Category Archives: Green Thoughts

Environmental compliance expert Kal Kawar’s blog

The Next Big REACH Deadline

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The European Chemicals Agency (ECHA) recently launched a campaign to remind industry to start preparing for the second REACH registration deadline, as reported by REACHspot.  We put together a few guidelines on how to prepare for the next round of REACH regulation deadlines.  Really, the next one to worry about is May of 2012.  Here’s what you need to know.

The big REACH deadline in 2013.To prepare for the REACH 2013 deadline, companies manufacturing or importing chemicals in Europe — in quantities at or above 100 tonnes per year — are required to register such substances with ECHA by May 31, 2013.

But first, find out if your substances are already registered.  To do this, simply go to the ECHA database of registered substances and search for your chemical.

If your substance meets the criteria of passing through the EU at a quantity of 100 tonnes or above and it has not already been registered, you are required to register your substance.

How to compile information to register. There are a few elements involved in compiling necessary information for registration.

  1. Substance identification and sameness of substance: confirm with the other preregistrants that you have the same substance
  2. Hazard information: collect all data available on the intrinsic properties of the substance to be registered
  3. Data sharing: as part of a joint registration, gather and share existing information, consider alternatives to testing and answer any information request from within your Substance Information Exchange Forum or SIEF
  4. Chemical safety assessment: carry out a chemical safety assessment in order to produce a chemical safety report based on the hazard information collected and knowledge on the uses

To wit:  for joint submissions, there must be a  so-called Lead Registrant who, yes, leads — and Members who follow.  The Lead Registrant is one registrant acting with the agreement of the other assenting registrant(s) who will submit the joint registration dossier with all information. ECHA recommends this is done at least 2 months before the legal deadline, which means by March 31, 2013. Members are other registrants who have confirmed their membership in the Joint Submission in REACH-IT, they have to submit their registration after the Lead Registrant within the May 31, 2013 deadline.

REACH deadlines 2012.There are 2 key deadlines for May of next year.

  1. Late preregistration deadline prior to the 2013 registration deadline, for first time manufacturers and importers. Late preregistration is a simple process. You just submit your information, via an agent, your own internal REACH software, or online using REACH-IT.  Please note that late preregistration is only allowed under specific circumstances.
  2. Downstream users should notify suppliers of uses by May 31, 2012 at the latest.

You are a downstream user if you use a substance, either on its own or in a mixture — also called a chemical cocktail — in the course of your industrial or professional activities. If you are a manufacturer or an importer of a substance, a distributor or a consumer, you are not a downstream user. Guidance is available.

Also, it’s advised that you research available tools for substance management and REACH management in particular, try a Google search for REACH software to start.

Ecodesign: Meet the New ISO 14006:2011

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ISO has developed a new standard to help organizations efficiently implement “ecodesign” — which is what it sounds like. The goal is for organizations to use the principles of ISO 14006:2011 in order to design and develop more advanced, profitable and sustainable goods and services.

Alongside, the newly published ISO 14006:2011 Environmental Management Systems – Guidelines for Incorporating Ecodesign provides instructional guidance on incorporating ecodesign into any environmental, quality or similar management system. The target audience is industry.

ISO 14006:2011 does not establish by itself specific environmental performance criteria and it is not intended for certification purposes. However, guidelines for incorporating ecodesign gives “how to” guidance on incorporating ecodesign into any environmental, quality or similar management system.

The ISO 14006 standard aims to assist organizations in their management of ecodesign as part of an environmental management system (EMS). Specifically, it aims to help:

  1. Establish.
  2. Document.
  3. Implement.
  4. Maintain.
  5. Continually improve.

Ecodesign. The goal is greener product development and greener product lifecycle management. The guidance applies to those environmental aspects of an organization’s products and/or services over which it has control or influence.

ISO 14006:2011  ISO 14006 is applicable to any organization. It is NOT conditional on a company or entity:

  1. Size.
  2. Geographical location.
  3. Culture.
  4. Complexity of management system(s).
  5. Complexity of target product or service.

