5.1.3 Optional - Requesting full substance list
The manufacturer shall request (or otherwise have access to) a list of substances in the materials, components, and parts contained in the covered product. The supplier requests shall cover either:
-At least 95% by mass of the superstrate and substrate and 95% of the remaining materials, or
-At least 90% of the directly contracted suppliers of materials, components, and parts
The manufacturer shall have a documented process, and a system or tool, to record the collected information, and to calculate the percentages stated above.
Manufacturer shall request suppliers to disclose the standardized number (e.g. CAS, EN, IMDS, GHS), for the list of substances.
"Request" means one or more of the following:
a)The manufacturer, or an agent or supplier of the manufacturer, has requested this information in writing from the supplier directly (e.g. email, letter). In all cases "request" includes documented acknowledgement of receipt by the supplier representative. Sending an email is not sufficient to meet this requirement, or
b)A contract, agreement, or purchase order between the supplier and the manufacturer (or between the supplier and an intermediary supplier [e.g. contract manufacturer]) requires the supplier to provide this information, or
c)A specification or other document to which the supplier is held by the manufacturer or an intermediary supplier that requests this information.
Point value: 1
Verification requirements:
a)Process documentation for collecting the information requested in accordance with this criterion
b)Process documentation for an information management system or tool adequate to address the nature and quantity of parts, suppliers and information relevant to the requested substance information
c)Summary of information used to calculate percentages achieved
5.1.4Optional - Database of substances in product[P1]
The manufacturer shall demonstrate that it has in have a database of the substances, including the substance standardized number (e.g. CAS, EN, IMDS, GHS), in the products/components supplied to the manufacturer from its suppliers, as specified in Table 5.1 below.
Manufacturer may claim the points associated with only one level in Table 5.1
Table 5.1
Data Acquired on Substance List / PointsMinimum of 70% of total product mass / 1
Minimum of 99% of total product mass / 2
The manufacturer shall have a system for recording information, calculating percentages of data acquired, and validating reports or other substance ingredient declarations from its suppliers.
Point value: maximum 2
Verification requirements:
a)Documentation that the database includes the substances in the products/components supplied to the manufacturer from its suppliers, including a substance standardized number
b)Calculation demonstrating the percentage of total product mass for which the manufacturer has a complete list of the substances
c)Evidence supporting the existence of a system for recording information and validating reports or other substance ingredient declarations from its suppliers
[P1]JC input: get additional points for public disclosure of full substance inventory?
10/16 Users are interested in disclosure of hazardous materials only; no need for disclosure of all materials.
Julie summarized that there was no interest at this time.
10/13/16 JC agreed to delete 5.1.3 and pull relevant information into 5.1.4
Action Item: Pamela will restructure & send for Ricky for review