By Michael Wurzman Being able to efficiently move data along supply chains, as addressed with CDX (Compliance Data Exchange), is only part of the solution. Having easily usable data is the critical second part. The old computer adage, “GIGO – Garbage in Garbage Out” applies here as well. We must train our supply chains to […]
The REACH Data Dilemma: Part 2 Read More »
By Michael Wurzman The REACH Data Dilemma: Part 1 Unlike man, all data is not created equal. REACH compliance is dependent on receiving high quality data from your supply chain and being confident it is current. If the substance content data you receive is not complete and in a usable form – or outdated –
The REACH Data Dilemma: Part 1 Read More »
By Michael Wurzman “You don’t know what you don’t know”. I can’t begin to tell you how many times I heard that from my dad growing up. I was always challenged to think in those terms in conversations, so I could put in context my comments as well as better evaluate what I heard. As
The Case for Training Read More »
REACH has all the transparency of a national tax code – even when it comes to import/export activities between two divisions of a multi-national company. For example, imagine that Heavy Equipment, Inc., (HEI/US) ships a preparation – windshield washer – and a component article – hand grips – to its sister organization in France (HEI/FR).
The Importer-of- Record and REACH Obligations Read More »
By Harvey Stone “I’m too busy making products.” My shareholders care about cash – not compliance.” “We’ll get to it next quarter” Over the years, I’ve heard many variations on the above themes in regard to compliance with RoHS, WEEE, ELV and other environmental laws. Typically, the executive or manager uttering them is stating what
By Michael Wurzman Recently, an equipment manufacturer voiced some concerns to me that you may also have. “REACH is so complicated,” he said. “It has so many nuances. How can I protect my company from being caught with an SVHC problem? Where do I start?” My response to him was this: “Start by understanding the
Reducing REACH Risk Management Read More »
By Michael Wurzman EU importers supply articles from non-EU manufacturers to the EU market. If any of those articles contain a Substance of Very High Concern (SVHC) in a concentration above 0.1% (w/w), REACH’s Article 33 requires the importer to automatically provide available and relevant safety information about the SVHC to the recipients of the
By Michael Wurzman “You can’t go it alone” is an adage that becomes ever more true as we address the data issues of REACH compliance. Success in achieving compliance requires us to overcome the supply chain data reporting objections that are blocking our compliance efforts. Let’s take a closer look. Suppliers continually say that everyone
You Can’t Go it Alone Read More »