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BMC Self-Certification Proposal

BMC Self-Certification Proposal. NAFTA Solution for Management of Friction Material Restricted Substances June 3, 2011. Program Goals

virginia-gallagher
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BMC Self-Certification Proposal

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  1. BMC Self-Certification Proposal NAFTA Solution for Management of Friction Material Restricted Substances June 3, 2011

  2. Program Goals • Develop an industry-wide self-certification program that ensures friction material suppliers (domestic and imported) manufacture, sell and distribute within NAFTA only products which comply with applicable California and Washington requirements (as amended). • The successful development, implementation and marketing of the Program to OEM vehicle and truck manufacturers, Aftermarket spare parts manufacturers, as well as legislative, regulatory and environmental stakeholders would be an integral tool to achieve a NAFTA solution in the absence of federal legislation. • Program will use accredited laboratories (ISO 17025 or NELAC certified) based on SAE testing protocol and edge code markings to ensure compliance with applicable state regulations for copper and other constituents contained in brake friction material products. • Program will use a third-party registrar to confirm regulatory compliance and provide pubic access to list of certified companies and products.

  3. Essential Program Elements: • Industry accepted 3rd party registrar to certify program compliance. • Importer of Record or other suitable US based entity must obtain certification for imported product. • Suitable product testing, edge code markings and product packaging labels utilized to confirm and advertise product compliance with Program. • SAE approved testing protocol and accredited laboratories (ISO 17025 or NELAC certified) required. • Initial certifications valid for 3 years – then may be renewed for subsequent 3 year periods upon updated testing results. • Product and packaging labels shall be marked with required edge code markings which include notation of regulatory compliance and product date code. • Product edge code and compliance confirmation will be available on Registrar’s Internet site for stakeholders’ confirmation and review. • Consumer focused product marking (i.e. Low Copper Product, Complies with California Copper Requirements, etc.) will be the decision of retail box designer.

  4. Edge Code Marking Existing AMECA edge code structure: DF 110 GF • DF – Manufacturer (could be multiple characters) • 110 – Formula code (could be multiple characters) • GF – Friction Coefficients Proposed: • add environmental letter code (A, B, C or X) and two digit year code to signify year of manufacture, to the existing AMECA edge code • DF 110 GF A14 – the “A” indicates meets requirements for heavy metals and asbestiform fibers • DF 110 GF B21 – the “B” indicates it meets the “A” requirements above, plus conforms to the 5% by weight copper limit • DF 110 GF C25 - the “C” indicates it meets “A” requirements above, but now meets the 0.5% by weight copper limit • DF 110 GF X21– the “X” would mean the friction material is exempt from legislation. The individual company, in conjunction with the state granting exemption, would need to provide some additional marking that would tie this to the actual exemption granted. The two digit code following the letter is the year of manufacture.

  5. Action Steps: • Obtain approval of BMC directors for further action. (June 2011 BMC meeting) • Establish steering committee to coordinate Program implementation and required timeline to ensure compliance with 2013-2014 state requirements. • Obtain RFP’s from 3rd party registrars for the Program. Review cost, implementation timing and Internet data access capabilities for each RFP. Make recommendation to BMC directors for registrar selection. • Develop formal written Program, subject to adjustments based on final state regulatory provisions as well as approved SAE testing protocol. • October 2011 - target date for initial written Program for WA draft regulatory due date. • Coordinate with SAE committee on testing protocol as required. • Development of an education / marketing program to inform the various stakeholders of the purpose and value of the Program. • Assist MEMA/BMC in state regulatory development discussions as required.

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