Implementing Environmental Compliance Services

Since the industrial revolution, humans have been innovating, creating, and manufacturing thousands of products a day. While this has allowed for the development of life-changing technology, it has also introduced substances that cause significant damage to the environment and human health. This is why developing environmental compliance services is crucial to the success of your company – without it, you can be faced with product recalls, heavy fines, and bad publicity.

What are Environmental Regulations?

Environmental regulations are rules the government puts in place to protect the environment and human health. They can apply to the substances in your product, the chemicals used/produced in manufacturing your product, and the disposal of chemical waste. They can also include employee training requirements and an emergency plan.

It is essential to be aware of the regulations applicable to your product. Otherwise, you risk investing resources into an item that can’t be put on the market.

The following is an overview of a few environmental regulations to take note of.

POP Environmental Compliance Services

POP stands for Persistent Organic Pollutants. POPs are halogenated organic substances and include compounds such as Polybromodyphenyl ethers (PBDE), Polychlorinated Biphenyls (PCB), and Pentadecafluorooctanoic acid (PFOA).

POPs are regulated due to a global agreement called the Stockholm Convention.

Some environmental regulations that restrict POPs are:

EU RoHS (EU)
SOR/2012-285 (Canada)
Regulation 2019/1021 on persistent organic pollutants (EU)

REACH Environmental Compliance Services

REACH stands for Registration, Evaluation, Authorization, and Restriction of Chemicals. REACH applies to most products in the EU market, excluding some industries, such as food and petroleum.

In addition, REACH has two subcategories: Substances of Very High Concern (SVHC) and Annex XVII.

If a product contains more than 0.1% weight of SVHCs, the manufacturer must declare these substances to both the consumer and the European Chemicals Agency (ECHA).

Annex XVII is a separate list that restricts substances from use in specific applications. For example, Tris(aziridinyl) phosphine oxide cannot be used in textile articles that come into contact with the skin. As a result, you need to be aware of the Annex XVII restrictions that apply to your industry.

Products that do not comply with EU REACH will be withdrawn from the market and placed on the Safety Gate Rapid Alert System for Non-Food Products website.

Prop. 65 Environmental Compliance

Prop. 65 is the shortened form of California Proposition 65. Prop. 65 is managed by the California Office of Environmental Health Hazard Assessment (OEHHA). This regulation applies to all consumer goods sold in California and businesses with ten or more employees.

If your product is likely to cause exposure to any Prop. 65 substances, you must have an appropriately placed warning label. However, this is unnecessary if the amount is below the No Significant Risk Level (NSRL) or the Maximum Allowable Dose Levels (MADL).

TSCA Environmental Compliance

The Toxic Substances Control Act, or TSCA, is managed by the Environmental Protection Agency (EPA). TSCA applies to all substances and products manufactured in and imported to the United States. TSCA restricts several substance families, including lead, CFCs, and Persistant Bioaccumulatives and Toxic Chemicals (PBTs).

Similar to REACH Annex XVII, different substances will have different thresholds depending on their application. For example, formaldehyde is harmful when contained in composite wood products. As a result, these products must meet the TSCA standard for formaldehyde emissions.

In addition, products that contain TSCA substances are subject to recordkeeping requirements. The documentation varies based on the substance, but all records must be kept for at least three years.

RoHS Environmental Compliance Services

RoHS stands for Restriction of Hazardous Substances. This regulation aims to reduce the amount of hazardous substances found in Electrical and Electronic Equipment (EEE). Thus, this regulation applies to all electronic and electrical products. This article will focus on EU RoHS, but many regions, such as China, the UK, and California, have their own version.

There are ten substances restricted under EU RoHS:

Lead
Cadmium
Mercury
Hexavalent chromium
Polybrominated biphenyls (PBB)
Polybrominated diphenyl ethers (PBDE)
Bis(2-ethylhexyl) phthalate (DEHP)
Butyl benzyl phthalate (BBP)
Dibutyl phthalate (DBP)
Diisobutyl phthalate (DIBP)

Achieving Environmental Compliance

The proof you need to achieve environmental compliance for your product will vary based on the regulation.

Some examples of things you may need are:

Bill of materials (BOM) of your product
Safety Data Sheets (SDS) of the components used in your product
Notes from suppliers
Laboratory test results

For example, one way to achieve RoHS compliance is to create a technical file that contains certificates of conformity from all the manufacturers. This is called a documentary approach, which typically involves collecting documentation from other parties. The commissions that oversee these regulations will sometimes issue standards, like the RoHS IEC 63000 standard, which gives clear guidelines on what documentation is required.

In other cases, specific guidelines are not given, and you may need to conduct a risk assessment to determine whether your product is compliant. This is also useful when you do not have all the required documentation.

Chemistry Testing

Another way to verify your product’s compliance is to test the product for banned substances. This can be done by either sending samples of your product to an external lab or purchasing the equipment yourself and having trained personnel perform the tests.

The types of testing you’ll need to do will vary based on what you’re testing for, but some of the most common ones are XRF spectrometry, chromatography, and mass spectrometry. While opting for chemical testing might be convenient, it may not be the best choice for companies with a limited budget.

Whether you are a large corporation or a small business, the environmental compliance of your products is your responsibility. If you ever need assistance navigating environmental regulations, contact Enviropass for a free consultation!