Thursday, March 26, 2015

Lockheed Rockets Up Indices

Lockheed Martin has been named to the Dow Jones Sustainability World Index and two CDP Climate Change Management Indices — representing a significant global benchmark among leading corporations. Ranking in these indices indicates sustainability standards where companies demonstrate economic, environmental and social performance.
New year in aerospace

Lockheed ranked in the top 10% of the 2500 public traded companies eligible for the recognition on the world index. It is one of five aerospace and defense companies worldwide to earn a spot on the highly respected index.

Being named top sustainability company in the RobecoSAM 2015 Sustainability Yearbook (page 42) indicates that Lockheed is a top performing company in the Aerospace & Defense industry. It is notable, sustainability does matter.

Sustainability in aerospace

The RobecoSAM 2015 Yearbook discusses aerospace & defense industry as a "profitable yet challenging business."

The forecast is that global cuts in government spending, especially in the United States, will put significant financial pressure on companies, forcing them to realign their strategies and diversify their business models. The commercial aerospace segment remains lucrative, with a strong demand for fuel-efficient next generation products. (Cooperation with both customers and suppliers remains a key driver of innovation, interestingly).

Product stewardship, life cycle management and operational eco-efficiency have become key requirements for both commercial and military applications, says the report. The call for alternative fuels and propulsion technologies is increasingly becoming a question of not only operating costs and mitigating supply chain risk, but one of national security and public policy.

Governance, compliance and bribery issues remain a threat to companies involved in the manufacture and sale of aerospace and defense products. Numerous scandals in the past years and investigations by authorities have led to a call for increased transparency and accountability by these companies. The sensitive nature of the business and the importance of this industry to national governments increase the public scrutiny around companies operating in this space.

Let's try something new — get the full report using this QR code:

(point your smartphone at it and... close your eyes and hope it works!)

Learn more about Lockheed sustainability efforts on their website, they're not shy about this headline.

As always, we keep an eye on Boeing and Lockheed and the aerospace industry, as all this represents such a titanic supply chain driver.

Thursday, March 19, 2015

Nanomaterials: How Safe Are They?

There are some interesting documents coming from the EU on the subject of nanomaterials.

There is Guidance available on protecting the health and safety of workers from potential risks related to nanomaterials at work, however there is no regulation (yet). Guidance for employers and health and safety practitioners is published by the European Commission in November of 2014. You can download the PDF document here. It's a good idea to get familiar with a copy.

The key thing to know is that under Europe's REACH regulation, the Registration, Evaluation, Authorization of Chemicals, nanomaterials are covered by the definition of a "substance" even though there is no explicit reference in REACH to nanomaterials. The general obligations under REACH — such as registration of substances manufactured at 1 tonne or more and providing information in the supply chain — apply to nanomaterials as they apply for any other substance.

It is clear that many workplace safety professionals right now are thinking about the potential for nanomaterials in a slurry, and exposures to dried slurry materials during maintenance of equipment. So that's getting a lot of attention.

Portrait of a nanomaterial

The US Environmental Protection Agency (EPA) defines a nanomaterial as "an ingredient that contains particles that have been intentionally produced to have at least one dimension that measures between approximately 1 and 100 nanometers."

The EU defines a nanomaterial thusly:

A natural, incidental or manufactured material containing particles, in an unbound state or as an aggregate or as an agglomerate and where, for 50 % or more of the particles in the number size distribution, one or more external dimensions is in the
size range 1 nm - 100 nm.

In specific cases and where warranted by concerns for the environment, health, safety or competitiveness the number size distribution threshold of 50 % may be replaced by a threshold between 1 and 50 %. By derogation [from the above], fullerenes, graphene flakes and single wall carbon nanotubes with one or more external dimensions below 1 nm should be considered as

Within this definition of nanomaterials, the terms "particle," "agglomerate" and "aggregate" are defined as follows:

  • "Particle" means a minute piece of matter with defined physical boundaries;
  • "Agglomerate" means a collection of weakly bound particles or aggregates where the resulting external surface area is similar to the sum of the surface areas of the individual components;
  • "Aggregate" means a particle comprising strongly bound or fused particles.

