Yesterday was the first day of ICPHSO’s 2012 Annual Meeting and Training Symposium in Orlando, Florida. As a product safety certification body, MET Labs is participating.
The first day was “Manufacturers Day.” For electronics manufacturers, the most relevant presentations focused on new supply chain disclosure requirements, and factors in standards development.
Here are the key points from the supply chain disclosure panel:
With its REACH and RoHS requirements, Europe has the most stringent requirements in this area.
The U.S. is following, with California leading the way. Four states have ‘green chemistry’ laws: California, Washington, Wisconsin and Maine. An additional nine states had green chemistry laws introduced in 2011/2012: Maryland, Florida, Illinois, Michigan, New York, Massachusetts, Vermont, Oregon and Alaska.
As covered in Compliance Today previously, Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act will soon implement reporting requirements for four conflict minerals. This regulation will go into effect when the SEC hammers out the details, sometime before June 2012.
Manufacturers are struggling to do this tracking, although the limited number of global smelters helps. Peggy Fowler, Walmart’s Senior Director of Corporate Product Safety and Regulatory Compliance, says companies should demonstrate due diligence steps, even if not all information is known.
Here are key points from a presentation on standard development:
A risk assessment looks at the frequency of an injury and its severity. Also, who is at risk? The EU RAPEX approach is a good model.
Don Talka, UL VP, gives an example of hair dryers:
- Frequency of injury: low
- Severity of injury: high (death)
- At risk: children
- Injury probability: high if device falls into bath tub
- Perceived cost of implementing fix: high – sometimes doubling cost of product
- Resolution: multiple steps were taken to safely allow full immersion
Have a thorough understanding of issue:
- Accept there is a problem
- Do a root cause analysis based on HBSE principles
- Discuss in a balanced group (STP or task group)