. In this section, I will explain the overview of the scheme of Collection of chemical substance content information in the Panasonic Group. 1
Collection of chemical substance [ content information ] 1. Initiatives across the Industry 2
Upstream company Substance, Preparation MSDS is provided together with products Issues to be Solved regarding Information Flow on Chemical Substances Contained in Products Midstream company (Upper) Original Article Midstream company (Middle) Article (subassy) Heavy burden on supplier training Chain of research instructions Chain of response to research Midstream company (Lower) Article (subassy) Various forms of research instructions Downstream company Finished Article Response to various forms of research instructions Inefficiency due to midstream information interruptions Research on chemical substances contained in products had to be led by downstream (assembly) makers, to comply with EU Directives and other related regulations. I would like to give you some information about industrial trends. Because the RoHS Directive targets finished products, downstream companies have issued requests to upstream companies for research on chemical substance content. Various forms of research instructions were issued, asking about a wide range of items. Therefore, upstream and midstream companies needed to give tailor-made responses to different customers, causing inefficiency in information communication throughout the supply chain. 3
Standardizing the "Substance Scope" and the "Information Communication Format," considering the response to the REACH Regulations. Japan Article Management Promotion Consortium (JAMP) Appropriately manage information of chemical substances, etc. that are present in articles. Establish the concrete structures necessary to disclose or communicate the information smoothly within supply chains. This is essential for improving competitiveness of the global industry. JAMP was established in September 2006 as a private organization to lead cross-industry activities (396 member companies as of January 20, 2012 ) http://www.jamp-info.com/ Proposal for common tools 17 promoter companies Asahi Kasei Corporation Kao Corporation Sumitomo Chemical Co., Ltd. Seiko Epson Corporation DIC Corporation TDK Corporation Toshiba Corporation Hitachi, Ltd. FUJIFILM Corporation Fujitsu Ltd. Cross-Industrial Initiatives Panasonic Corporation Mizuho Information & Research Institute, Inc. Mitsubishi Chemical Corporation Mitsubishi Electric Corporation Murata Manufacturing Co., Ltd. Lion Corporation Ricoh Company, Ltd. Upstream corporations (substances, preparations) MSDS MSDSplus Mid-stream corporations (molded articles) AIS (composite part) AIS (original parts) Disclosure/ communication Disclosure/ communication Disclosure/ communication Conventional procurement/surveys (Updated versions) Downstream corporations (finished products) Procurement/ surveys In this context, upstream chemical manufacturers, midstream device makers, and downstream appliance makers jointly established the Japan Article Management Promotion Consortium (JAMP), which has pushed forward measures for establishing a cross-industrial scheme for information communication. It has standardized the scope of chemical substances for which information communication is required, and the format for communication. 4
Information Communication Formats Proposed by JAMP Chemicals industry (upstream company) Device industry (midstream company) Finished products industry (downstream industry) Information where communication is mandatory for chemical substances Provides MSDS and MSDSplus to the articles industry Converts the above into AIS and communicates it downstream Based on the information of AIS, manages the controlled substances contained in products Legislation information relevant to chemical substances Content information for declarable substances regarding articles Chemicals industry MSDS MSDSplus Parts industry AIS of original parts AIS Finished products industry JIG, IMDS etc. MSDS MSDSplus AIS of original parts AIS Used as AIS MSDS MSDSplus Compound AIS Chemical/physical changes at this stage (Information conversion required) MSDS: Material Safety Data Sheet MSDSplus: Material Safety Data Sheet plus AIS: Article Information Sheet Management Guidelines for Chemical Substances Contained in Products This slide shows the information communication formats proposed by JAMP. MSDS has been used for communicating information on substances and preparations from upstream companies (materials suppliers) to midstream companies. MSDSplus has been established as an additional format to supplement MSDS, with an extended substance scope in response to the REACH Regulations. "AIS" stands for Article Information Sheet and it has been established for communicating information on articles from the midstream parts makers to downstream companies. In addition to these formats, the Management Guidelines for Chemical Substances Contained in Products have been established as a guide to chemical substance management operations. 5