Where technically feasible and requested in specific legislation, compliance with the definition [of a nanomaterial] may be determined on the basis of the specific surface area by volume. A material should be considered as falling under the definition where the specific surface area by volume of the material is greater than 60 m2/cm3.

However, a material which, based on its number size distribution, is a nanomaterial should be considered as complying with the definition even if the material has a specific surface area lower than 60 m2/cm3.

Source: European Commission, Recommendation 2011/696/EU.

Additional Nano-Safety Resources

The following might help. Here are a couple of the publications relating to exposures during equipment maintenance from the European Agency for Safety and Health At Work, a decentralized agency of the European Union tasked with collecting, analyzing and disseminating relevant information that can serve the needs of people involved in safety and health at work. EU-OSHA is based in Spain. Here are two relevant documents:

Also see Toward Safe and Sustainable Nanomaterials: Chemical Information Call-in to Manufacturers of Nanomaterials by California as a Case Study here.

Special thanks to members of EHS Grapevine for sharing knowledge on this subject.

Thursday, March 12, 2015

New US Toxic Chemical Bill Fails

Environmentalists cry "fail" on the proposed new bill that would overhaul Federal chemical regulation. Environmental Working Group in particular published a press release itemizing the ways the bill falls short. Briefly:
This bill fails to ensure that chemicals are safe, to set meaningful deadlines and to provide the U.S. Environmental Protection Agency with adequate resources to do the job. [The bill] would rob the states of the ability to protect public health. In particular, the industry bill fails to offer a strong safety standard that would require chemical manufacturers to prove their chemicals are safe before they hit the market. Instead, the bill would allow companies to show only that their substances pose “no unreasonable risk of harm.” - EWG
Then again, don't Environmentalists always say TSCA reform bills fall short? I don't mean to nit-pick but one does wonder what a sufficient proposed reform bill would look like.

The New TSCA

The bill submitted Tuesday is co-sponsored by U.S. Sen. Tom Udall, a New Mexico Democrat, and Sen. David Vitter, R-Louisiana. It would require the Environmental Protection Agency (EPA) to make its assessments about chemical safety solely on risk to public health and the environment. It would also increase fines on chemical companies that break the law from $25,000 to $37,500 per violation. (Not too intimidating.) (Maybe EWG is right after all!)

Anyway, here is the official release from Tom Udall's website. These proposals come and go, but we are responsible for knowing their contents regardless.

Among other changes, the new law sets more aggressive and attainable deadlines. For instance it imposes at least 15 deadlines for EPA action, developed with input from the agency.

Also, the new bill creates additional requirements and sets reasonable limits on Confidential Business Information claims, such as:

  1. Requiring that confidentiality claims be substantiated up front and imposes a 10-year, renewable time limit on such claims
  2. Requiring EPA to review claims that protect the identities of chemicals in commerce
It's interesting, of course, so check out the bill in its entirety as soon as you have an opportunity.

Tuesday, March 3, 2015

Apple Improves Conflict Mineral Accounting

Smartphones are made of metal. Every smartphone contains about 40 different minerals, including tantalum, tungsten, copper, iron, nickel, aluminum, tin, silver, chromium, gold and palladium. Each performs a different role. Some of those minerals may come from mines or smelters and refineries associated with conflicts in unstable parts of the world; in that case, those so-called conflict minerals violate U.S law.
Conflict mineral compliance can be a cloudy affair

Apple hasn't been at the forefront of conflict mineral tracking for ethical or legal compliance, but their 2015 Supplier Report indicates the company is making progress.

"All tantalum smelters known to be in our supply chain remained verified as conflict-free throughout 2014," says the company in its recent report. Note the qualifying phrase, known to be in our supply chain; that phrase highlights both the central snag in supply chain material disclosure and one of the more popular loopholes. (It's what you don't know that can't hurt you. In theory.)

