Chemical Information Management— Upstream and Downstream
By Aaron Zude, senior director, SEMI Environmental Health and Safety
Chemical information management is rapidly becoming one of the most pressing issues of concern for EHS professionals in the semiconductor and high technology supply chain. By information management, I mean the active engagement in collecting and responding to “upstream” sources of information, and the efficient participation in the “downstream” exchange of information.
Upstream Chemical Information Management
Upstream chemical information management issues revolve primarily around the challenges of identifying, tracking and “data mining” the vast number of chemical-related proposed, enacted, and amended regulations that seek to register, restrict, or ban the use of chemicals, or the products containing them (substances, preparations and articles for you REACH fans). The trick to upstream information management is to obtain and interpret the right information, in the right amount, and at the right time— to enable the efficient mobilization of resources for advocacy or for responding to the regulatory requirement.
From the perspective of the SEMI EHS Division, effective upstream chemical information management allows us to:
- Mobilize potentially affected member companies in advocacy activities
- Prepare industry position papers
- Develop consensus approaches to compliance
- Organize informational workshops and webinars
From the perspective of SEMI member companies, effective upstream chemical information management allows you to:
- Alert management of potential activities that may limit production or use of certain chemicals or the ability to sell product into certain countries
- Advise product developers of future limitations of raw materials, components or subassemblies
- Develop strategies for achieving regulatory compliance
- More effectively forecast staff and external resource needs
A number of companies provide subscription services that assist EHS professionals with tracking existing regulations and obtaining early warning information on chemical regulations. In addition, the SEMI EHS Division, working through the International Compliance and Regulatory Committee (ICRC), is currently developing a Regulation Tracker or “Dashboard”, to assist member companies with managing upstream chemical information. The Tracker will identify regulations that are, or will be, impacting the semiconductor equipment and materials industry, and provide color codes (green, yellow, red) to indicate the need for industry response and action.
Downstream Chemical Information Management
Downstream chemical information management issues are being driven primarily by REACH and RoHS type regulations, which essentially require registration of certain chemicals, development of data on chemical hazards and risks, and communication of safe use to customers and consumers. These new regulations are especially challenging. To be successful in obtaining the information needed for required activities like developing exposure scenarios and performing risk assessments, a materials and equipment supplier must be actively engaged throughout the entire high-technology industry supply chain. As in your personal life, constant and effective communication is the key to a harmonious relationship. Such is also true in the relationship among semiconductor suppliers and device manufacturers. The importance of such communication was recently articulated by a SEMI member company EHS representative who succinctly put it as: “No Data, No Market.”
If you are a materials and equipment supplier needing support in managing downstream chemical information issues, there are a number of SEMI EHS Division activities available to help you:
- The SEMI REACH Chemicals Suppliers Working Group is currently working with industry association partners, ISMI and ESIA to refine REACH exposure scenario template for use across the industry supply chains.
- The SEMI REACH Equipment Suppliers Working Group has launched an awareness raising campaign for the supply chain of equipment manufacturers.
- The SEMI RoHS Working Group is focused on appreciating and mitigating the impacts of recent changes to China RoHS regulations and proposed changes to EU RoHS regulations.
If you would like to participate in these Working Groups, please contact Sanjay Baliga (EHS Senior Manager) at firstname.lastname@example.org. Also, please feel free to contact me at email@example.com or 408.943.6921 or stop by as my door is always open.
Mar 3, 2009