Challenges in Identifying SVHC Content SVHC in the REACH Regulations will be progressively* selected from some 1,500 specified hazardous substances. * About every six months Repeated information collection will be required in response to the addition of new SVHC. Scope for possible designation of SVHC in the REACH Regulations To be added 8 substances (Third candidates) 15 substances (Second candidates) 15 substances (First candidates) Added progressively SVHC List http://echa.europa.eu/web/guest/candidate-list-table First, I would like to describe the challenges we face in identification of SVHC content. SVHC in the REACH Regulations will be progressively selected from some 1,500 specified hazardous substances. The inclusion started with 15 substances, and a total of 15 substances were included in January and March of 2010. Another 8 substances were included in June 2010, and after that, substances are added every six months. Because ECHA officially announces substance inclusion every six months, SVHCs are added progressively, which means that we must repeat collection of information many times if we responded to announcements each time. 6
Substances in Scope of Management by JAMP JAMP specifies a common substance scope for information communication, covering possible SVHC in the REACH Regulations. Carcinogenic Categories 1 & 2 Mutagenic Categories 1 & 2 Toxic to Reproduction PBT and vpvb Substances (Residual + Bioaccumulative + Toxic + Highly Residual + Highly Bioaccumulative) (REACH Annex XIII) Categories 1 & 2 + + Endocrine-disruptive features Residual + Bioaccumulative + Toxic Highly Residual + Highly Bioaccumulative (Substances excluded from REACH Annex XIII) Substances in the scope of management by JAMP 1. Scope for possible designation of SVHC in the REACH Regulations EU CLP Regulation, CMR Substances (Categories 1 & 2) Substances for PBT determination & notification in ESIS*1 *1:European chemical Substances Information System 15 substances (First list) Added progressively 2. Substances specified by other laws and regulations EU Directives RoHS & ELV EU REACH Regulation, Annex XVII Japan Chemical Substances Control Law (Class 1 specified chemical substances) Japan Industrial Safety and Health Law (substances whose manufacture is prohibited, etc.) The Japan Poisonous and Deleterious Substances Control Law (specified toxic substances) Therefore, to minimize the need for repeated information collection in response to the addition of new SVHC, JAMP has specified a common substance scope for information communication, covering possible SVHC in the REACH Regulations. This scope comprises the scope for possible designation of SVHC in the REACH Regulations, and substances specified by other laws and regulations. 7
Summary of JAMP Declarable Substances Revised in January 2012 to correspond with the latest JIG and AIS Ver4 (Ver 3.000) Code JP01 JP02 JP03 EU01 EU02 EU03 EU04 EU05 EU06 OT01 IA01 IA02 Poisonous and Deleterious Substances Control Law (Prohibited substances for manufacturing etc.) PRTR Law (Specified poisonous substances) EU RoHS Directive EU ELV Directive EU CLP Regulation Annex VI Table3.2 CMR-Cat.1,2 REACH Regulation Annex XVII Restricted substances [Excluding: CLP Regulation Annex VI Table 3.2 CMR - Cat1,2] Candidate substances under REACH authorization (SVHC) EU POPs Regulation Annex I ESIS PBT (Part corresponding to PBT criteria) GADSL Declarable Substance Criteria Industrial Safety and Health Act (Class I Specified Chemical Substances) JIG (Correspond to JIG-101 Ed 4.0 and later) Application MSDSplus AIS - - - (Ref.) The list of JAMP declarable substances http://www.jamp-info.com/list The JAMP declarable substances cover almost all the chemicals that may be specified as SVHCs under the REACH Regulation. A revised version was published in January 2012 in order to reflect updates in the management of substances in specific industries, such as information specified as SVHCs or substances subject to authorization, addition of restricted substances, and JIG that are substances subject to green procurement investigation in the electronics industry. This is compatible with MSDSplus and AIS Input Support Tool that were also updated in January 2012. 8
JAMP Tools: Declarable Substance List http://www.jamp-info.com/english Be sure to ensure to download and read through respective documents. (The following image is a sample. Be sure to confirm the latest version.) To see JAMP declarable substances, download the relevant documents from the JAMP website and refer to the contents. 9
Collection of chemical substance [ content information ] 2. Initiatives by the Panasonic Group 10
