Conformity Magazine - July 2008 - (Page 33)

What else do I need to know? We recommend that you review every last item that you box up and ship to Europe. You may find, as some of our clients have, that your main product may well be an article but with it you ship substances or preparations or who-knows-what, like glues, lubricants, primers, paints, adhesives, desiccants, and so on. This will open up other Pandora’s boxes related to REACH that again are beyond the scope of this article, but not beyond the scope of your concern. Finally, if you think this is the end, you’re mistaken. China is already developing, and may by this time have already issued, it’s REACH-like regulation. Here at home in the U.S., there is a growing movement among states, NGOs, and even industry titans to review and potentially revise the aging American chemicals policy (i.e., the Toxic Substance Control Act of 1976). And don’t forget to review your products against the revised and soon-to-be in-force EU Battery directive, the review of the RoHS directive that’s currently taking place, and the Energy-using Products directive. One of the key challenges of REACH is that communication through the supply network will have to change. It will no longer be unidirectional, with OEMs expecting information flow to be to them alone. Communication will have to take place in both directions and flow through the disaggregated and fragmented mess that is today’s supply network. Conceived without environmental considerations in mind, today’s supply networks have proven nearly incapable of handling the flow of RoHS information downstream in a timely manner. Without significant retooling, as well as development of software tools and standards that are useable, lightweight, and practical, the communication requirements of REACH may bring many supply networks to their knees. Further Reading Note that there are many details that we do not have space to relate. In fact, there are thousands of pages of guidance documents for various aspects of REACH. Here are links to a few of the more relevant ones: • www.echa.eu - The European Chemicals Agency website – when published, RIP 3.8 will be available through this site. Read the FAQ on this website as well. • reach.jrc.it – Home of the REACH Navigator. This excellent tool helps you answer the question “What are my obligations under REACH?” • ec.europa.eu/environment/chemicals/reach/reach_intro.htm Directorate General Environment’s REACH page • europa.eu.int/comm/enterprise/reach/ - Directorate General Enterprise’s REACH page • www.acea.be/reach - Automotive industry’s guidance • www.orgalime.org - Look for their guidance document in the “publications” area • www.aia-aerospace.org - The Aerospace Industry Association’s REACH guidance is listed in the “Issues by Subject” section • www.astm.org - ASTM’s Committee F40 on Declarable Substances in Materials has produced the first release of its REACH supply network communication guidance. • www.ansi.org/chemicals - ANSI Manufacturers Network, helping industry deal with the continued onslaught. Michael Kirschner is president of Design Chain Associates, LLC, and can be reached at mike@designchainassociates.com. The author wishes to thank Kris Pollet of Pollet Environmental Consulting for reviewing and suggesting changes to this article. Notes 1. Actually it applies in the entire European Economic Area, or EEA, which includes Iceland, Lichtenstein, and Norway as well as the EU. Categories are defined in Annex XIII of REACH, as well as in 67/548/EEC, the Dangerous Substances directive. 2. FAST Link www.conformity.com/1940 JULy 2008 Conformity 33 http://www.aia-aerospace.org http://www.astm.org http://www.ansi.org/chemicals http://www.conformity.com/1940 http://www.echa.eu http://reach.jrc.it http://ec.europa.eu/environment/chemicals/reach/reach_intro.htm http://europa.eu.int/comm/enterprise/reach/ http://www.ddbunlimited.com http://www.acea.be/reach http://www.ddbunlimited.com http://www.orgalime.org

Table of Contents Feed for the Digital Edition of Conformity Magazine - July 2008

Conformity Magazine - July 2008 Contents Editor's Note FCC Adopts 6 Million Dollars in DTV Enforcement Orders Commission Enforcement Bureau Adopts V-Chip Consent Decree FDA Seeks 2 Million Dollars from Medical Device Manufacturer FDA Answers Questions About CFLs and UV Radiation EPA Issues Energy Star Specs for TV, Video Boxes Canada Unveils Sweeping Product Safety Legislation How the Evolution of CISPR Standards Continues to Shape the Requirements for Anechoic Chambers ESD Open Forum Reach Compliance for Non-EU Article Manufacturers The iNARTE Informer Preamplifier Considerations for Emission Measurement Systems Effective Shielding in Medical Electronics Applications Product News Focus On...Power Components Buyer's Guide Updated Standards List for the EU's ATEX Directive EOS/ESD Symposium Set for September CPSC Actions in the News Researchers Work to Develop Non-Flammable Batteries Safety Link Launches Redesigned, Enhanced Web Site IEC Standards Update UL Standards Update Product Reviews Telcordia Standards Update From Our "You Can't Make This Stuff Up" Department Looking Back: Items from Past Issues of Conformity Advertisers

Conformity Magazine - July 2008

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