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June, 2010
Sustainable Business Practices
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HGC News Note 06-06-10
6/15/2010 11:59:11 AM
HGC News Note 060606
“Leave Your Carbon Footprint At Home” was the heading of an article in the travel section of a recent Sunday newspaper. The spill in the Gulf is six weeks old and barely controlled. Are you sensing the approaching perfect storm in environmental regulations?
Are you too small to be concerned? 
When it comes to environmental requirements most small companies see these as something to be avoided and have failed to recognize the strategic value these requirements can provide. If you are below the radar screen and have no competition that might be one approach. Companies who recognize that staying in the pack provides some protection are doing the minimum to avoid trouble. They know that the customer (or rather the loss of one) is a bigger threat to their business than the regulatory agencies. The leaders have crafted strategies that are not reactive and are quietly changing the marketplace.
News Briefs: 
  • RoHS and WEEE Revisions moved forward.  Renewables got some concessions but will pay the piper if they don’t honor their commitments in the future. The fact that renewables are in the RoHS WEEE discussion indicates the expansion that is occurring in these Directives. 
  • Just as trace elements can be critical to your health, rare earths may be critical for your product.   The International Electronics Manufacturing Initiative (www.iNEMI.org) is conducting a survey to assess the electronics industry's usage of Rare Earth Metals (REMs).  You can use the following link to access the Survey:     http://www.surveymonkey.com/s/Rare_Earth_Metals     Check with your suppliers if you don’t know your rare earth dependency.
  • REACH compliance investigations in the EU show there are problems. A very significant problem for you or your supply chain would be substances that were not pre registered (or registered) and must be pulled from the market. 
  • The failure of the BP blowout preventer is sending a major shock wave throughout regulated industries.
  •  The President’s Cancer Panel reports that environmental and occupational exposure to chemicals is a more significant risk than originally thought.
Please, contact me if you need additional information on any of these news items
HGC News 05-25-10
6/15/2010 11:57:21 AM
HGC News Note 052510
 
What are your customers or competition doing on the environmental front?
 
Supply chain information    While Walmart was not the first corporation to require suppliers to provide environmental information, it is probably the most noteworthy. Walmart recently reported five years of progress including progress on its goal of removing 20 million metric tons of greenhouse gases from the supply chain. Ford and Ikea are doing the same. Ford has contacted suppliers who represent a third of its annual $65 billion supply chain spending. Ikea has shown that based on sales there is a reduction but not in absolute emissions. Where can this information be found? In these companies’ annual sustainability reports.
Key electronics firms support RoHS revisions. What do they know that you don’t? When Companies like Sony Erickson, HP, Dell and Acer support the rigorous changes proposed for the revision of the Restriction of Hazardous Substances Directive, you should be planning accordingly.
HGC News Note 05-07-10
6/15/2010 11:55:29 AM
HGC News Note 05-07-10
A few news items that should be in your thoughts as you plan and conduct your business. 
Resource scarcity is on the minds of DoD as reflected in their Strategic Materials Security Plan. You may recall that the EU has been doing the same especially with the steep ramp up in some metal and rare earth prices. You may also remember that the DoD announced plans to reduce their “boot print”. A $10 a barrel increase in the price of oil adds about $1.2 billion in additional energy costs.  
A study on sustainability initiatives reports that regulations are a more important driver than competitive advantage. In addition to the impact of Greenhouse Gas reporting, the importance of Scope 3 reporting for their supply chain has increased when measured against the previous year’s report.
If you still dismiss sustainability as vague do gooder stuff, you should read the Harvard Business Review which listed environmental issues as the next business mega trend.
Walmart starts testing toys for Cadmium.
California is preparing its plan for declaring chemicals of concern and managing those chemicals in products or use under California’s Green Chemistry Initiative.
As this note goes to press (to server probably more current) the price of oil is at $77 per barrel). It only took Greece, a Gulf of Mexico well leak and a 1,000 point drop in the DOW to get the price down from $83. Energy costs and the environmental issues associated are important business considerations.
Preparedness is another consideration. Some areas in Massachusetts and Kentucky had unprecedented flooding. Two million people in the Greater Boston Area had a boil water order when a relatively new coupling blew out on a 10 foot diameter water supply pipe. Water supply was maintained and potable water returned to service in a few days. For either event, would you be prepared?
The RoHS and WEEE Recast (review) is looking at some very significant changes that will have a major impact on product design and end of life cost management. Use of the CE Mark and expansion to all electronic equipment is under consideration. Deliberations will continue this Spring.
Sony’s aggressive targets for energy, materials and Co2 reductions may be an indication of what to expect in the market place. Sony plans to have a zero environmental footprint by 2050. 2050 may not be your concern, but milestones in 2015 could be.
HGC News Note 3/30/2010
3/30/2010 8:40:55 AM
HGC News Note 3/30/2010
Acrylamide Listed As SVHC
Today the European Chemicals Agency listed Acrylamide as a REACH SVHC . This listing is off schedule as it had originally been planned for January but was delayed because of pending legal action. See the January 31 HGC News Note.
Acrylamide is a carcinogen and mutagen used in wastewater treatment, paper processing and engineering grouts, among uses. Your information obligations are in effect today.
HGC News Note 3/21/2010
3/30/2010 8:37:35 AM
HGC News Note 032110
REACH SVHC Additions 
The eight chemicals recently proposed by the EU for addition to the REACH Substances of Very High Concern (SVHC) list are:
  • boric acid;
  • tetraboron disodium heptaoxide hydrate;
  • disodium tetraborate anhydrous;
  • potassium dichromate;
  • ammonium dichromate;
  • potassium chromate; 
  • sodium chromate;
  • trichloroethylene.
These substances have wide use across many products and manufacturing operations.
 
