Practical guide to maintaining a materials declaration system

1. Created by: Raj Takhar, PhD Researcher
First Published: October 2016
© 2016 Sukhraj Takhar All Rights Reserved

2. Topic Areas
1. High-Level Picture
2. Information Needs
3. Define Internal Data / Process Flows
4. Clean Up Data
5. Methods of Data Exchange
6. In-House or Outsource?
7. Risk Mitigation
8. Positive Declarations
© 2016 Sukhraj Takhar All Rights Reserved

3. © 2016 Sukhraj Takhar All Rights Reserved
A
Material
General
Terms
6. Method of Data Exchange
SpreadsheetForm
WordProcessedForm
DatabaseForm
XMLForm
CentrallyHosted
SupplierPortal
Authorisation Requests
Positive Declaration Requests
1.Information
Needs
Known Knowns
Unknown Knowns
Unknown Unknowns
4. Establish Supplier Engagement
Specific
Terms
2. Define Internal Data /
Process Flows
ExamineDataFlows
AvoidBottlenecks
Engage
Stakeholders
PerformRegular
Reviews
Provide
Feedback
MindMap
KPI’s
PPAP
5. Frequency of Initiation
AsSupplied
ArticlesChange
Annually
Bi-Annually
AsChemical
Regulations
Change
AsRequested
3. Clean Up Data
How Are Articles Defined?
Internal Specifications
Industry Specifications
Supplier Specifications
Internally
7. Declaration Management
Outsource
8. Declaration Monitoring
Transmitted Requests
Response Rates
Incomplete Returns
Positive Declarations
9. Data Analysis
DataCollation
Declarable
SubstanceList(s)
InitialImpact
Analysis
DataStorage
10. Risk
Mitigation
Exemption Requests
Look For Alternative Substances
Redesign
Restrictions
11. Customer Declarations

4. © 2016 Sukhraj Takhar All Rights Reserved
Becomes Problematic When Multiple Optional Mixtures and Substances Defined
Data That You Should Know
Your Specifications That
Reference Mixtures and
Substances
Your Specifications That
Reference Mixtures and
Substances
Supplier Specifications That
Reference Mixtures and
Substances
Data That You Need To
Know
Data That You Need To
Know
Determine Substances Usage
Determine If Substance Use Is
In Finished Article or As Part Of
Production Process.
Register Use.
Determine Substances Used by Suppliers
How Does The Supplier Use The Substances?
Has The Supplier Registered The Use? (Positive
Declaration Follow Up)
Determine Business Risk if Substance Is No Longer Available.
What Are The Mitigation Actions??

5. © 2016 Sukhraj Takhar All Rights Reserved
Define Internal Data / Process Flows (i)

6. Substance / Mixture
Data
Material
Declarations
Substances
Against Which
Legal Obligations
Identified
Regulatory
Requirements
Chemical
Legislations
Product Data
Risk Management
Plan
Customer
Declarations
Technical Publication Manual /
Conformance Statement (
Paper / Electronic)
Customer
Analyse data
Assess impact
Define Action
Plan
Substitution
Authorisation
Exemptions
Restrictions
Identify Supply
Chain Risk
Perform last time buy
(Where you know
substance will be
restricted but need
enough of substance to
maintain production)
Top Level
Product
BOM
Top Level
Product
Part Number
Specification
Number
Substance
Mixture
Substance
Master Chemical
Substance Inventory List
SDS SystemRegulatory Lists of
Substances
Regulatory lists of substance:
List name: Substances on list
as defined by common name
or CAS number or EC number
Chemical Mixtures and
Substances on Hand Data
Supply Chain
Material Declaration
Statements
Define Internal Data / Process Flows (ii)
© 2016 Sukhraj Takhar All Rights Reserved

7. Clean Data
© 2016 Sukhraj Takhar All Rights Reserved
Internal Specifications (Supplier Usage)
• Which mixtures / substances are in use?
Supplier Specifications
• Which mixtures / substances are in use?
• Aid suppliers to clean up data as it aids more
accurate substance reporting.
Industry Specifications
• Often generalise on substance ranges (like Safety
Data Sheet data)
Internal Specifications
• Clean up Specifications .
• Remove Inaccurate Substance Data.
• Remove Redundant Data.
• Minimise Optional Mixtures / Substances (or create
additional specifications to aid traceability).
CleanyourOwnDataToAid
AnalysisandOfferSupplierHints
andTipsToAidThem

8. Methods of Data Exchange
© 2016 Sukhraj Takhar All Rights Reserved
A
XML Form – XML form, producing XML output file, easily importable to a
wide range of IT systems, where reporting would take place
B
Spreadsheet Form – Relatively simple to create, data transformation may
require custom scripting. Commonly used, however lacks enhanced reporting
capability (adherence to functions of specific spreadsheet versions)
C Word Processed Form – Can work in a similar fashion to an XML form, no
reporting, may need additional configuration to work with other IT systems.
Database Form – Can be complicated will depend on users machine having
same version or run-time version of the database form, avoid.
D
E Supplier Portal – Dedicated internal system which handles supplier
communications
E Centrally Hosted – A central location either internal or out-sourced which
handles material declaration processing.

9. In-House / Outsource Material Declaration Processing?
• Generate a list of articles which require a
supplier to provide a material declaration
against.
• Generate a list of suppliers who provide
articles.
• Generate supplier contact details.
• Create introduction pack.
• Transmit material declaration requests.
• Receipt material declaration responses.
• Track response rates and metrics
• Clarify any issues with suppliers
• Chase outstanding requests.
• Process declarations into reporting systems.
• Submit positive declaration requests.
• Track response rates and metrics
• Clarify any issues with suppliers
• Chase outstanding positive declaration
requests.
• Process positive declaration data.
• Analyse data © 2016 Sukhraj Takhar All Rights Reserved
• Generate a list of articles which require a
supplier to provide a material declaration
against.
• Generate a list of suppliers who provide
articles.
• Generate supplier contact details.
• Create introduction pack.
• Process declarations into reporting systems.
• Process positive declaration requests.
• Analyse data

10. Risk Mitigation

11. Positive Declaration
©2016SukhrajTakharAllRightsReserved
Supplier Data
<Supplier Company ID Number>
<Supplier Company Name>
<Supplier Contact Name>
<Supplier Contact Email>
<Supplier Contact Address Details>
<Supplier Contact Phone>
<Date of Request>
<Respond by Date>
<Requestor Terms / Comments>
Conformance Statement Declarable Substance List
<Requestor
Part
Number(s)>
<Requestor
Part
Description>
<Supplier
Part
Number(s)>
<Supplier
Part
Description>
Product Data
<Exploded BOM>
<Chemical Substance Name>
<Unique ID Number>
<CAS Number>
<EC Number>
<Synonym>
<Identified
Chemical
Substance>
<Mixture> <Region Used>
< Declarable Substance List ID >
Positive Declaration Data
<Sunset
Date>
<Process
Only>
<Strategy for
Replacement>
Requestor Data