On June 21, 2018, the ECHA added Lead to the Candidate List for Substances of Very High Concern under REACH.
While this regulation arguably covers only manufacturers and importers in the EU, the fact of the matter is that our shops here in North America are producing components (articles) which are incorporated into products in the EU.
Our customers, who specify the use of leaded materials because of the economics of product provision (Leaded materials machine at much higher efficiency rates, lower costs , and seldom need post fabrication operations) are now asking their suppliers for a statement of compliance for the materials that THEY specify us to make THEIR components from. Leaded Steels, Brasses and Aluminums.
Our shops find themselves placed right in the center of a paradox- how can they certify that the material that their customer told them to use is compliant with this new REACH development?
PMPA has analyzed this and provided our members with a guidance document that
- Recites the applicable facts and regulatory obligations
- Describes where and where not the REACH and other EU regulations apply / might not aply;
- Analyzes the duties to our customers
- Describes ways to meet our obligations
- Provides references for understanding this new development
The world of Precision Machining is characterized by Volatility (this regulation just Arrived), Uncertainty (does this apply to me, I’m an North American, not European manufacturer?) Complexity ( So I need to read the ECHA announcement, The ECHA Substance Support Document, the Annex that covers Lead, and then two more annexes that tell me what I need to do) before I can figure out what I need to do, and Ambiguity (Actually the annexes do not expressly state what the exact deliverable required is).
This VUCA world is made manageable by PMPA regulatory sensemaking to help our shops first recognize, then intelligently understand and manage their risk.
- Who is helping you and your team recognize new regulatory risks?
- Who is helping you to understand those risks?
- Who is providing answers so that you can concentrate on making those critical parts that the world needs, instead of spending three or four man-Days trying to figure it out? (Presuming that you know the issue even exists!)
PMPA members know who.