toward achievement of sound chemicals … achievement of sound chemicals management in products: the...

Toward Achievement of Sound Chemicals Management in Products: The Case of Thai SMEs

Dr. Werasak UdomkichdechaExecutive DirectorNational Metal and Materials Technology Center (MTEC)National Science and Technology Development Agency (NSTDA)Ministry of Science and Technology, Thailand

12th Eco-Products 2010, Tokyo, Japan

JAMP 5th Anniversary Symposium

Outline

• Profile & Characteristics of Thai SMEs

• Demands for Sound Chemicals Management in Products

• Implications of Environmental & Chemical Safety Regulations on Thai SMEs

• Building up SMEs’ Sound Chemicals Management Capability

• The Way Forward

• Conclusions

Dec 9, 2010 JAMP 5th Anniversary Symposium 2

1. Profiles & Characteristics of Thai SMEs

Dec 9, 2010 JAMP 5th Anniversary Symposium

Source: Office of Small and Medium Enterprises Promotion, Thailand

Size No. of companies No. of Employees% contribution to

Thailand’s 2009 GDP

Large Enterprise (LE) 1,181(0.2%)

2,704,243(21.8%)

66.3%

Medium Enterprise (ME) 4,496(0.8%)

1,438,735(11.6%)

20%

Small Enterprise (SE) 542,556(99.0%)

8,262,619(66.6%)

13.7%

SMEs547,052(99.8%)

9,701,354(78.2%)

33.7%

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1. Profiles & Characteristics of Thai SMEs


Top 10 SME output* Top 10 SME Intense Industry*

* Based on 2009 GDPSource: Office of Small and Medium Enterprises Promotion, Thailand

4

Typical Practices

5Dec 9, 2010 JAMP 5th Anniversary Symposium

WoodsTreatment & ProcessingTimber

Textiles

Chemicals(Glues, paints & lacquer, etc.)

Cushions

Accessories (Nails, screws, hinges, …)

Fabrication & assembly

Products

Incoming materials from ‘competitive’

sourcesAdd value

Supply direct to customer along supply chain or to traders

SME

Strength & Weakness


*: Based on MTEC’s survey of focused industries (EEE, Auto, Furniture, Packaging/Food) during May-August 2010

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2. Demands for Sound Chemicals Management in Products

• Drives from environmental & chemical safety (E&C) regulations– Global regulatory environment with increasing complexity

– Wave of regulations prohibiting uses of hazardous substances (HS) in products• RoHS – Restriction of certain Hazardous Substances in Electrical and Electronics Equipment

• ELV – End-of-Life Vehicles• PPWD – Packaging and Packaging Waste• VOC – Emission of Volatile Organic Compounds• Product Safety (Toys, Wearing apparel, …)• REACH - Substances of Very High Concerns (sVHCs) and Restriction of the uses of dangerous substances

• Market & Industry movements towards cleaner & safer chemicals-product- processes


Environment

Chem. Safety

Chem. Safety

7

Wave of regulations prohibiting HS


European Union (EU)RoHS,WEEE,ELV, EuP, REACH,

Packaging, Battery, etc.ChinaMII-39

(China RoHS)

JapanHARL, JMOSS, Packaging, PRTR

KoreaKorea RoHS/WEEE/ELV

ThailandThai RoHS (Vol) & (Draft)Thai WEEE

CaliforniaProp 65,

SB20/50, AB48

USAFed. Rest. on Hg, PBDE in many states, E.O.13423

MexicoList of Substances for Toxic

release inventory

BrazilRecycling Targets for

EEE & Battery

Norway(Super) PoHS

HS: Hazardous Substances

8

Dynamic list of controlled substances


Before 2003 ‘03 2006 2007 2008 2009 2010 2011 2012

PCB/PCT

Asbestos

PBB

Organostanic(Organic tin)

Cd, Ni*

Azo-colorants + TDBPP, etc.

PPWD-v1(4)

Toys-v1

CMR Cat 1,2 (~1000)

ELV (4)

PBDE (Penta-, Octa-)

RoHS-v1 (6) RoHS-v2 (???)

Phthalates (3+3) (Toys)

PFOS (100+)

DMF DMF*

Battery-v2 (Hg, Cd)

PPWD-v2 (4+CMR Cat 1,2)

REACH sVHC - 15

REACH sVHC-38 (UVCB!!!)

New CMR Cat 1,2 (+500?)

PAH (8)

TBT/TPT

DBT,DOT

New Toys (19 elements + 63 fragrances + CMR Cat 1,2)

New intentions (sVHC, Restriction)

+CFC, HCFC

+UN-POP List

+ …

+Industry/Voluntary InitiativesVOC, BFR, Halogen-Free (PWB),

PVC, …

Getting too complex &beyond SME’s capacity to comprehend/manage

9

Demands for chemicals management in products


Based on MTEC’s survey of focused industries (EEE, Auto, Furniture, Packaging/Food) during May-August 2010

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E&C are becoming mainstream requirements for industry

Reasons for Change


Sound E&C practices are driven mainly by customers and market opportunity

11

Based on MTEC’s survey of focused industries (EEE, Auto, Furniture, Packaging/Food) during May-Aug 2010

Outline





• The Way Forward

• Conclusions


TimberTreatment & Processing

3. Implications of E&C Regulations on Thai SMEs


Woods

Textiles

Chemicals(Glues, paints & lacquer, etc.)