The new standard is intended to be used primarily by organizations that have implemented an EMS according to ISO 14001, whether or not they have a quality management system (QMS) according to ISO 9001. It can also be useful for organizations without a formalized EMS or QMS but which are interested in reducing the adverse environmental impacts of their products.

ISO 14006:2011 was developed by ISO technical committee ISO/TC 207, Environmental management, subcommittee SC 1, Environmental management systems, working group WG 4, Guidelines in ecodesign. It may also be obtained directly from the ISO Central Secretariat, price: about USD$135.00 via the ISO Store online.

Other ISO standards of interest  The ISO 14000 family of standards relating to environmental management systems in businesses, homes and communities.

  1. ISO 14006:2011 — Environmental management systems — Guidelines for incorporating ecodesign.
  2. ISO 14005:2010 — Environmental management systems — Guidelines for the phased implementation of an environmental management system, including the use of environmental performance evaluation.
  3. ISO 14004:2004 — Environmental management systems — General guidelines on principles, systems and support techniques.

By complying with ISO 14000 standards, you’re never afraid to show your hand.

Breaking Chains: New California Law Means Supply Chain Audits

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If your business touches the great state of California, you’ll want to know about this new law, effective January 2012.  The California Transparency in Supply Chains Act of 2010 will bring audits of supply chain practices to a new level.  Businesses need to know what’s going on not just here, but over there.

Starting Jan. 1, 2012, if you haven’t scoured every corner of your supply network for possible dark spots, you must be able to show that:

  1. you are capable of a supply chain audit, and
  2. you have procedures, resources and tools in place to regularly execute such an audit, i.e., that you are capable.

Supply chain visibility becomes law. In September 2009, the US Department of Labor released a report that named 122 goods from 58 countries that are believed to be produced by forced labor or child labor in violation of international standards. The State of California then passed a human trafficking law that will take effect Jan. 1, within the law there is an amendment to the state Revenue and Tax Code.  This amendment includes disclosure requirements that will rock the supply chain and make transparency more necessary than ever.

This legality was a subtle part of the umbrella law, and it’s only now that executives are realizing its ramifications.  There’s a related flurry of business for supply chain management software, especially the more cost effective, quick to implement, platform and location agnostic Software as a Service (SaaS) modules.

The new law is also expected to boost sales of headache pharmaceuticals for Supply Chain Managers around the world.

From electronics to organic food. A supply chain in any industry, from electronics to aero and auto, and into food manufacturing and distribution needs to be able to audit its supply chain for sourcing and working conditions.  Consider some of the working conditions in the food industry, for instance, even though the electronics industry gets so much of the attention on this (e.g., Foxconn), not to mention mining, metals and oil & gas.

One good example is illustrated by how IPC, the renowned electronics industry association, points out the new law’s affect on its member companies:

There will be serious consequences for the entire electronics industry: customers will ask questions and supply chains will be audited regarding social responsibility practices, imposing extremely costly burdens. The immediate effect will be on organizations with annual gross global receipts in excess of $100 million, with a set of disclosure requirements that must be clearly publicized on company websites.

How to comply with California’s new law. For more information, ask your quality assurance managers, risk management team and compliance officers to review the law itself, and consider contacting the advisor you trust for supply chain compliance.  There are three key elements of an assurance program:

  1. whether a particular program or software tool can work in your unique business conditions
  2. how quickly it can be implemented
  3. whether the tool can work with your current software platforms/ERP/portal(s)

Good luck to all and to the Golden State.

 

The Leaning Tower of Six Sigma

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Whatever happened to Six Sigma? It was so intently-discussed in years past — then faded from the conference table. Well, it’s back. From the Obama administration’s Oval Office to siloed enterprise facilities in rural areas of America, Six Sigma is a hot topic — again.

What is Lean Six Sigma? Lean emphasizes removing waste from organizations and processes while focusing on and delivering more value to customers. Six Sigma focuses on variation reduction in processes, products, and services. Lean Six Sigma is basically streamlined processes but faster, simpler. (And yes, there’s an app for that.)

