Do you have an overview of environmental regulations in different coun-
triesand the ability to account for variations in compliance requirements?
Whether it’s REACH, Restriction of Hazardous Substances (RoHS), China
RoHS, Waste Electrical and Electronic Equipment (WEEE), or others in an
expanding list of regulations and standards, the compliance challenges and
risks you face are substantial.
Noncompliance can result in costly fines, legal ramifications for top execu-
tives, revocation of operating permits, and loss of brand value or important
customers. If your company doesn’t have a comprehensive GRC program —
whereby environmental and sustainability initiatives are embedded in every
aspect of its operations such that they are consistent across your enterprise
and reflected in the communities where you do business — it’s high time you
figure out what you need to do to make it happen.
Figuring Out What Your Materials Are and What They Do .....................
If you think that materials are the only things a product is made of, think again.
Materials may indeed be the heart and soul of your products, but they are a
heart and soul made of very, very important — to say nothing of tricky —
things that regulatory agencies and watchdogs call “substances.”
From man-made synthetics such as gasoline, concrete, and plastics to natural
matter such as cotton, gold, and wood, every material in every product is
comprised of substances. Some of them are pure, and some impure. Moreover,
substances can be made of compounds or elements. Compounds are mixtures
of two or more elements, such as water — a pure substance, by the way. An
element, on the other hand, is a single substance, such as hydrogen or oxygen,
that can’t be broken down into constituent substances.
The question that is no doubt bouncing around in your brain right now like a
stray kernel of popcorn is probably, “Why the basic chemistry lesson?” Don’t
worry. This is where the chemistry ends and the product compliance begins.
The lesson is this: material or substance, pure or impure, everything with
which you make your products must be certifiably documented, right down
to their tiniest constituents. More importantly, you need to know the nature
of every substance in your products, insofar as it is clean or hazardous. Why?
This is how today’s laws demand that products be classified: either they are
made of clean materials and substances — meaning they pose no threat to
people or the environment — or they are made of materials that are hazardous,
in which case they do pose a potential threat, however minor. Regarding
environmental, health, and safety compliance, such materials constitute
two separate categories: hazardous materials and dangerous goods.
Chapter 12: Making Your Products Environmentally Friendly 219
