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Guest column: Compliance through efficient substance tracking
Authorisation is a multi-step process which aims to phase out or substitute substances of very high concern (SVHCs). Many downstream users have introduced substance tracking procedures to help them meet the deadlines for substituting SVHCs or for submitting an authorisation application to continue using the substance until a suitable replacement has been found.
As manufacturers of complex and technologically advanced products, we at Jaguar Land Rover rely on thousands of different substances that are used along our multi-tiered supply chain. In addition to our ongoing efforts to reduce the risks associated with the use of chemicals in our products at our own sites, it is important to have systems in place to track the regulatory status of the substances in components on which we rely. We also need to prepare for the potential impact of a substance being removed from the market.
From left: Matthew Griffin, Jonathan Swindel. Image: Jaguar Land Rover.
Many of our substance tracking activities are coordinated through the REACH Task Force of the European Automobile Manufacturers Association (ACEA, Association des Constructeurs Européens d'Automobiles), in which Jaguar Land Rover is an active participant.
Since the automotive supply chains are complex, we have to start our substance tracking as early as possible in the authorisation process. So, shortly after a substance is added to the Registry of Intentions, ACEA's REACH Task Force carries out a survey of its members to determine how critical the substance is to our continued vehicle production. This depends on how often it is used, initial understandings of the availability of technically equivalent substitutes, and the potential impact of substitution on vehicle type-approval. Where a substance is identified as being of critical importance across the industry, ACEA coordinates the tracking of the substance status, and develops contributions to public consultations on the Annex XV dossier and on draft recommendations to add new substances to the Authorisation List.
When a substance is added to the Candidate List for authorisation, more detailed assessments of the impact on the industry of potential substitutions are done. If a substance is added to the Authorisation List, then we as individual companies have to plan to be prepared for the sunset date (the date after which the substance can no longer be used). We will then speak to our own affected suppliers to gain a more detailed picture of alternatives. We need to find out if they meet our technical requirements as well as what their costs and delivery capacity are.
|Rebecca Bree. Image: Jaguar Land Rover.|
Where suitable direct substitutes are available and can be implemented by the sunset date, we will instruct our suppliers to go ahead with substitution. Where no direct substitutes are currently available, we will work with suppliers to develop and validate alternatives.
The REACH Regulation allows for continued use of a substance after the sunset date by having an authorisation. We at Jaguar Land Rover do not apply for authorisation ourselves. As an end-user, we can only apply for authorisation for our own use and our immediate suppliers' right to supply the substance. This means that if the authorisation is to cover all users in our entire supply chain, we have to rely on companies upstream applying for authorisation and we have very little visibility on how this is progressing. The decision on whether the application is approved or denied is also likely to be made only a few months before, or even after, the sunset date, whereas substituting a substance in an automotive production part will take up to four years from when we have validated a suitable alternative.
In most cases, we cannot rely on getting an authorisation and so we must plan for complete substitution of the substance by the sunset date. We know that in the coming years more substances will become subject to authorisation, and the efficiency and effectiveness of our substance tracking systems will become increasingly important in ensuring our continued compliance.
The automotive industry has collaborated to create and maintain the Global Automotive Declarable Substance List (GADSL), which defines certain substances as 'declarable' or 'prohibited', based on the input of REACH and other global, national or regional regulations.
In Europe, the industry has also been subject to the End of Life Vehicles Directive for more than a decade. In response, automotive manufacturers had already put effective substance tracking tools in place before REACH came into effect and we were therefore already familiar with legislation that had similar requirements to REACH.
Along with most other major automotive manufacturers, Jaguar Land Rover uses the International Material Data System (IMDS) to collect and review information on materials along the entire supply chain. Together with the Global Automotive Declarable Substance List, this results in a complete library of all substances of interest used in automotive parts.
In addition, we have our own Restricted Substance Management Standard (RSMS) that in some cases sets further restrictions and earlier substitution dates than those identified in GADSL. These standards are referenced on all our drawings, requests for quotations and our global purchasing terms and conditions, forming an essential part of our contracts with our suppliers. Additionally we apply the same standards to our materials review process, which covers non-dimensional materials, for example, paints, adhesives and floor cleaners, both for production and non-production use.
Our in-house database hosts multiple substance lists, including GADSL, RSMS and the REACH Candidate and Authorisation Lists. This allows us to check against the listed substances when reviewing articles and materials from our suppliers, before their approval. We can also search the database by name, hazard classification (e.g. all sensitisers) or REACH status (e.g. all Candidate List substances). Together, these integrated systems give us a complete picture of all substances used in our vehicles and at our sites.
Jonathan Swindell, Product Stewardship Manager at Jaguar Land Rover
Matthew Griffin, Hazardous Materials Technical Specialist at Jaguar Land Rover
Rebecca Bree, Toxicologist at Jaguar Land Rover
Jaguar Land Rover
Jaguar Land Rover is the UK's largest automotive manufacturing business with an expanding global presence. It employs 30 000 people globally.
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