U.S. Department of Defense has no program in place for completing substance registrations. Hundreds of substances are at risk in the supply chain. Sometimes working with suppliers can result in exemptions therefore eliminating the need to register.
The European Union’s REACH (Registration, Evaluation and Authorization of Chemicals) Regulation requires manufacturers, importers and downstream users to ensure their supply chains are compliant with the regulation.
If suppliers do not register substances used in foreign military sales, it is possible that downstream users will be stuck footing the bill for the registrations. The European Chemicals Industry Council (CEFIC) (www.cefic.be) stimates the average cost per registration between $112,000 and $140,000.1
With hundreds of substances at risk in the supply chain, it is critical for defense procurement personnel to ensure their suppliers have registered so they do not end up paying for suppliers’ mistakes.
#1: Quantify magnitude ofrisk (how many substances do you use?)
The most critical substances are those which cannot be replaced, those which are key to the highest dollar-value programs and those which are used in mission-critical military applications. It is for these substances that shortages in materials may lead to delays in delivery.
A survey of your materials selection professionals can identify those products which would be most likely to present these types of problems. Seeking out the suppliers of these materials first makes sense as the risk is highest and thus the benefit of risk mitigation is also highest.
#2: Substances not pre-registered
For each critical substance, visit the European Chemicals Agency (ECHA) website (www.echa.eu) and key in the substance CAS number in the “Pre-registered Substances” section to determine whether it has been pre-registered. If it has not been pre-registered you are probably currently using an illegal substance on the EU market.
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