In early 2014, Apple says it introduced a deadline to smelters: be verified conflict-free or in the process by the end of 2014. If the deadline were missed Apple threatened to remove them from the supply chain.

Apple reports it more than doubled the number of verified conflict-free smelters to 135 in 2014, and another 64 are in the process of verification by the Conflict-Free Smelter Program (CFSP) or an equivalent independent third-party audit program.

According to Apple's 2015 report, four smelters were unwilling or unable to commit to be audited by a third party. Apple says it put those smelters "on notice" that they will be removed from the Apple tree.

It would be interesting to see a list of those four smelters.

It turns out, you can. Starting in 2011, and not a moment too soon, Apple began encouraging its supply chain smelters to comply with the CFSP (or an equivalent independent third-party audit program). To drive accountability and help stakeholders track progress, the company publishes a quarterly list of the names, countries — and CFSP participation status of the smelter and refiners in the supply chain.

The following smelters and refiners are suppliers to Apple that Apple has listed as "Not Participating" in third party audits despite pressure to do so from Apple. It looks like more than just the four they mentioned.

Apple Smelters / Refiners Not Participating in 3rd Party Audits

Name, Country, Metal
Bauer Walser AG, Germany, Gold
Caridad, Mexico, Gold
Chugai Mining Co., Ltd., Japan, Gold
Daye Non-Ferrous Metals Mining Ltd., China, Gold
Do Sung Corporation, Republic of Korea, Gold
Doduco GmbH, Germany, Gold
Gansu Seemine Material High-Tech Co. Ltd., China, Gold
Guangdong Jinding Gold Ltd., China, Gold
Hangzhou Fuchunjiang Smelting Co., Ltd., China, Gold
Hunan Chenzhou Mining Group Co., Ltd., China, Gold
Hwasung CJ Co. Ltd., Republic of Korea, Gold
Korea Metal Co. Ltd., Republic of Korea, Gold
Lingbao Gold Co., Ltd., China, Gold
Lingbao Jinyuan Tonghui Refnery Co. Ltd., China, Gold
Luoyang Zijin Yinhui Metal Smelting Co. Ltd., China, Gold
Penglai Penggang Gold Industry Co. Ltd., China, Gold
Samwon Metals Corp., Republic of Korea, Gold
Tongling Nonferrous Metals Group Holdings Co., Ltd., China, Gold
Torecom, Republic of Korea, Gold
Yunnan Copper Industry Co. Ltd., China, Gold
CNMC (Guangxi) PGMA Co. Ltd. China Tin
Gejiu Kai Meng Industry and Trade LLC, China, Tin
Gejiu Zi-Li, China, Tin
Huichang Jinshunda Tin Co. Ltd,. China, Tin
PT Seirama Tin investment, Indonesia, Tin
Jiangxi Minmetals Gao’an Non-ferrous Metals Co., Ltd., China, Tungsten

From the Apple Quarterly Smelter List, February 2015, in the Apple Supplier Responsibility synopsis. For more information about Apple’s Supplier Responsibility Program, visit

In closing, conflict mineral compliance is not the easiest thing to achieve. But it can be done. And Apple can do it. It might not be the most desirable compliance activity in terms of logistics. But others have done it, and Apple, with cash reserves now topping $178 billion, is not without resources.

Tuesday, February 24, 2015

Bee Bop BPA

Bisphenol A (BPA) is being considered by California again for possible listing on Proposition 65. Last time it was listed was for "developmental" toxicological endpoints. BPA was removed from the Prop 65 list after a lawsuit fought by the American Chemistry Council (ACC).

"We do not believe there is a scientific basis for including BPA on the Proposition 65 list and we look forward to our case being heard on the merits sometime this summer,” said Steven G. Hentges, Ph.D., of the American Chemistry Council’s (ACC) Polycarbonate/BPA Global Group.

This time the listing is based on female reproductive toxicity.

The Developmental and Reproductive Toxicant Identification Committee (DARTIC) has its next meeting on May 7, 2015. DARTIC is essentially California's "experts" for determining whether a chemical has been clearly shown through scientifically / generally accepted principles to cause reproductive toxicity.