Lean Six Sigma has been back in the spotlight recently as several U.S. presidential candidates have pledged to use the management tool, if elected. Also, the Obama administration is reportedly studying how Lean Six Sigma could help eliminate federal government waste.

Lean Six Sigma online survey  More than 2,500 quality improvement professionals participated in a recent survey around the subject of Lean Six Sigma. A group called ASQ conducted the survey, ASQ being a “leading global network of quality experts,” and in all fairness is a reputable organization. It was conducted using online technology, across disparate geographies.

Lean Six Sigma could help reduce the soaring national debt, decided the survey respondents, but it faces some key challenges in government implementations. The biggest obstacle, survey respondents said, is a U.S. federal government structure that can be a barrier to comprehensive evaluation and accountability.

In addition to noting challenges with the federal government’s structure, survey participants noted other obstacles to implementing Lean Six Sigma in government agencies:

  1.     An environment faced with conflicting strategies, goals, and priorities
  2.     Creating a sense of urgency to deploy a comprehensive improvement methodology across all government agencies
  3.     The personnel management model currently used by many government agencies
  4.     A lack of familiarity with Lean Six Sigma and how it can benefit the organization
  5.     Ongoing political partisanship

Lean Six Sigma in Action  “In business, some process improvements are obvious,” said Russell McCann, national speaker on Six Sigma and President and CEO of Actio. “For instance, if a scientist is creating a new product, and the product contains a chemical that is banned or is restricted in some countries, then it’s best to identify the issues at the request stage.  This averts a scenario where the enterprise spends millions of dollars developing an unusable product.

“While these sorts of process improvements can be done manually – with traditional paper-based systems – process efficiency and accuracy are compromised,” said McCann.  “Critical information is inevitably ‘siloed’ at individual locations rather than being shared across an enterprise; in some cases data is not even shared within a single facility.  This type of scenario presents an ideal environment for a Six Sigma program.

“A Six Sigma initiative that includes Six Sigma software such as Actio modules will reduce cost, improve control processes, and rationalize materials management,” McCann said.

Survey says…  Many participants in the ASQ survey said there are benefits to using Lean Six Sigma. More than 75% of participants surveyed said they have implemented Lean Six Sigma in their organizations and an impressive 79% said the tool is very effective in improving efficiency and productivity.

The respondents found that Lean Six Sigma has also been effective in the following areas:

  1. Raised levels of quality in their organization (74%)
  2. Reduced costs (73%)
  3. Helped individuals in their organization be competitive in the marketplace or to pursue the organization’s core mission (68%)
  4. Had a positive impact on employee safety (56%)
  5. Improved innovation (46%)

Kudos to ASQ for pulling this data together, certainly an interesting study.  ASQ is headquartered in Milwaukee, Wisconsin, with national service centers in China, India, and Mexico.  Learn more about ASQ’s survey, their members, mission, technologies and training at www.asq.org.

Will GHS affect WHMIS?

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GHS stands for the “Globally Harmonized System of Classification and Labelling of Chemicals.” GHS is a system that defines and classifies the hazards of chemical products, and communicates heath and safety information on labels and material safety data sheets (called Safety Data Sheets, or SDSs, in GHS).  The goal of GHS is to have a universal set of rules for classifying hazards, using the same format and content for labels and safety data sheets (SDS) worldwide.

The Workplace Hazardous Materials Information System (WHMIS) is Canada’s national hazard communication standard.  WHMIS has a complicated implementation, a multi-angled approach coordinated through federal, provincial and territorial legislation. The key elements of the WHMIS system are:

  1. cautionary labelling of containers of WHMIS “controlled products”
  2. the provision of material safety data sheets (MSDSs)
  3. worker education and training programs

Overall, the current roles and responsibilities for suppliers, employers and workers likely will not change in WHMIS after GHS, but there will be some changes.