Panasonic Group Chemical Substances Management Rank Guidelines (for Products) Substances under the Scope of Management by Panasonic Group Rank Prohibited Substances Level 1 Level 2 Definitions A substance that is prohibited by an existing law or regulations from being present in products A substance that will be prohibited from being present in products by a law or regulations within one year of the revision of these guidelines A substance that has been notified, in Environmental Notices issued by the Panasonic Group, as being prohibited from being present in products A substance that will be prohibited from being present in products after a certain period by a treaty, law or regulations A substance that is prohibited from being present in products by the Panasonic Group, prior to the effective period specified by a treaty, law or regulations A substance whose use is voluntarily restricted by the Panasonic Group A substance whose consumption needs to be monitored, and for which consideration needs to be given to human health, safety and hygiene, adequate treatment, etc. Managed Substances The intentional use of these substances is not restricted, but their use and content level must be monitored. Rank Guidelines latest Version * See the Panasonic website for the latest version. http://panasonic.net/procurement/green/ Reflects revision to the JAMP declarable substances, and marketing restrictions in the EU Rank Guidelines latest Version Panasonic's Prohibited Substances (Levels 1 & 2) Panasonic's Managed Substances Substances in the scope of management by JAMP latest Version Next I will introduce the initiatives by the Panasonic Group. The Panasonic Group manages chemical substances based on the Panasonic Group Chemical Substances Management Rank Guidelines for Products. Taking into consideration the latest movements in the EU Directives and the REACH Regulations, the Panasonic Group revises the Rank Guidelines on an as-needed basis and specifies "Prohibited Substances" and "Managed Substances". Panasonic's Prohibited Substances and Managed Substances correspond to the JAMP Declarable Substances provided by JAMP. 11
Formats for Information Communication to Panasonic Group Applicable formats will be notified by the requesting department of the Panasonic Group. Normally For identifying the presence of substances prohibited or managed by the Panasonic Group If all composition need to be identified In response to requests from Panasonic's customers (e.g., response to IMDS for automotive industries) Scope Panasonic Rank Guidelines latest Version (Prohibited & Managed Substances) Substances in the scope of management by JAMP latest Version Substances in the scope of JIG Substances in the scope of GADSL All parts Formats for information communication from suppliers to the Panasonic Group Preparations Existing MSDS JAMP MSDSplus Existing MSDS Complete Preparation Composition Sheet Panasonic Device Department Articles JAMP AIS MSDS: Material Safety Data Sheet MSDSplus: Material Safety Data Sheet plus AIS: Article Information Sheet JAMP AIS (Enter all parts) I would now like to explain about the formats for information communication used by the Panasonic Group. Several formats are used for information communication from suppliers to Panasonic. Applicable formats will be notified by the requesting department at the Panasonic Group. Normally, information communication is required for the prohibited and managed substances specified in Panasonic Rank Guidelines latest Version. The existing MSDS, as well as MSDSplus to supplement it as a format, will be used for preparations. AIS will be used for articles. At departments that produce original parts such as electronic parts and semiconductors, it is sometimes necessary to identify all compositions in response to requests from Panasonic's customers. In such cases, Panasonic's Complete Preparation compositions Sheet is used as a specific format for preparations. AIS will be used to identify all compositions of articles. Suppliers may be asked to enter all compositions in AIS. 12
The JAMP Website JAMP's tools are available to general users from its website. http://www.jamp-info.com/english Tools JAMP's tools are available to general users from its website. Tools and manuals in English and Chinese versions are also available. However, please note that downloading procedures are explained in Japanese. Suppliers for the Panasonic Group can download the files from the GP-Web manual screen, which I will explain in the next slides. 13
JAMP Tools: MSDSplus https://eww.gpscmn.panasonic.co.jp/prtl (For Supplier) http://www.gpscm.mei.co.jp/prtl (For Panasonic internal use) If your company supplies articles, please ensure to download and read through all the documents. (The following image is a sample: confirm that you have the latest version.) (1) (2) In the GP-Web, you can download various tools from the manuals page. If your company supplies preparations, please download the files relating to MSDSplus, and refer to the contents. 14
JAMP Tools: AIS https://eww.gpscmn.panasonic.co.jp/prtl (For Supplier) http://www.gpscm.mei.co.jp/prtl (For Panasonic internal use) If your company supplies articles, please ensure to download and read through all the documents. (The following image is a sample: confirm that you have the latest version.) (1) (2) If your company supplies articles, please download the files relating to AIS, and refer to the contents. 15