At that meeting in May, stakeholders will consider whether BPA has been clearly shown to cause female reproductive toxicity.

The URL for the webcast (not active until the day and time of the meeting) is here, if interested. If the DARTIC does not complete its deliberations on May 7, 2015 the meeting will be continued on May 21, 2015 at the same location. The agenda for the May 7 meeting will be provided in a future public notice published in advance of the meeting.

Here's the US EPA BPA findings.
More info here.

Friday, February 20, 2015

West Coast Ports Remain Stalled

[UPDATED] Tuesday February 24, 2014 -- West Coast ports began operating at full capacity on Monday. Dock workers and port owners reached tentative contract late Friday night. It figures, right after I blog about affects of closed ports, they open right up again! #MurphysLaw  Anyway, what we've written below still stands in terms of consumer implications.


West Coast dockworkers and their employers had not yet reached a labor deal yet today, Friday February 20.

James McKenna, the president of the Pacific Maritime Association, told Bloomberg recently that delays at many of the ports are leading to a "coast-wide meltdown." It is a serious situation, as anyone can see. It may affect the consumer sooner rather than later.

Take the auto industry. Global car companies rely on shipped inventory rather than having warehoused stock and parts.

Honda said it will slow production beginning Monday at plants in Ohio, Indiana and Canada because of shortages of "several critical parts," including "electronics, and some larger assemblies such as transmissions" that arrive via West Coast ports, reported in Auto News.

Even if automakers airlift parts to factories to bypass ports, it's a more expensive process. All this means higher prices for consumers.

Hopefully this won't require a tax-payer bailout....

We'll keep an eye on it.

Thursday, February 12, 2015

Living in a Material World: Lists and Compliance

It's a challenge for companies today to keep up with rapidly changing expectations on chemical use and chemical management in products, in processes, in facilities and in a supply chain.

Retailers and manufacturers in a supply chain face increasing scrutiny over material use. Whether it's ongoing compliance related to international laws and regulations such as Europe's REACH regulation, or new expectations around disclosure of conflict minerals, companies must have robust and effective tools in place to keep them out of trouble.

We live in a material world

In addition to staying on top of existing and emerging regulations, companies must also continuously evaluate and respond to their customers' demands for disclosure about green chemistry, materials stewardship, and chemicals management.

Over the last year, major retailers such as Walmart have started identifying chemicals for suppliers to eliminate. Similar lists are expected to pop up everywhere.

Managing these lists — not just the regulatory, not just the industry-specific but also the company-specific a la Walmart — by hand is one way. At a certain point it becomes desirable to automate not just tracking substances in a supply chain but tracking the restricted lists as well!

Supplier data management software should contain at a minimum these features:
  1. Data collection from and about suppliers
  2. All data is inter-connected but accessible by permission only
  3. Product stewardship and risk assessment dashboard tools
  4. REACH, RoHS, WEEE (and more) compliance assurance
  5. Compliance with hundreds of regulatory lists
  6. Disclosure management down to the substance level
  7. Ability to set threshold quantities for substance analysis
  8. Document management / central relational database
  9. Reporting capability, customizeable
  10. Conflict mineral tracking and reporting functionality
  11. Ingredient data management for compliance
  12. Mechanisms for bill of materials (BOM) for analysis down to the substance level to pinpoint regulatory issues
  13. Bill of materials (BOM) scrubbing and data consolidation
  14. Automatic upload, parsing and analysis of the latest EICC GeSI supplier template
  15. Ease-of-use for increased supplier usage and faster response times
  16. Audit trail of requests and responses including supplier material declaration sign-off
  17. Supplier dashboard / performance at-a-glance
  18. Visibility into substances in the supply chain
  19. Suppliers kept hidden from one another
  20. Technology updates are fairly easy
  21. No demanding consultant fees -- mind the racket ;)
Look at Actio Software for Material Disclosure, their new website has good downloadable assets that are useful for gathering requirements for software decisions.