GHS changes to WHMIS. How chemicals are classified will be affected.  It’s likely that WHMIS legislation will:

  1. adopt all of the major GHS health and physical hazard classes including aspiration hazard and specific target organ toxicity-single exposure. Some sub-categories in GHS may not be adopted. It is unlikely that the environmental hazard classes will be adopted under WHMIS (but this does not exclude that it may be adopted by another government department)
  2. continue to include some hazards that are currently not in the GHS system, but are present in the current WHMIS system – such as biohazardous materials
  3. have more specific names for its hazard classes
  4. combine two WHMIS classes (teratogenicity/embryotoxicity and reproductive toxicity) into one new GHS hazard class called reproductive toxicity

What won’t change in WHMIS under GHS. Suppliers, importers and producers duties will continue to include:

  1.     classifying hazardous products
  2.     preparing labels and SDSs
  3.     providing these elements to customers

Employers must continue to:

  1.     educate and train workers on the hazards and safe use of products
  2.     ensure that hazardous materials are properly labelled
  3.     prepare workplace labels and SDSs as necessary
  4.     provide access for workers to up-to-date SDSs
  5.     ensure appropriate control measures are in place to protect the health and safety of workers

Workers will still:

  1.     participate in WHMIS and chemical safety training programs
  2.     take necessary steps to protect themselves and their coworkers
  3.     participate in identifying and controlling hazards

Hopefully this helps set you set up for GHS.  There are tools and solutions for GHS conversion, and here is a web site reference for all things WHMIS: http://www.ccohs.ca/oshanswers/chemicals/ghs.html.  You can contact me with specific issues.

ACC-tung Baby: New Tool For TSCA

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Pressure to modernize TSCA is mounting from all sides, and the American Chemistry Council (ACC) is offering a tool that agencies can use to do something about it.  The ACC is proposing a chemical prioritization system that it believes could be used by the Environmental Protection Agency (EPA) to determine which chemicals warrant additional review and assessment.

Achtung means “Pay attention” in German, and the world is indeed paying attention to TSCA reform.

ACC President and CEO Cal Dooley said as part of the new tool’s announcement, “As outlined in ACC’s principles for modernizing the Toxic Substances Control Act (TSCA), establishing a clear and scientifically-sound prioritization process is key to creating a world-class chemical management system.”

The 35-year-old TSCA law does not dictate a process to utilize the information currently available to prioritize chemicals for review.  ACC’s approach offers one way to evaluate chemicals against transparent, consistent and scientific criteria that take into account both hazard and exposure. In this system, chemicals are given a score based on certain criteria and then ranked based on both:

  1. scores, and
  2. the agency’s best professional scientific judgment

Those rankings would then be used to determine which chemicals should be referred to EPA’s Office of Chemical Safety & Pollution Prevention for further assessment.

Conflict of interest? The obvious problem with ACC contributing a chemical prioritization tool to EPA lies in seemingly inevitable conflicts of interest where an industry-backed association has a stake in evaluating its own products (in this case chemicals) for the marketplace.

ACC says its prioritization tool is not intended to produce conclusions about which chemicals necessarily present a risk to human health or environment. The tool is, apparently, just a gift, simple as that.

EPA’s stakeholder meeting on prioritization. On Sept. 7, before the announcement, representatives from ACC met with officials at EPA to discuss the tool in conjunction with the agency’s stakeholder dialogue on prioritization.

[EPA is opening an online discussion forum for comment from hrough Sept. 14 to get input on the prioritization factors and data sources the Agency plans to use to identify priority chemicals for review and possible risk management action under TSCA.  Participate here.]

“We are glad that EPA has recognized the urgent need to prioritize chemicals for review,” said Dooley. “ACC welcomes the opportunity to participate in [this] dialogue and hopes EPA will utilize our concepts to develop a consistent and transparent prioritization process.”

For more and for reference, see: www.americanchemistry.com/Policy/Chemical-Safety/Chemical-Safety-Regulations

 

15 Bad Intentions Under REACH

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Three new restriction proposals for NPs and NPEs have been announced under REACH.  Specifically, the three are:

  1. 4-nonylphenol, branched
  2. nonylphenol
  3. nonylphenol ethoxylates

NPs and NPEs are grouped under alkyl phenols and their ethoxylates.  Sweden has proposed intentions to restrict the three substances.