EPA TSCA List   
EPA is providing free web access to the Toxic Substances Control Act (TSCA) Chemical Substance Inventory. This is one of many steps that EPA is taking to update the 30 year old process the US uses for chemical approval. The inventory can be found at
http://www.epa.gov/oppt/newchems/pubs/invntory.htm

Greenhouse Gasses and Your Customers 
If you find that your customers are expecting you to provide environmental information about your products and operations, don’t be surprised. Home Depot announced it will achieve a 20% reduction in kWh per square foot usage in its U.S. stores by 2015. They already have  saved 2.6 billion kWh since 2004 (yes, that is billion). The second part of their program is reducing greenhouse gas (GHG) emissions 20% from US suppliers (also by 2015).   You may recall from earlier News Notes that Walmart is on an aggressive sustainability program with its supply chain and expects  a 20-million-tonne cut in greenhouse gas emissions through its supply chain by 2015. If you are a Federal contractor or vendor don’t forget that under Executive Order 13514 Federal Agencies are in the process of reporting and reducing greenhouse gas emission from Federal Agencies, their contractors and their vendors.
HGC News Note 3/9/2010
3/30/2010 8:33:21 AM
HGC News Note 030910
REACH SVHC List Expanding   The European Chemicals Agency has proposed adding eight new substances to the Substances of Very High Concern List. If accepted, the additions will be published this summer. More information on these substances will be available in the next news note. Many of the proposed SVHCs have broad use including electronic products.
Emergency Power Generators -  EPA issued a final rule on February 17th on emission requirements for large existing diesel engines. This rule includes emergency use engines. The owners and operators will need to install emissions controls. Emergency engines will need to comply with operating limit requirements. Assess your situation so you can plan and budget accordingly.

A Word to the Wise  
On March 8th, U.S. Environmental Protection Agency Administrator Lisa P. Jackson discussed the agency’s seven key priorities and the strong connection between environmental protection and economic prosperity in a speech at the National Press Club today.  Here is just one comment that businesses should heed:  “Consumers want to know that their products don’t have hidden health and environmental costs.  Companies must respond to parents who refuse to buy bottles with BPA in them, or that leech dangerous chemicals into drinking water.  Industry can try to resist and ignore EPA, but I know – and they know – that they resist the forces of the green marketplace at their own peril…”
Managing the chemicals in your products is becoming a business requirement. The full text of the Administrator’s comments can be found at http://www.epa.gov/newsroom.
HGC News Note 2/21/2010
3/30/2010 8:31:40 AM
HGC News Note 2/21/2010
Chemical Cocktails
The Environment Council of EU Environment Ministers is recommending that the European Commission consider the effect of exposure to multiple chemicals as part of chemical policy and risk management.  These mixtures are also known as chemical cocktails. These recommendations underscore concerns with endocrine disruptors. The US is not far behind - a National Academy of Science report pointed out the need for examining combined exposure to phthalates. Similar concerns were reported from Danish biomonitoring research. Your business plan should include strategies for managing this risk when the New York Times splashes the latest chemical of concern and the fact that it is in your product. 
 
