Discover the Power of Data with Full Material Disclosures

Assent ComplianceDirector, Compliance Programs

Overview of an “FMD”

Methods for creating an FMD

IPC-1752A Class D

Creation of FMD in practice

In the electronics industry, this would mean 100% disclosure of every substance down to the homogeneous level

Without this level of disclosure, an FMD would not demonstrate compliance to the RoHS Directive

In an industry which does not have any regulatory requirement to restrict or disclose substances at the homogeneous level, this could mean 100% disclosure at the “Article” level (i.e. total concentration)

Having 100% disclosure at the Article level would support compliance to REACH SVHC communication requirements and a variety of other legal requirements

But... it only works if the format makes sense to exchange complicated data structures in a common format for one system’s output to be readable in another system

Otherwise, one is unable to perform analysis and judgement

To create a common structure, the format must contain logic within its data population

PDF Excel Word XML

HTML Pen and Pencil Mind reading

Provides a set of rules for encoding documents into a human and machine readable format

Without the rules, data exchanges would result in files being passed from one machine to another resulting in dump of uncommon data

IPC-1752A, Class D IPC-1754 (in development) IEC 62474 ChemSHERPA

Created a data exchange standard to support not only the requirements of RoHS and REACH, but also those to come in the future IPC-1752

First released as a PDF, but has not been supported in years

Currently available in XML

The most highly adopted standard for materials data exchange

Class A - Provides an answer to a query For example, Query for RoHS is answered by “Product meets EU RoHS

requirements without any exemption”

Class B - Provides the amount of different material classes within a product For example, 50% stainless steel, 25% polyvinylchloride, 25% zinc and its alloys

Class C - Provides substances details if above or below threshold against a specific list or lists of substances For example, Product contains DEHP at 0.25% after being asked for the

presence of SVHC substances

A

B

C

D

If I have a Class D, am I able to demonstrate compliance to all regulated substances?

Not necessarily

The standard has been created to be open for a variety of uses and many “fields” are optional

Not mandatory to include unique chemical identifiers (e.g. CAS #)... but highly recommended

Certain substances may contain regulated substances as a constituent (additives, stabilizers, plasticizers)

Substance names are not standardized (e.g. aluminum, aluminium)

Proprietary substances

Mandate a unique identifier if exists (e.g. CAS #)

Mandate all regulated substances must be reported What does that mean?

Mandate all substances on specific list be reported

Mandate a consistent method of proprietary

And many more

Assentcompliance.com/fmd-complete/

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October 20, 2016 | Chicago

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