Collection of chemical substance [ content information ] 3. Requests 16
Requests to Suppliers (General) 1. Re-establishment of the scheme for information collection in response to the REACH Regulations - A scheme for obtaining required information from upstream manufacturers - Identification of personnel in charge (for data compilation & change control, formulating reporting formats, etc.) - Upgrading REACH compliance at your business units and overseas sites 2. Provision of chemical substance content information on your products - Promoting the collection of chemical substance content information on the relevant products from upstream manufacturers - Chemical substances in the scope (Equal to Substances in the scope of management by JAMP latest Version) - Prohibited & Managed Substances in Rank Guidelines latest Version - Substances in the scope of management by JAMP latest Version - Substances in the scope of GADSL (automotives industry) - Format: JAMP Format MSDSplus AIS latest Version - Applicable part numbers: To be notified from the Panasonic Group s departments concerned 3. Consideration to join JAMP and utilize JAMP information distribution Your submissions will form the basic data for REACH compliance. Make sure that the information you provide is accurate. Now, I would like to explain about requests to suppliers. First, you should upgrade the scheme for information collection on chemical substance content at your company. This comprises the following actions. First, establish a scheme for obtaining required information from upstream manufacturers. When doing this, utilize the JAMP formats as far as possible since it is important to standardize the method of information communication throughout the supply chain. Second, identify the person in charge of data compilation & change control, formulating reporting formats, etc. Through these initiatives, please provide chemical substance content information on your products. First, please promote the collection of chemical substance content information on the relevant supplies from upstream manufacturers. The applicable part numbers, etc., will be notified from relevant departments of the Panasonic Group. Third, please consider joining JAMP and utilizing the JAMP distribution information. Your submissions will form the basic data for REACH compliance. Make sure that the information you provide is accurate. 17
Action Flow at Suppliers Articles and Preparations Supplier Panasonic G Request for rechecking for parts / preparations that require data updating (1)Data request from Panasonic e-mail + (2)Collect data back through the supply chain (Scope: Rank Guidelines Ver. (latest Version) or all ingredients) (3)Identify compositions and chemical changes through your process (4)Aggregate data on the chemical substances contained in your products and prepare AIS / MSDSplus (Rank Guidelines Ver. (latest Version) or all ingredients) GP-Web Request for data on new parts / preparations (6)Updated AIS / MSDSplus data (or entry from screen) (5)Prepare new AIS / MSDSplus data In some supplier situations, AIS / MSDSplus may be prepared using existing GP-Web data for parts / preparations. This is about providing information about products such as parts and preparations that you deliver to Panasonic. The Panasonic Group will send you a list of covered products via email. Please refer to the latest version of the Rank Guidelines, and go back the supply chain to collect information. As the same time, please identify the compositions and chemical changes through your process. With those information, tabulate the data on the chemical substances contained in your products, and proceed to preparing AIS and MSDSplus. When you have prepared the AIS and MSDSplus, please provide us with the information through the GP-Web. In the event Panasonic requested information on existing parts through the GP- Web, please update the information by uploading the AIS data, or in some cases revise/review the existing data from the Web screen so that it corresponds with the latest version of the Rank Guidelines. Although we would like to ask you to prepare a new AIS in principle, downloading existing registered data is also acceptable, according to the supplier's situation. In addition, when submitting the MSDSplus, please also submit MSDS together if it had not been submitted before. If Panasonic needs to identify all compositions, it may request entry in the GP- Web. 18
