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REACH
Compliance Interview
with Wiring Harness News
Wiring Harness News May/June 2011
Michael Wurzman was
featured in an interview appearing in the May/June 2011 issue of
Wiring Harness News, the official publication of the Wiring Harness
Manufacturers Association (WHMA). The front page article was titled
"REACH Basics for the Harness Manufacturer." Key excerpts
from the article are reprinted below, with many thanks to the
Wiring Harness News:
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[Wurzman]
stressed that with REACH, wire harness manufacturers will need
to track ALL substances contained within the components and be
able to know at any point in time whether those substances are
on the SVHC Candidate List, or the Annex 14 [Authorization]
list. |
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“I view REACH
as working together with the supply chain to get toxic
substances out of the production environment. If I know I have
no SVHCs coming in the door, and I’m not creating any in my
process, then the products are good for sale in the EU.” |
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“You really
have to know your suppliers, and this brings up the whole notion
of risk management. Is your polymer supplier a small offshore
company offering a ‘same-as’, or is it DuPont, Dow, or any of
the other big names that have a lot of risk?” |
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“The way the
legislation is written, you are responsible for knowing what is
in the product you receive.” REACH substances are often hard to
test for, and he reiterated the importance of knowing the
supplier is doing proper audits, along with the proper testing. |
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Once the supply
chain has been verified, Wurzman indicated the next step is to
build the database. “What I do with customers is work on a
database of all the substances in all the components that come
in, again, just like we do for automotive.” Once this occurs, it
becomes obvious to him where there is incomplete data. |
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Of equal
importance to Wurzman is checking a company’s facility from
receiving to shipping. “When we do an audit,” he said, “we go to
every department -- receiving, engineering design, manufacturing,
and shipping -- to make sure nothing is added that we don’t know
about.” |
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When asked
specifically about guiding his customers through the SVHC
declaration process, Wurzman is proud to say, “The way we handle
that is, we have it out of there before it ever hits the SVHC
list.” |
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RSJ Technical
keeps close tabs on discussions between EU Member States and the
various non-governmental advisory groups, “so we know what is
coming down the pike for SVHC Candidate List inclusion, and can go to work on substitutes well in
advance.” |
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In concluding
his assessment of REACH, Wurzman described the benefits that a
good consultant brings in putting together a process to track
materials. “It’s really a matter of putting REACH in as part of
your supply chain process. For most companies, they don’t have
the time or adequate human resources, so that’s where we come
in.” |
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He expressed
RSJ Technical’s ability to provide varying levels of service
depending on customer need. He also noted that their experience
has led them to a select group of software products that improve
the quality and manageability of environmental compliance data
for various laws, directives and standards. |
To
learn more about
REACH, please see our tutorial page.
To learn more about our REACH
reporting services, please see our services page.
We are here to help you! Our services are extremely
cost-effective. Please
email us (include your phone number) if you would like to receive a quote for
our reporting or consulting services.
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Jun 2011 -- All
Rights Reserved
RSJ Technical
Consulting
PO Box 867705, Plano, Texas 75086
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