Notification of intention: September 2, 2011
Expected date of submission: August 3, 2012

Currently, most substances under intention for restriction are mercury compounds and phthalates.  To view or download the list of 12 substances with intention for restriction under REACH see below or download REACH’s12 intentions.

The Swedish Chemicals Agency understands that the proposed restriction is a new restriction, not an amendment of an existing one.  (The amendment of an existing restriction requires first a decision according to REACH article 69(5) to amend the restriction and then a decision according to the normal procedure amending the restriction.)

Justification for the three new proposed market restrictions for 4-nonylphenol, branched and nonylphenol and nonylphenol ethoxylates is reportedly based on Sweden’s understanding that:

  1. NP (e.g., nonylphenol) and NPEs (e.g., nonylphenol ethoxylates) have been found in environmental samples taken from freshwater, saltwater, groundwater, sediment, soil and aquatic biota
  2. NP has also been detected in human breast milk, blood, and urine and is associated with reproductive and developmental effects in rodents
  3. NP is persistent in the aquatic environment, moderately bioaccumulative, and extremely toxic to aquatic organisms
  4. NP has also been shown to exhibit estrogenic properties in vitro and in vivo assays. NP’s main use is in the manufacture of NPEs
  5. NPEs are nonionic surfactants that have been used in a wide variety of industrial applications and consumer products. They can be found in textile (including leather) articles
  6. NPEs, though less toxic and persistent than NP, are also highly toxic to aquatic organisms, and, in the environment, degrade into NP
  7. Levels of NP in waters above the environmental quality standards in the Water Framework Directive (WFD) is found in several waters despite the strict restriction on the use of Nonylphenol (NP) and Nonylphenoletoxilates (NPEO) under the limitations directive 76/769/EEC (now in Reach Annex XVII, entry 46) having been in force since January 2005
  8. NP and NPEO in textiles have been identified as a significant source of NP in the environment

Based on these data, the Swedish Chemicals Agency is investigating the possibility to propose a restriction on the placing of the market of textile and leather articles containing NP or NPEO.

REACH Gets A 5-Year Review

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It’s been five years since REACH* was adopted. Now, five years later, the European Commission (EC) is preparing to review the legislation.

The review is expected to be significant but not overwhelming. The EC-led review will be based on “lessons learned” from the implementation of REACH, focusing on the costs and administrative burden and other “impacts on innovation.”REACH regulation The review will include:

    1. Test method costs and spends: an audit of the amount and distribution of funding made available by the EC for the development and evaluation of alternative test methods.
    2. REACH scope: whether to amend REACH scope to avoid overlaps with other EU legislation.
    3. ECHA: a review of the European Chemicals Agency (ECHA).
    4. Lower tonnage substances: a review of registration requirements for lower tonnage substances.

‘So, how’s my driving?’ Originally, REACH sought to test, analyze, categorize and track ~100,000 chemical substances. But since 2006, only a small number of chemicals have actually been reviewed, starting with a list of 47 Substances of Very High Concern (click here for full SVHC list), which are suspected of causing cancer or disturbing the human reproductive system.

“But there are a lot more substances out there,” said Jamie Page from the Cancer Prevention and Education Society, as reported by Euractiv.

Page is calling for the screening process to be accelerated. “Obviously, there are a lot of chemicals on the market – people estimate between 80,000 and 100,000 – so it is like a few down, a lot to go.”

ChemSec, an environmental lobby group, has recently accused the EU of delaying action on “endocrine-disrupting” chemicals such as phthalates, calling on regulators to speed up work. ChemSec wants 378 substances included in the SVHC list. “There are a lot of controversial products,” Page concurred, citing Bisphenol A, a compound which has recently been banned in plastic baby bottles but which some scientists believe could be harmful in other guises, such as coatings for food cans.

Activist lawyers ClientEarth and chemicals campaigners ChemSec recently said they had sued ECHA for refusing to disclose the names of facilities producing 356 potentially dangerous chemicals. ECHA told Reuters in May it had decided to publish company names ONLY in the case of firms that are suppliers of hazardous substances, but that those entities and stakeholders could request confidentiality.

For producers of nonhazardous chemicals, the disclosure would be voluntary.