3 levels for submitting responses Level Rn (R6) Banned substances + announced SVHC Objective Within the interim response to Panasonic. Use when response is unfeasible for M80 etc. due to lack of time. Final response must be in M80, D80 Feature Relatively narrow scope of substances; facile confirmation Mn0 (M80) Banned substances + declarable substances Dn0 (D80) All substances Panasonic's standard management level Management level regarding products/components for the automobile industry Covers future SVHC candidates Includes information on safe substances If time is needed to respond, submit an interim response in Rn standards first and then submit an official response in Mn0 level within a few months. The level of information that needs to be submitted to Panasonic is as follows. Information of content within the range of declarable substances is the basic rule in JAMP. However, for suppliers that do not have sufficient content information regarding the products they handle, 3 types of standards are set. Those are: standard R, which is to be responded within the range of SVHC that have already been announced as a banned substance, standard M which is equivalent to the JAMP basic standard mentioned earlier, and standard D which requires response for almost all content information including safe substances. However, because standard R is an interim response for Panasonic, please respond in standard M with the necessary content information as soon as possible after submitting the response in standard R. 19
Recommendation for Participation in JAMP and Use of JAMP Information Distribution Infrastructure Recommendation for Enrollment in JAMP Privileges: 1) Exclusive information provision, etc. - Reports on Committee activities (materials, minutes, etc.) - Inviting input on Committee activities, etc. - Notifications on presentations and seminars - Update developments of EU Directives, etc. 2) Participation through inputs and direct involvement in Specialized Committees for guideline development, etc. For details, visit: http://www.jamp-info.com/english/entry Recommendation for Use of JAMP Information Distribution Infrastructure - Information infrastructure is being established to improve efficiency in information distribution across the supply chain. - Application service providers have started business operations to support data exchange, which you can utilize as appropriate. Establishing social infrastructure that combines chemicals information seamlessly Your Supplier Supplier company Customer Customer Information flow of chemical substance content in products MSDSplus Management Guidelines AIS Sound information distribution Information distribution infrastructure (GP/AS) Support for Sees For details, visit: http://www.biz.jemai.or.jp/jamp-gp/ Last but not least, please consider enrollment in JAMP, the Joint Article Management Promotion consortium, which has established a crossindustry scheme for information communication, as I have outlined. Membership privileges include exclusive information provision such as: - Access to the report on Committee activities, such as materials, minutes etc.; - Invitation for inputs on Committee activities etc.; and - Notification on presentations, seminars, and update developments of EU Directives, etc. Members can also participate through inputs and direct involvement in the Specialized Committees for Guideline Development, etc. Standardization of information communication must be achieved through the joint efforts of key players in supply chain. JAMP is promoting the establishment of a portal service to support global information distribution, with the aim of improving efficiency in information distribution across the supply chain. Application services and their standardization are also planned for supporting data transmission through the above infrastructure. Please consider utilizing such services if you are interested in improving efficiency in information communication. 20
Panasonic Plan for Utilizing the JAMP Information Distribution Infrastructure Device business Assembly business Part table Part Part Part GP-Web system Customer Customer company; Panasonic's European sales company Supplier Supplier Link via JAMP-IT Information collection Contained chemical substances Terminal Material Substance フィルタ Filter Power 電源 supply Electrode Material Substance Transformer トランス Material Substance Information processing by product Approval Tabulated data AIS information communicati on sheet Reply to customer Link via JAMP-IT AIS information communicati on sheet RICOH, NEC, Hitachi, Toshiba AIS information communicati on sheet Panasonic collects information from, and provides information to, key players in supply chain, utilizing the JAMP scheme for information communication. In order to obtain information available to suppliers promptly, and to efficiently forward it to customers, we connect with the global portal for the JAMP information distribution infrastructure. Suppliers who wish to receive information via information distribution infrastructure JAMP-IT should contact the GP-Web helpdesk through Panasonic's procurement division. Also, suppliers who wish to receive information on parts sold by the Panasonic Group via information distribution infrastructure JAMP-IT should contact Panasonic's sales division. 21