Cushions

Accessories (Nails, screws, hinges, …)

Fabrication & assembly

Products

Request information & certification (of absence) of

controlled substances

• Request certification of compliance to specific legislation

• Submit products to testing labs for ‘certification’ of compliance

• Request certification of compliance to specific legislation

• Submit products to testing labs for ‘certification’ of compliance

Larger CompanySMELarger Company

Key Success Factors

• Data:

– Availability of reliable and up-to-date data on substances in products

• Materials:

– Availability of reliable materials with reduced risk

• Operational capability:

– Ability to adjust operations to keep pace with complex & dynamic requirements


• Beyond SME’s ability to control• Heavier burden on SME– Lower production outputs & high product customization

– Fewer human resources– Lower ‘bargaining power’

Challenges for industry

• Need to understand materials flows and supply chain linkages

• Need to understand products and production processes– What Why & How chemicals are being used

– The function of chemicals

• Data collection– Need enough & quality data to make informed decision

• New approach needed to request & manage supplier data

• Means of communication from producers to users


Approaches to manage chemical contents in products


• Large efforts spent on generating document to meet customer’s requirements than on risk reduction and product improvement

– A direct consequence of strict customer’s requirement

• Overwhelming costs (of generating compliance document) and risk of non- compliance drive industries to adopt of a sound management system

16


Key operational limitations


Scale: 5 = very important, 4 = quite important, 3 = moderate

#1: Human resources#2: Management, Access to necessary inputs & Investment funds

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Key operational limitations (2)


Scale: 5 = very important, 4 = quite important, 3 = moderate

SME: HR & fundLE: HR & Management

Innovation is considered important limitation for Thai & Public companies

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Outline





• The Way Forward

• Conclusions


4. Building up SMEs’ Sound Chemicals Management Capability


2002~2005 2006 2007 2008 2009 2010 2011~

Field survey of initial status

Raising awareness

Technical training & Consultation

Develop practical guideline for Thai Ind.

Train pilot companies

Join IEC TC-111

Thai TC-111 Mirror Committee (TC 1008)

Form ThaiRoHS Alliance

Collaborate with JAMP/JEMAI

Thai RoHS Standard (TIS 2368-2551 (2008))

JAMP Seminar & Workshops

Capability Building Programs for analytical laboratories

Sign MOU with JEMAI

Practical training for Thai RoHS

Enforcement Authority

RoHS EnforcementREACH Notification

(of SVHC)REACH Enforcement

REACH 1st candidate List

30+ Training Courses

10+ Seminars

Train the Trainer

40 Trainers/Auditors

45 Companies

2 inter-laboratory studies27 Labs participated

20

Thai EE industry at the Early Stage (2002)

• Barrier for adjustment

– Cost of substitute materials 47%

– Lack of material information 40%

– Lack of technology 39%

– Lack of local supplier 37%

– Lack of supporting infrastructure 33%

– Lack of technical personnel 32%

– Lack of capital 18%


Note: ELV (or SoC) was not in the scene then

21

Thai EE industry at the Early Stage (2005)

Demands from Thai industry [survey in 2005]

Things that could help you or your supply-chain improve your/their products

(%)

Financial Support 26.2

Sources of news/information/knowledge/assistants 83.5

Handbook/Tools for the adjustment 36.0

Forum for exchanging news/information/knowledge/opinions

43.7

Training Courses 49.5

Reliable sources for parts/materials 2.9

Others 3.9


2005-2006: Raise awareness


Voluntary Efforts from ~ 40 Organizations (~500 man-days)

Thailand 1st RoHS/ELV Compliance Guideline (2006)


Training of pilot companies


Project “Practical Guideline to become RoHS/ELV Compliance Producers and Preparation for the Energy Using Products (EuP) Directive”, Supported by EU-Thailand Economic Co-operation Small Projects Facilities (SPF Project)

Training of pilot companies


Hands-on class


First pilot companies support the second round training


Companies support each others…


Pilot companies


Period: 2006-2008 (3 Times)45 Companies300 Participants40 Trainers/Auditors

Books (2006-2007)


Focused on Basic/Technical knowledge

2009~


Focused on Up-to-date information dissemination & in-depth technical analysis-Training courses-Discussion forum-Technical Papers

From RoHS/ELV to REACH


High degree of complexity of the Regulation

High degree of complexity of the Regulation

High degree of complexity of globalized production

chain

High degree of complexity of globalized production

chain

Anticipated large number of concern substances to

manage

Anticipated large number of concern substances to

manage

Tight timeline to response (to dynamic list of concern

substances)

