An integrated compliance program is needed to achieve quality compliance dataBy John Wagner, AEM Director, Materials Management, and Michael Wurzman, President, RSJ Technical Consulting

(This is the 6th 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.

The Big Compliance Headache

Does your company approach compliance with toxicity-targeting laws like REACH in a one-off or disjointed manner? If it does, you likely know from painful experience that fire drills, squandered cash, wasted time and staff upset are the predictable (and unnecessary) by-products of such an approach.

Furthermore, the situation will only get worse.  REACH, RoHS, ELV, and Prop 65 are the highest-profile toxicity laws with the highest financial risks. But they are only the tip of the compliance iceberg. From California to China, there are hundreds of other jurisdictional laws that target thousands of substances and compounds that impact millions of products from our industry and virtually every other industry.

So, if sequentially addressing one or two of these laws at a time doesn’t work, what is a viable solution? In a phrase: implementing a Regulatory Compliance Management Process (RCMP).

Headache Pain Relief: A Regulatory Compliance Management Process

Your company runs on processes. It would be out of business if it didn’t have design, manufacturing, quality, logistics, service, HR and other processes that contribute to your making a product, making a sale and making a profit. Those processes routinize activity, improve efficiency, lower costs and allow your company to capitalize on opportunities.

If your company has not yet applied its process-development skills to the task of complying with toxicity-targeting regulations, as well as the expanding requirements for sustainability reporting, AEM strongly suggests that it is time to do so.

After years of trial-and-error and partial solutions, our industry and supporting software industries have evolved a viable solution for your company, your customers and your suppliers.

Furthermore, there has now been enough experimentation and forward progress to define, launch, implement and maintain a compliance-based process. Using the same principles as used in your product quality processes, this compliance-based process will help you to attain quality data, required documentation and necessary reports.

In doing so, the key is proactively designing in the compliance so that “Do It Right, Do It Once” is the norm. Lacking this norm, the default is for companies to use a far more costly model, wherein they verify whether they are compliant with REACH, RoHS or some other law and, if not, they expend additional costs to redesign the non-compliant aspects of their product.

Bottom Line

Today, the broad strokes of an RCMP are well understood by AEM and RSJ Technical, and they are well integrated into AEM’s Market Access Pathway program. AEM and RSJ Technical can assist you in tailoring those strokes to your specific corporate make-up and market position. We can help you to choose the best corporate “home” for the RCMP; to define the functional tasks needed for implementation; to establish an implementation team; and to arrange for the proper training to make it all work.

Over time, the benefits of integrating the RCMP will very likely impact your financial bottom line and staff morale in a positive way.

For More Information

For further information about how AEM and RSJ Technical can assist your company with designing and launching its RCMP, contact John Wagner, AEM director, materials management (, tel: 414-298-4164).