This is part of a series in which we recap sessions from the 2023 IMDS & Product Chemical Compliance Conference held on October 17-18, 2023, at Suburban Collection Showplace in Novi, Michigan.
The Chemical Management & Reporting Work Group (OHCL) is doing important work to improve IMDS as it provides guidance for emerging substance regulation impacting the automotive industry and North America’s perspective to the global industry and supply chain.
A summary report was recently presented at the 2023 IMDS & Product Chemical Compliance Conference by Jim Raymond, a senior manager in the Chemical Management Office in the Product Regulatory Affairs Division of Toyota Motor North America Inc. Here are the highlights.
The group’s goals are three-pronged.
- Define the global impact of emerging chemical management or product stewardship regulations on the automotive industry (TSCA, Canada-CMP, REACH, ELV, SCIP, Brazil ROHS, POP, China VIAQ).
- Support the development and operation of chemical reporting processes to meet regulatory and customer requirements (IMDS, SCIP).
- Interact with other automotive associations on regulatory, customer, and reporting requirements (SUAL, IMDS-SC, CLEPA, ACEA, JAPIA, IPC, ZVEI).
2023 in Review
OHCL had a productive year. It supported various industry groups representing the North American Automotive Industry, including proposing five enhancements for IMDS version 15.0; assisting AEM (Heavy Equipment Manufacturers) as they set up their processes for chemical management; explaining IMDS and GADSL and how they work together to the BizNGO Hazardous Assessment Work Group; and with IPC participating in material declaration teams and the ESG group.
The group also made Recommendations 025 for recyclate guidance development, raising major issues for clarification; and consolidated the GHS work group into another working group and formed two new working groups, Electroplating Work Group and Product Carbon Footprint — AIAG Team.
Future View on Emerging Challenges
OHCL has its eye on several action items as it approaches 2024. The utilization of IMDS for LCA (Life Cycle Assessment) — Product Carbon Footprint is one of the next big topics that it will focus on. Also, the EPA PFAS Reporting Rule published in September 2023 is very significant, and reporting guidance will be another key topic of discussion in upcoming meetings.
In addition, OHCL will revise and expand the recycling reporting for metals and biobased, Recommendation 025. Plus, OHCL will update the AIAG website to add supporting information, including resources about various OHCL-related topics, such as SCIP, Chemistry Manager, EU Battery Directive, and GADSL.
OHCL Subgroup Highlights
OHCL has four subgroups tackling different initiatives. Here’s a look at what they’ve been up to and what’s new.
IMDS Conference Planning Work Group
This group plans the conference and makes improvements every year based on survey feedback. The 2023 summit theme was Transitioning IMDS from Materials Compliance to the Circular Economy. The conference was extended to two full days to capture additional sustainability content. In-person attendance was up from the previous year and offered increased opportunities for networking.
Recommendation and Documentation Work Group
This group does model office testing and provides feedback for IMDS 14.0, 14.1, and 14.2, identifying errors and making recommendations for improvement.
“This is a really core activity for AIAG,” Raymond says. “It’s a great opportunity if you want to see what’s coming and have some feedback in what the final version looks like.”
The group also captures North America’s desired enhancements and refines them for submission to the IMDS Steering Committee, which recognizes AIAG as a key contributor to enhancements.
Supplier Alliance Work Group
This group has significant influence toward IMDS enhancements. It proposed five enhancements for IMDS 15.0 and five for 14.0, four of which were adopted with the fifth still under consideration.
The group also presented AIAG activities at the CLEPA event in May 2023; represented AIAG in a face-to-face meeting with the IMDS Steering Committee and Supplier Alliance; and participated in IMDS workshops.
Electroplating Work Group
This new group was recently formed to focus on hexavalent chrome and PFAS replacement for electroplating. There are a lot of technical barriers that it will navigate in a phased approach.
Its stakeholders include OEMs, chemical suppliers, electroplating applicators, and the National Association of Surface Finishers.
Its objectives are to focus on the technical development of new process chemistries, as well as the operational aspects of the industry transformation; and to explore ways and means to expedite a smooth transition to these new technologies while maintaining optimum quality and continued uninterrupted supply.
Introducing the AIAG Product Carbon Footprint (PCF) Team
OHCL recently added this team in connection with the PCF activity happening in Europe between Catena-X and the IMDS Steering Committee. Within it, four sub-teams were formed — IMDS Enhancement, Rulebook, Data Quality, and Data Generation – but the latter two recently merged. Every regional association is allowed to have three members on each team, so three members from AIAG OHCL are participating to provide input for North America.
Get Involved with OHCL
OHCL is seeking volunteers to assist with its subgroups and team at multiple tier levels in order to help accomplish their goals. Volunteers benefit from bimonthly regulatory updates, as well as having a direct line to what is happening in the IMDS Steering Committee and future IMDS software updates. All AIAG members are encouraged to participate. To get involved, contact Jim Raymond at Jim.Raymond@Toyota.com, Yvonne Luiza at Yvonne.Luiza@Aptiv.com, or Lecedra Welch Jones at LWelch-Jones@AIAG.org.
About the Presenter
Jim Raymond is a senior manager in the Chemical Management Office in the Product Regulatory Affairs Division of Toyota Motor North America Inc. He has worked at Toyota since 2003. He spent almost 10 years in the Quality Division and has been working in chemical management since 2012, including a one-year assignment at Toyota Motor Corporation in Japan. His team’s responsibilities include regulatory approval of incoming chemicals, approval of part composition data (IMDS), regulatory reporting to the EPA and other agencies, creating and overseeing implementation of company chemical-related polices, and supply chain management activity related to chemical management. Raymond has been the OEM Chair of the AIAG Chemical Management and Reporting Group since 2020. He is also active in various automotive industry associations and participates on the Global Automotive Stakeholders Group America’s Technical Team.