RoHS Revisions
The comment period closed last week on the significant changes for the RoHS revisions. Based on the latest proposed text, the requirements will expand to all electrical and electronic products and include the following additional materials in the restrictions (at 0.1% homogeneous level)
  • brominated and chlorinated flame retardants;
  • PVC,
  • chlorinated plasticisers,
  • DEHP, BBP and DBP.
 
It also sets the stage for reviewing the following chemicals for future inclusion:
  • arsenic compounds,
  • beryllium and its compounds,
  • antimony trioxide,
  • dinickeltrioxide,
  • bisphenol A,
  • organobromines and organochlorines
Are you ready to manage these changes?
 
DoD and Climate Change
For the first time, the US Department of Defense will address climate change in its Quadrennial Budget. The Pentagon expects global climate change to cause political instability and conflict.
HGC News Note 1/13/2010
3/30/2010 8:25:23 AM
HGC News Note 011310
The Consumer Electronics Show
Green was mainstream at this year’s CES, considered integral to the product and an expected criteria. Because environmental considerations and energy efficiency are becoming widely adopted, manufacturers are actually saving money through design and innovation.   Many of the greenest products are also top of the line with best profit margins.  Some key learning from CES are energy efficiency, reduction of toxic chemicals, and managing product end of life.   These should be part of your design considerations.
EPA Priorities
The EPA Administrator announced “seven key themes” to focus the Agency’s work for 2010. Two of these themes will impact you. The first is Global Climate and Greenhouse Gas reduction, the second is safer chemicals. You may have been able to ignore European requirements but you won’t be able to ignore the EPA.
REACH SVHCs Added
Effective today, January 13, 2010, the European Chemicals Agency formally added 14 of the proposed 15 Substances of Very High Concern. Your information obligation for the new additions commences immediately. Acrylamide has not been added today pending an order by the General Court of the European Union to terminate an interim relief order. For your sales in the EU you or your importer needs to be prepared to inform your downstream users or answer requests for SVHC declarations.   For more information contact Stephen Greene.
HGC News Note Dec 28
1/2/2010 8:50:08 AM
Wishing you the very best in 2010.   A cautionary note from 2009 and some points for the New Year you will want to follow.
Know your product
Most small businesses have not addressed the basic information requirements for conformance with generally accepted product stewardship and sustainability standards.  While these businesses have avoided the effort and potential expense of gathering and managing these requirements, they need to understand the business implications of restricted markets or the inability to address their customer’s requirements in a timely manner.
 
Plan for the following in 2010
  • 15 new substances of very high concern will be added next week to the REACH SVHC list (Annex XIV). Your obligation to provide Downstream User information begins the day of official listing. This will bring the current list to 30 substances.
  • HCFC refrigerants ban in new products - specific Class 2 Montreal Protocol Ozone Depleting Substances are now coming up for restriction by EPA.
  • While the UN Conference on Climate Change in Copenhagen was marginally successful, the issue of carbon impact has not gone away. Smart money is preparing as appropriate for their business. This may be as simple as improved energy efficiency, better design and review of specifications and purchasing contracts. Gathering or providing the right information will be the key to success. Considering the cost of energy, understanding the carbon impacts will be a financial benefit even if carbon labeling is not required for your products or services.
  • Understand the implications of the Energy Independence and Security Act of 2007 for your business. In 2010 lamp labeling will be required and by 2012, incandescent bulbs will be banned in stages. Some European countries are ahead of the US on the incandescent lamp ban. With the shift to new light technology, it is important to fully understand the impact of the changes for your business.
If the European market is important to your business, have you factored in new eco design criteria in your CE Marking requirements. At present this applies to external power supplies and some energy using products.
EPA is concurring with the voluntary production ban of Deca brominated fire retardant.
9 items total
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