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REACH guideline by construction equipment manufactures. REACH project team, CEMA Japan. Proposal. Create guideline together with 3 associations (CECE, AEM, CEMA) Key issue is “parts which intentionally release substances.” CEMA would like to reach the agreement for our proposal.
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REACH guideline by construction equipment manufactures REACH project team, CEMAJapan
Proposal • Create guideline together with 3 associations (CECE, AEM, CEMA) • Key issue is “parts which intentionally release substances.” • CEMA would like to reach the agreement for our proposal. • Send guideline to ECHA by the end of November, before the deadline for pre-registration.
Parts which intentionally release substances CEMA chose following 3 items. 1. Extinguishing agent in fire extinguisher 2. Window washer fluid When packaged with part for export: 3. Oil for volatile corrosion inhibitor paper (bag) Cf. Guideline of car industry lists following 3 items. 1. Fragrance dispensers 2. Fire extinguisher systems 3. Windshield-washer fluid reservoirs 4. Compressed gases from pyrotechinic devices
Purpose • Having the common understanding • Which parts are intentionally release substances ? • Article or Preparation? • Acting in the common way to suppliers, customers, authorities • SVHC information provide to customers • Substance survey, like IMDS > RIPS 3.8 Guidance recommends making “Good practice by Industry association”. • ACEA(EU), car industry made its helpful guideline with JAMA(Japan), AIAG(US) & KAMA(Korea).
Introduction about substance survey system • CEMA introduced the JAMA sheet to members. • JAMA sheet is, • Excel sheet with chemical substance regulation information • Made by Japanese automobile parts industry to collect chemical substance information for every parts. • Car manufactures collect JAMA sheet from suppliers and input data to IMDS*. • IMDS was not open for industries other than automobile. However, CEMA negotiated and got permission to use it with some conditions. • More companies use it, more improvement will be expected, because IMDS was made for car parts and might need some improvements for our use. >How do you collect substance information? >Do you have common software or database for this purpose? *IMDS: International Material Data system (http://www.mdsystem.com)
納入部品 Parts 構成品A Structure parts 材料1 Material 銅 Cupper 構成品A1 構成品A2 鉄 材料2 材料3 鉛 構成品B 構成品C 六価 クロム 材料4