lilly snur workshop automotive case study final · 5 imds%(internaonal%material%datasystem )...
TRANSCRIPT
Case Study -‐ Automo/ve
Amy Lilly, Hyundai-‐Kia Technical Center, Inc. Brenda Baney, Delphi
September 17, 2015
Agenda
• Global Supply Chain • History of IMDS • GADSL and IMDS Infrastructure • IMDS Rules & Recommenda/ons • Future State • Lessons Learned & Addi/onal Considera/ons • Recommenda/ons for SNURs
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Global Supply Chain
History Lesson – Auto Regula/ons • Auto specific chemical regula/ons began in Europe
– European End-‐of-‐Life Vehicle Direc/ve passed 2000 • Banned substances effec/ve 2003: heavy metals • Mandatory recycling percentages, improvement targets
• ELV Annex II list of heavy metal exemp/ons is undergoing 8th stakeholder revision – Some exemp/ons expire – Exemp/ons without technical solu/ons con/nue with later review date
(~4 yrs) • There are other regula/ons around the world that address chemicals
and impact the automo/ve industry: – U.S.: CA Green Chemistry, TSCA – Canada: Canadian Gaze`e – Europe: RoHS, REACH, Biocides – China: China ELV & Compulsory Cer/ficate, China REACH, VOC Legisla/on – Japan: Chemical Substance Control Law – India: ELV Standard is emerging – Global: Stockholm Conven/on
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IMDS (Interna/onal Material Data System)
Efficient management of a huge amount of data
Easy overview on chemicals in parts
Quick feedback and effec/ve communica/on between suppliers and OEMs
In 1999, 7 OEMs decided to develop one common collec/on tool
Challenges Target
Web based Standardized Quan/ta/ve report Computeriza/on
Move from Paper to Electronic Data
Fulfillment of legal requirements with lowest effort
• The automo/ve industry collaborated with EDS (now HP) on an innova/ve new database to capture full material content of automobile.
• Access: www.mdsystem.com
Up to 30,000 unique components
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2000 2001/02 2004 2003
2005 2006 2007 2008 2009 2010 2011 2012
IMDS History
* Opel is a part of GM
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Global Automotive Declarable Substance List www.gadsl.org
Criteria: • List is based on substances expected in automobile parts or vehicles at
point of sale. Substance repor/ng for parts and materials in final state! • Substances are regulated or projected to be regulated. Added by
dossier created by techical regional experts (EU, US, and AP) • Reportable threshold levels will be based on the lowest level required
by regula/on or scien/fic evalua/on (typically 0.1%).
GADSL
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• Within the whole supply chain, each supplier has to enter the substance & material informa/on for his component/material to the IMDS-‐account of his customer
• Results in a more or less complex “Material Data Sheet” that is sent from the Tier 1 Supplier to the car manufacturer (OEM)
• The OEM is using the data to check compliance of the purchased parts and substances for internal requirements as well as legal obliga/ons
• Each level of the chain can (and is) using the data to check and proof compliance
• Data ownership (and responsibility) is on data creator site
• Data cannot be modified by the receiver (without genera/ng a new version (Data ID)
Data Collec/on for IMDS
Raw Material supplier
Tier n supplier
Tier 2 supplier
Tier 1 supplier
OEM
IMDS Communica/on of substance informa/on
GADSL One reference list for declarable substances
Pictures of IMDS Use of pseudo-‐substances, wildcards, and ranges allow for protec/on of confiden/al material informa/on
Printed Circuit Board (PCB) represented by Tier 1 with use of Flat BOM
Component & compliance detail received but assembly summariza/on allowed
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IMDS Rules & Recommenda/ons • General Rules
– In principle, agreed to by all par/cipa/ng OEMs – Addresses topics surrounding:
• Level of disclosure, including – Pseudo-‐substances, such as ABS, ceramics, etc… – “Jokers/wildcards” represen/ng non-‐GADSL industry confiden/al substances
allowed to be stated within a material up to 10% by weight total • Published materials
– By IMDS Steering Commi`ee and/or recognized industry bodies – Problems with individual company published data quality & accuracy along
with accessibility. ***need for lowest /er engagement • Con/nuing evolu/on as disclosure needs expand
• Recommenda/on 019 (electronics repor/ng) – Used to communicate to supply chain best repor/ng prac/ces
• Relaxed material naming rules for small electronic components <5g • Use of ‘standard material set’ for describing assembled circuit board
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Future State • IMDS updates on regular basis (~yearly)
– Projects aimed at improving data accuracy & quality – Inves/ga/ng faster methods of updates for materials regulatory status
– Supply Chain Confiden/ality • Other durable goods industry efforts
– Heavy Machinery and Aerospace are both looking into material repor/ng.
• Establishing substance lists and data standards. • Process chemicals
– Currently excluded from repor/ng scope due to depth of supply chain and global nature.
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Lessons Learned • Benefits
– Well established process across the automo/ve industry – Provides a consistent means of repor/ng for suppliers – Reduces costs by having harmonized rules for fulfilling various global chemical
regulatory regimes • Limita/ons
– It took 5years, (up to 10) to reach data quality, and work is on-‐going – The industry has invested a lot of money to develop the tool
• These expenses will con/nue because it needs to be maintained and it is updated annually – Confiden/ality must be maintained
• Non-‐disclosure agreements • OEMs cannot share informa/on iden/fying suppliers, parts, or other unique informa/on
– Data is only as good as what is entered • Must rely on supplier support and informa/on • Regional concerns with raw material data
– Only applies to exis/ng regula/ons and is not future looking • GADSL list is based on current & pending regula/ons • Discussions on-‐going about expansion to include forecasted substances
– An inves/ga/on for a given substance via IMDS can take up to 6 months due to repor/ng complexity in the automo/ve supply chain
– CAS numbers iden/fy substances, and they are not always provided in regula/ons
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Addi/onal Considera/ons • IMDS is an automo/ve system working very well for car manufacturers
• Suppliers have indicated a need for more mul/-‐industry collabora/on concerning informa/on on chemicals in materials and products
• Drivers – Opera/onal efficiency – Compliance & Reputa/onal risk – Stakeholder expecta/ons
• Benefits – Crea/ng sustainable product development processes – Improved risk management – Expor/ng a global culture of responsibility
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Recommenda/ons for SNURs IMDS is a great tool and it provides a means to reduce the burden and /me of inves/ga/ng the content of hundreds of thousands of components in global supply chains. However: • Informa/on must be provided in a way that will allow the auto industry to
take advantage of IMDS: – Provide CAS numbers: It is challenging to inves/gate the use of a chemical if
CAS numbers are not provided – Provide threshold levels, (op/mally 0.1% by weight): Uses below this amount
are likely not in IMDS • IMDS does not provide informa/on on all chemicals, and therefore:
– Allow plenty of @me for inves@ga@ons: Chemicals currently not used by the auto industry will not be included in GADSL….. or found in IMDS.
• Without use of IMDS, companies have to send out individual surveys to suppliers • It takes at least a year to add chemicals to IMDS, and then /me to be iden/fied throughout
the supply chain – Consider exemp@ng ongoing uses not iden@fied during the comment period:
It may be next to impossible to find all ongoing uses in this short /meframe • Companies need to be able to provide unique replacement parts for
customers for many years aver produc/on: – Provide exemp@ons for replacement parts
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