By John Wagner, AEM Director, Materials Management, and Michael Wurzman, President, RSJ Technical Consulting
(This is the fifth in a series of articles that assist AEM members in meeting today’s stringent substance-in-products documentation and reporting requirements; reducing their non-compliance financial risks; and generating financial opportunities from their compliance activities.)
In today’s compliance-driven business landscape, “ubiquitous training” has emerged as a surprisingly critical success factor for your company and virtually every manufacturer.
Ubiquitous training is the ability to provide affordable (if not free) training not only to OEMs, but to every company in your supply chain. Our supply chains, with an average of 11 supplier tiers, must be trained at each tier on how to provide quality substance data, i.e. data that is accurate, complete and protects supply chain confidentiality, if we expect reliable data to be passed all the way to the OEMs.
In turn, imagine documenting inaccurate and incomplete data for regulatory authorities and/or your customers. How could your company legitimately report to its shareholders, owners or managers? How could it claim that it has protected its markets, customers and revenue from the financial risks associated with REACH, RoHS and the many other global laws that target toxicity in products?
As discussed in the second article in this series, compliance with these toxicity laws is unprecedented in that – except for materials manufacturers – virtually no company can account for the substance data in its products by itself.
Even with the availability of a comprehensive data-exchange infrastructure (CDX from HPE) that was discussed in the last article, companies will be subject to ongoing fire drills and higher compliance costs if companies throughout the supply chain lack 1) a common understanding of why they are documenting and exchanging substance data and 2) the correct how-to methods for inputting, evaluating, extracting and updating their data.
Lacking this common understanding, the data that companies pass along and/or receive will be yet another case of “garbage in – garbage out.” Furthermore, poor quality data erodes your bottom line. Nearly 15 years of data-exchange experience in the automotive industry indicates that the need for data-collection re-work spikes the costs of compliance. And, as customers become more demanding in their requirements for quality data through the use of flow-down clauses and explicit statements in their purchase orders, the failure to provide that documentation will drive them to competitors who can provide it.
So, given the above, every company in the supply chain has a stake in that common understanding and methodology. To that end, AEM’s Market Access Pathway (MAP) has already developed a series of online trainings in regard to REACH and Conflict Minerals. It has arranged for in-person trainings in how to use CDX. And, shortly, it intends to produce a series of online CDX trainings.
For More Information
For more information, contact John Wagner, AEM Director, Materials Management (firstname.lastname@example.org, tel: 414-298-4164).