Tight timeline to response (to dynamic list of concern

substances)

• Beyond operational capability of a single entity

• Require new facilitating tools• Require regional/international collaboration

• Entity along supply chain need to work in concert

• Beyond operational capability of a single entity

• Require new facilitating tools• Require regional/international collaboration

• Entity along supply chain need to work in concert

33

JAMP Demonstration Programs in Thailand


Activities 2008 2009 2010

JAMP Seminars #1: 90 participants#2: 180 participants

#1: 300 participants (from 161 companies)

#2: 175 participants (from 125 companies)

236 participants (from 119 companies)

JAMP Workshop –MSDS Plus

93 participants #1: 30 participants (from 17 companies)#2- #4: Dec’10 ~ Jan’11

JAMP Workshop –AIS, GP & IT Tools

#1: 79 participants (from 34 companies and 3 organizations)#2: 88 participants (from 45 companies and 2 organizations)

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JAMP Workshop in Thailand 2008


JAMP Workshop in Thailand 2009


ThaiRoHS – JAMP AIS discussion forum

JAMP AIS workshop

Some of the Pilot companies

Activities in FY 2010


JAMP Seminar, 16th November 2010

MoU JEMAI-MTEC

JAMP Workshop, 17th -18th November 2010

37

Lessons learned

• Lessons learned from implementation of JAMP tools in Thailand– After REACH, there exists a higher level of awareness on chemical

substances management in products

– Common mechanism (at international standards level) for transferof information on chemical substances not available

– SMEs’ needs of information infrastructure development

– Recognition and utilization of JAMP

• Management Guidelines/JAMP Tools is gaining more recognition andcould be effectively utilized along the supply chain

• Language issues to improve the understanding on JAMP and its tools

• Development of human resources to promote JAMP more extensively


Outline





• The Way Forward

• Conclusions


5. The Way Forward

• Key Challenges– Identifying chemicals/materials of concern– Inventorying chemicals/materials of concern in supply chain

– Actual implementation• Some challenges from IT tools• Good chemicals management practices for SME• Issues around difficulties to collect data from suppliers from overseas, especially those who are not aware of JAMP

• ‘Spill-over’ effects– Model & Tools for other industries– Stepping stone for improvement in other areas


Other Environmental Improvement Activities (Other than those demanded by customers)


Scale 1=never, 2: sometimes, 3: moderate, 4: quite often, 5: always

41

More efforts on improving eco- efficiency than on creating eco- innovation


Conclusions

• E&C regulations are now too complex for a single entity– Need to go beyond the next regulation to plan for design and

implement safer and cleaner products and processes– Require new facilitating tools– Require regional/international collaboration– Entity along supply chain need to work in concert

• SME carries heavy burden in relation to their outputs• Mechanism to manage and disseminate information on chemical substances needs to be established– JAMP tools and support

• Highly rated by participating companies in demonstration projects• Could be effectively implemented in supply chain

– For JAMP to gain more visibility/recognition• Domestically – Develop local experts and publish guidelines in local language

• Internationally – International standardization of JAMP mechanism


MTEC’s Environment Research Unit


Environment Research UnitActing Director: Dr. Nudjarin Ramungul

LCA Lab

Head: Ms. C. Yuvaniyama

[email protected]

• Infrastructure for and

Application of Life Cycle

Assessment

• Evaluation of

Environmental Products

• Development of

Environmental

Assessment Tools

• Consultation services on

LCA & Carbon Footprints

• Human Resources

Development on LCI/LCA

EcoProduct Lab

Head: Dr. K. Annanon

[email protected]

• Design and Development

of Ecoproducts

• Products Prototyping

• Development of

supporting tools for the

development of

Ecoproducts

• Human Resources

Development on

Ecodesign

• Consultation services on

Ecoproducts Development

& Ecolabelling

Environmental Management

Lab

Head: Mr. S. Papong

[email protected]

• R&D in Environmental

Management Technology

• Support industry in the

area of Eco-efficiency

improvement

• Assessment of Life Cycle

Costing

Materials for

Environment Lab

Head: Dr. P. Saewong

[email protected]

• R&D of products from

industrial & agricultural

wastes and products

from natural materials

• Develop prototype of

production process –

focuses on process

simplification and

reduction/ elimination of

the uses of toxic

substances

Hazardous Substances Free

Technology (HSF) Lab

Head: Dr. A. Thanaboonsombut

[email protected]

• R&D for environmentally

preferable materials and

process

• R&D on materials

technology for the reduction

of toxic emissions

• Capacity building for the

analysis of the amount of

concern substances in

products

• Human Resources

Development and

Consultation services in the

area of regulated

substances in products

Unit in charge of JAMP

Contact persons:

Dr. Apinya Panupat, [email protected]

Dr. Nudjarin Ramungul, [email protected]

Thank you for your attention!

Werasak UdomkichdechaNational Metal and Materials Technology Center

E-mail: [email protected]


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