The Association of Equipment Manufacturers (AEM) is on a mission to help educate its members about compliance with REACH regulations that could otherwise cut off their global access to highly regulated markets. REACH, the Registration, Evaluation, Authorization and restriction of CHemical substances, is the most comprehensive and complex regulatory barrier yet imposed on equipment manufacturers.
"AEM's unique and exclusive training will help our member companies to learn about compliance with REACH regulations, which require compliance from every vendor in a supply chain. It's necessary for Original Equipment Manufacturers (OEMs) to know that every substance in their products complies with REACH, and that every supplier complies with the regulations. Our training provides the efficient means to educate members about compliance without revealing any company's proprietary information," says Charlie O'Brien, AEM Senior VP.
REACH training is available immediately through AEM's MAP (Market Access Pathway) training platform. The consequences of non-compliance with REACH at any point in a supply chain could ultimately lead to products being kept out of the European Union market, as well as other markets that have their own version of REACH, such as China and South Korea.
The training modules will educate companies and the vendors in their supply chain how to document the substances used in manufacturing, their origin, and the concentrations in each product. The goal is to allow companies that implement this training and gather the required data as part of their regular business process to be better prepared to meet the challenge of new and emerging regulatory issues.
Companies participating in the training program will be able to provide high quality training not only to their own internal employees but to their Tier 1 suppliers, as well as the rest of the supply chain. AEM's MAP training platform allows manufacturers to trace vendors' participation and completion of the training at every level of the supply chain without revealing proprietary vendor information.
An AEM cross-industry working group formed three years ago identified the need for this training program. The group said it wanted to "find industry solutions to comply with onerous materials management regulations." AEM solicited comments from the following companies: Ford, Boeing, RSJ, Seagate, Bosch, Caterpillar, Terex, Toro, Doosan, CNH, Navistar, John Deere, and Komatsu, ensuring the best possible knowledge base for the industry specific project. However, only AEM member companies, Caterpillar, Terex, Doosan, CNH, Navistar, John Deere, and AGCO, helped create the training program.
"AEM members are quick to point out that other regulatory barriers will require similar education programs. This unique MAP training platform is also suitable for training associated with other arduous regulations like Conflict Minerals and RoHS because of the ability to track training through the entire supply chain. Each of these regulatory regimes requires unique compliance training. It is our mission to help our members stay ahead of those regulatory demands as well," says O'Brien.
"Compliance boils down to companies being able to have the correct, secure data and to understand each substance in their products, and where those substances originated. Data is only as good as the weakest link in the supply chain and companies that can offer this training throughout their supply chain will be better able to judge how good the information is coming through the supply chain," O'Brien says.
REACH currently lists 151 substances on its SVHC (Substances of Very High Concern) list. Substances are added to the list every June and December, and the list is expected to cover at least 440 SVHCs by 2020. For REACH, the concentration of a substance determines if the substance is reportable, but for Conflict Minerals any amount of a named substance (tin, tungsten, tantalum and gold) and its source of origin must be documented.