On June 21, 2018, the ECHA added Lead to the Candidate List for Substances of Very High Concern under REACH.

Not banned in every application…

While this regulation arguably covers only manufacturers and importers in the EU, the fact of the matter is that  our shops here in North America are producing components (articles) which are incorporated into products in the EU.
Our customers, who specify the use of leaded materials because of the economics of product provision (Leaded materials machine at much higher efficiency rates, lower costs , and seldom need post fabrication operations) are now asking their suppliers for a statement of compliance for the materials that THEY specify us to make THEIR components from. Leaded Steels, Brasses and Aluminums.
Our shops find themselves placed right in the center of a paradox-  how can they certify that the material that their customer told them to use is compliant with this new REACH development?
PMPA has analyzed this and provided our members with a guidance document that

  • Recites the applicable facts and regulatory obligations
  • Describes where and where not the REACH and other EU regulations apply / might not aply;
  • Analyzes the duties to our customers
  • Describes ways to meet our obligations
  • Provides references for understanding this new development

The world of Precision Machining is characterized by Volatility (this regulation just Arrived), Uncertainty (does this apply to me, I’m an North American, not European manufacturer?) Complexity ( So I need to read the ECHA announcement, The ECHA Substance Support Document, the Annex that covers Lead,  and then two more annexes that tell me what I need to do) before I can figure out what I need to do, and Ambiguity (Actually the annexes do not expressly state what the exact deliverable  required is).
This VUCA world is made manageable by  PMPA regulatory sensemaking  to help our shops  first recognize, then intelligently understand and manage their risk.

  • Who is helping you and your team recognize new regulatory risks?
  • Who is helping you to understand those risks?
  • Who is providing answers so that you can concentrate on making those critical parts that the world needs, instead of spending three or four man-Days trying to figure it out? (Presuming that you know the issue even exists!)

PMPA members know who.
PMPA Members Only Guidance Document

You may be surprised that Technology as a stand alone item is not one of them.

Our future is not about shinier flying saucers.
We will master  and implement whatever technologies are developed.
But our future is being impacted by these 7 items  today:

  1. Loss of experienced workers taking tribal and craftsman knowledge out of our shops.
  2. Lower average wages as experienced workers with seniority leave and younger workers start at trainee wages, making it difficult to attract talent with facts about “increasing wages”- even though they are.
  3. Training growing in percent of spend as many shops are unable to purchase new technology to quote new work because they do not have trained workforce.
  4. More and more jobs being quoted out of more challenging, non free machining materials;
  5. A bit of relief from new regulations, but more uncertainty as Washington turns to trade issues which can impact availability and cost of imported materials, and tooling,  as well as impact the exports of finished goods that contain our parts.
  6. Increasing demands for certification of production to a wide variety of customer demanded requirements regardless of legal obligations- Conflict Minerals, REACH, RoHS, Animal- Free; Ca. Prop 65. Etc.
  7. Possibility of an “Association Healthcare Insurance solution” in 2019 or beyond.

What do you see as the trends shaping our company and industry future?
Please don’t say technology- as Humans, we’ve been successfully implementing new technologies for quite some time.

Flying cars
Todd Rundgren Future

PMPA Regulatory Assurance is how PMPA members gain confidence when dealing with the ever changing and growing area of regulatory compliance.

Here is an example of the kind of sensemaking that PMPA members count on to confidently assure regulatory compliance.

Do my parts comply with REACH Regulations?
Do my parts comply with REACH Regulations?

-Regulation (EC) No 1907/2006 of the European Parliament and of the Council of 18 December 2006 concerning the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH), is a regulation on substances

-Unless exempted from scope or from registration in accordance with Annex IV or V, substances on their own or in preparations are always subject to registration when manufactured in, or imported into, the EU.

-Substances on their own and in preparations in the form of, or contained in, articles produced in or imported into the EU are subject to registration only if they are intended to be released under normal or reasonably foreseeable conditions of use and if this use of the respective substance have not been registered before in the Community.

-In Article 3 (3) of the REACH regulation the definition of an article is given as “an object which during production is given a special shape, surface or design which determines its function to a greater degree than does its chemical composition.

So the question “Do my parts comply with EU REACH Regulations?” boils down to this question: “Do your parts meet the Article Exemption test?”

For an object to be considered an article, the following conditions should be fulfilled:

The shape, surface or design of the object must:

  1. be obtained during production and be special;
  2. be relevant for the function of the object;
  3. be more important for the function than the chemical composition of the object.

Precision machined products easily meet these conditions:

1. The shape, surface or design of the object must be obtained during production and be special

-The shape and many surfaces of precision machined parts are created by stock removal during production and are regarded as “special”

-Precision machined products are custom produced (special) at the order of the customer.

-They have different dimensions and technical characteristics, as specified by the customer at the time of the order.

-Their surfaces are  developed during production to meet the customer’s (special) dimensional and geometric requirements.

2. The shape, surface or design of the object must be relevant for the function of the object

-it is axiomatic that the custom design of the precision machined product is to create the needed form fit and function needed to assure desired performance and function.

3. The shape, surface or design of the object must be more important for the function than the chemical composition of the object

-Precision machined products are machined from a variety of metallic alloys, including steel,  stainless steel, aluminum, brass and many others of varied compositions.

-These compositions are varied and determine manufacturability as well as influence mechanical properties, though they are not sole determinants of those properties.

-Without final precision machining to special size, form and geometry, the raw material itself would not provide the needed function demanded by the customer.

Bottom line: Precision machined products are clearly “articles” as defined by Regulation (EC) No 1907/2006 of the European Parliament and of the Council of 18 December 2006 concerning the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH), and so exempt from regulation.

Caveat: If during foreseeable conditions of use of the part, it could cause an intentional and  forseeable release of a substance that has not been registered before in the Community, you might need to investigate further.

Where do YOU go to get this kind of regulatory assurance?