Notes: * REACH is the European regulation for the safe use of chemicals. REACH deals with the registration, evaluation, authorization and restriction of chemical substances. Adopted in 2006, it entered into force on June 1, 2007. The European Chemicals Agency (ECHA), based in Helsinki, Finland, acts as overseer of the REACH system.

REACH strives to do two things: 1) catalogue all ~100,000 chemicals in use today, and 2) set restrictions on uses of toxic chemicals.

ECHA guidance: http://guidance.echa.europa.eu/index_en.htm

EPA’s New GHG Reporting Program: e-GGRT

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The US Environmental Protection Agency (EPA) has announced a new tool to allow 28 industrial sectors to submit their 2010 greenhouse gas (GHG) pollution data electronically.

Grabbing ahold of industry’s GHG data is a bit like grabbing a tiger by the tail.

Tiger by the tail. The electronic GHG Reporting Tool is known as e-GGRT for short, a gritty, growly and staccato moniker for a function that is precisely that. Reporting GHG data is a nuts and bolts effort, slightly predatory, that can only be done one data piece by one data piece.

A user can hope for speed and a usable interface, but one thing we’ve noticed in our years of environmental data consolidating — from relatively simple MSDS data fields to more complicated supplier material disclosure data — is that bulk uploads are great but one by one is inevitable. Meaning: data has to be culled. Do it at the start, do it later which is more difficult as time creates data dependencies, but evenutally data must be culled. (This is the type of project companies rightly outsource.)

EPA says that it put the e-GGRT through its paces before making yesterday’s announcement. More than 1,000 stakeholders, including industry associations, states and NGOs tested the electronic GHG Reporting Tool (e-GGRT) — testing for clarity and user-friendliness.   Apparently it passed.

It’s e-GGRRRREAT? The EPA expects to receive 2010 greenhouse gas data from approximately 7,000 large industrial greenhouse gas emitters, including power plants, petroleum refineries and landfills. The agency plans to publish non-confidential greenhouse gas data collected through the tool by the end of 2011.

If you missed the August 1, 2011, deadline, go ahead and register or have your agency register anyway; EPA is likely to be lenient.  They want a queue of data more than they want a queue of wrists to slap.

On August 19 (2011) EPA Head Lisa P. Jackson signed a final action related to certain data elements reported under EPA’s Greenhouse Gas Reporting Program. EPA says it needs to further examine the likely business impact from the disclosure of these data elements before they are reported and potentially subject to public availability. This action defers the deadline for reporting these data elements while EPA addresses issues related to reporting and public availability of these data elements. In fact, EPA is deferring the reporting deadline for some of these inputs until March 31, 2013, and for others until March 31, 2015. This action does not affect the reporting deadline for other data elements under the rule or for suppliers of greenhouse gases.

To compare EPA’s e-GGRT tool with a commercial Greenhouse Gas reporting tool, Google search for emissions regulator tools. Here’s one example of a commercial tool.

On the EPA Confidential Business Information (CBI) page. Also, EPA & Air policy is online.

For $12B, Google Buys Motorola’s Insured Supply Chain

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The Google-Motorola deal announced last week is about hardware manufacturing capability.  In other words, Google just paid $12.5 billion for a gadget supply chain with over 20,000 patents as the cherry on top.

As Chris Nowak put it in a recent article in Environmental Leader about quality management in a modern supply chain, “Today’s business problems include how to compete with a supply chain like Apple’s – a bristling hot pot of electronics suppliers and logistical hubs that delivers a customized, monogrammed electronic gadget in 3 days or a book you order today that’s delivered tomorrow, or the sneakers that you design to wear next week.

“Like it or not,” writes Nowak, “this is today’s competitive field.  All this speed still has to be cost-effective, innovative, compliant and risk-analyzed for whatever market it’s being made in and sold into.  Today’s global supply chain has blink-fast distribution demands.”

It couldn’t be more true.  What Motorola has is a hardware supply chain for gadgets comparable to Apple’s; now Google has one too.  That’s a large chunk of the $12 billion, and that chunk that was worth it.

