Implementing A Material Declaration System

Created by: Raj Takhar, PhD Researcher First Published: October 2016

© 2016 Sukhraj Takhar All Rights Reserved

Topic Areas

1. Implement a Material Declaration System.

2. The ABC of Material Declarations.

3. Declarable Substance List Size to Data Flows.

4. Performing A Material Declaration Pilot.

5. Typical Material Declaration Response Times


A Material


6. P

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orm

a S

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ilot

Plan in Advance

Engage With Suppliers

Avoid Pitfalls

Good Training Materials

Perform the Supplier Pilot

Redesign of Template

Review the Supplier Pilot

2. Material Declaration Template

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Pro

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Declarab

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Sub

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Attach

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1. Declarable Substance List

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Look for ‘Known Unknowns’ &

‘Unknown Unknowns’

3. Identification of Test Data

Suppliers

Update Training Materials

4. Supply Chain Engagement

Early Engagem

ent

(Co

nce

ptio

n / D

esign)

Pro

cess has to

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7. Lessons Learnt

Initial Engagement Emails 5. Prepare Training Materials

Plain English Training Manuals Printed / on-Line / Face to

face Training Presentations

Modify Declarable Substance List

Expect Some Redesign

Update Engagement Emails / Letters

The ABC of Material Declarations

Declarable Substance List Size – The bigger the list the longer the implementation cycle to embed the substance list within a supply chain.

Material Declaration Template – The more data collected, more information a supplier will need to collate resulting in more data querying and delay to receiving rich qualitative data.

Supply Chain Mapping – understand your supply chain as per Post#2.

Smaller Quicker response Larger Longer response

Less Quicker response

Bigger Longer response

Unmapped Longer response

Mapped Quicker response


Declarable Substance List Size to Data Flow 1 to 400 Substances

Regulated substance lists, which the supply

chain is obliged to report against.


18 to 24 Months

> 1,000 Substances

Regulated plus assumed short-term, medium-term and long-term

substances

400 to 500 Substances

Regulated plus additional prioritised

substances.

24 Months

Data flows

25 to 48 Months

36 Months

5 Years + 48

Months +

Performing A Material Declaration Pilot (i)

1. Engage with your supply chain as early as possible.

2. Make initial contact with some suppliers to discuss the proposed material declaration template.

3. Encourage your supply to participate in a pilot to use the proposed material declaration template. This can be an extremely time consuming and exhaustive process, sending several hundred emails may result in a less interested suppliers than you would otherwise think.


Performing A Material Declaration Pilot (ii)

Start

Analyse Data Needs

Baseline Declaration

Template

Baseline Declarable

Substance List

Compile List Against

Regulatory List(s)

Organisation List(s)

Industry List(s)

Compile Against

Data Exchange Standards

Internal Data Needs

Regulatory Data Needs

Your Basic Data Elements

Your Details

Supplier Details

Your Part Number(s)

Supplier Part Number(s)

Your Part Number(s)

Specifications

Yours

Suppliers

Industry Substance

CAS #

EC #

Known Data Needs

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Performing A Material Declaration Pilot (iii)

4. Do not use companies which are part of your business group, within a pilot, this just skews the data quality responsiveness of the pilot, in that fellow business units will generally be more compelled to respond to material declarations requests and therefore accept errors and omissions whilst an external entity may report back in a more honest manner.

5. Ensure you have adequate training media, with which to engage your supply chain with. This training media HAS to cover every single data field which is collected in the material declaration template, explaining how the data is derived and updated, showing various methods of completion. For example if you ask for volumes of substances in a mixture - be clear on how a supplier should collate this data and report back.


Performing A Material Declaration Pilot (iv)

Start

Ready to Begin Pilot

Known Data Needs

Initial Supply Chain

Engagement Early Discussion

Operator Agrees to

Participate

No – Look for alternative supplier(s) to engage with.

Define a Representative

Sample of Suppliers to Contact

Map Supply Chain

Sound Judgement

Base on Tier 1, Location, Size

of Supplier

Ignore Language and Capability to

Complete - Pilot is Testing This.

Yes – Supplier agrees to participate.

Train Pilot Participants

Declarable Substance

List

Material Declaration

Template

Printed Matter

Virtual Training

On-Site Training

Telephone / Video Conference


Performing A Material Declaration Pilot (v) 6. With an agreed set of suppliers, perform an initial training activity

either as a face to face event or via online web conferencing / training media.

7. Allow suppliers a fair period of time from receipt of the material declaration template to update and respond to it, as part of the pilot activities. The MINIMUM period has to be 2-3 months to complete and feedback data.

8. Create a survey monkey type questionnaire to get feedback from suppliers.


Performing A Material Declaration Pilot (vi)

Start

Supplier Declaration Data

Transmitted

Assume Operator Awaiting on Their

Supply Chain Information Flowing

Back

Provide Guidance and Ensure Training Matter Is Updated

No

Begin Pilot

How deep is your supply chain? How deep will the supplier pilot go (sub-tiers assume 1 month of pilot per tier, a simple 3 tier model will require at least 2-3 months for transmittal and receipt for a simple pilot).

Ensure Additional Training Available

The Larger the Substance List =

Longer Response Times

Supplier in Receipt of List &

Template?

Can Supplier

Complete Data?

Does Supplier Need to Contact

Their Supply-Chain?

Yes

No

Yes

No

Yes Data Transmitted

Down Supply Chain

No

Declaration Template and

Declarable Substance List is

Absorbed by Supply Chain

The Larger the Data Elements =

Longer Response Times

Does Operator

Need More Guidance?

Process Check


Performing A Material Declaration Pilot (vii) 6. When reviewing the results of a pilot be sure to collate and record:

How many potential suppliers were contacted by participants in a pilot?

How were the supplier contacted?

How many suppliers were approached and how many agreed to respond initially?

How diverse were the suppliers who agreed to participate - by this I mean where they all tier 1 type suppliers or several tiers down within your respective supply chain

How many suppliers agreed but did not send any completed materials declaration templates?

7. Of the received material declaration templates, how many were received completed and received incomplete material declaration.

8. Record the response rate in terms of data that was completed material declaration templates (correctly completed) as opposed the number of suppliers originally approached.

9. This data should be presented back in the analysis documentation to show just how well the material declaration template was received by a supply chain.


Performing A Material Declaration Pilot (viii)


Month 1

1. Declarable Substance List

2. Material Declaration Template

Month 2 Month 3 Month 4 Month 5 Month 6

3. Identification of Test Data Suppliers

In Reality A Declarable Substance list may take >6 Months to compile and agree

4. Supply Chain Engagement

5. Prepare Training Materials

6. Perform a Supplier Pilot

7. Lessons Learnt

Month 7

Typical Material Declaration Response Rates (i)

Response rates can be defined as the number of completed material declaration templates you receive back from your supply chain, measured against the total number of material declaration templates submitted throughout your supply chain.

If your material declaration template is too complex and time consuming to complete, then it will take a while for the data to flow back to you.


Typical Material Declaration Response Rates (ii)

A realistic working assumption would be to expect for an initial material declaration template a response rate of less than 20% for an initial pilot.

This means in reality you will receive 20 completed responses back from a supply for every 100 material declaration templates which are distributed to you supply chain.

If your material declaration template is overly complicated, with a more complex declarable substance list, then this figure will be greatly reduced


Engineering

Implementing A Material Declaration System