The environmental compliance piece. What’s notable from our point of view is that Motorola has in recent years made significant efforts in its supply chain environmental compliance.  Their supply chain risk in terms of compliance vulnerabilities is low, low, low.

Motorola has for years been actively collecting supplier chemical information, fortifying compliance efforts with REACH, RoHS and other environmental regulations — imposed by both government and industry alike.

Did Google see that as part of the value?

Did Google acquisition executives see this material disclosure data as significant portfolio gold that may continue to return value?

As regulations tighten worldwide and the pressure mounts to know what’s happening at the chemical level in an electronics (or in any discrete manufacturing) supply chain, Google will know.  Their competitors?  Not so much..

Microsoft, Apple and Oracle have a new and sudden weak spot. While the term material disclosure has more than one meaning, some call it “supply chain insurance.”  Here’s how Motorola — in just a few years — has insured its supply chain.

“We require our suppliers to disclose an extensive list of Motorola Solutions’ banned, controlled and reportable substances as well as request recycled material content for each part supplied to Motorola Solutions,” says the company.  “We do this to fully understand and track the material content of our products, to comply with regulations, prepare for future regulations and control and improve the environmental profile of our products.”

This is not a partial approach.  It’s bold and thorough.

If you think about all the law suits that fire back and forth between the tech giants like Google, Apple, Microsoft and Oracle — the giants without material disclosure insurance seem suddenly keenly vulnerable in the environmental, sourcing, and quality assurance heel.

Motorola’s material disclosure advantage. Motorola Solutions — in its corporate documentation — discusses how its taken a proactive approach and compiled a list of 63 substances (or substance groups) targeted for exclusion, reduction or reporting during the design and manufacture of products. The list is divided into three sections:

  1. Banned substances which are not allowed for use in any Motorola Solutions product at any level
  2. Controlled substances which are limited for use in manufacturing processes or certain product applications (use limitations are typically defined by national or international environmental regulations)
  3. Reportable substances which are are not currently banned or controlled for use, but are likely to be in the future or the company has identified the need to understand their use as part of a environmentally conscious design process and/or for end-of-life management

Motorola has for years now required its suppliers to fully disclose information on the materials composition of parts and components, including information on substances of concern and recycled material content.  The company collects, stores and published information about internal efforts in researching alternative materials and stewardship regarding batteries and other end-of-life concerns.

Regulatory specifics. Motorola has been a leader in recognizing that many countries around the world have implemented regulatory restrictions on hazardous substances.

  1. European Union’s directive on the restriction of hazardous substances (RoHS):  Motorola Solutions complies with the European Union’s directive on the restriction of hazardous substances (RoHS) for electronic products sold in the EU. The company voluntarily extended compliance with the European Union’s restriction of the hazardous substances (RoHS) directive to cover all newly designed professional and public safety two-way radio products as well as mobile and wireless products for the enterprise, regardless of where they are sold worldwide.
  2. China Management Methods:  China’s Management Methods for Controlling Pollution from Electronic Information Products requires manufacturers to report and label usage of the same six hazardous substances listed in the EU RoHS Directive affective as of March 1, 2007. All Motorola, Inc. and Solutions products manufactured after March 1, 2007 and shipped into China comply with the labeling requirements of China Management Methods.  Motorola posts a direct phone line where you can call to get more information.
  3. REACH:  REACH, the European Union substances regulation that entered into the force of law on June 1, 2007, has notable phased deadlines to 2018. The broad regulation requires communication throughout the supply chain, and Motorola Solutions has been “actively sharing information to meet our obligations and help our customers meet theirs.”

The Wily Larry Page. Acquiring Motorola Mobility’s environmental compliance and collection of material disclosure information from suppliers may not be the final straw that flips the other turtles onto their backs.  But it may.  In the meantime, the value of the logistical aspects of Motorola Mobility’s logsitical supply chain is not to be overlooked.

Not everything Larry Page, Inc., also known as Google, has done in 2011 has been amazing, but this deal is a smart, wily, forward-thinking acquisition for a number of reasons — from risk management right down to the chemical level.