This is part of a series in which we recap sessions from the 2023 IMDS & Product Chemical Compliance Conference.
Are you in the know about the latest round of major IMDS enhancements? A session at the 2023 IMDS & Product Chemical Compliance Conference titled “What’s Next: IMDS Release 14.2 & Beyond” shared important insights about where we are now, where we’re going, and what’s coming.
The presentation was given by Chuck LePard, an environmental, social, and governance senior consultant at DXC Technology and the Americas representative for the International Material Data System & Compliance Data Exchange. You can also read our recap of LePard’s other session at the 2023 IMDS Conference, “Top 2023 IMDS Helpdesk Issues, Escalations & Rejections.”
“To borrow a phrase, ‘This ain’t your father’s IMDS,’” LePard said. “What we have to do to satisfy the regulators today is a lot more demanding than what we had to do three years ago and probably a lot easier than what we’ll have to do in three years.”
Register for the 2024 IMDS Conference
This topic and more will be covered at the 2024 Hybrid IMDS, Product Compliance & Sustainability Conference from October 15-16, 2024, at Laurel Manor in Livonia, Michigan. Conference registration is now open here. You can also separately register to add on a new optional Day 3 in-person half-day training on Oct. 17 here.
On Day 2, LePard will lead two sessions: “IMDS Release 15 Preview,” which looks ahead into pre-production IMDS Release 15 content and preliminary results from AIAG IMDS Model Office testing; and “IMDS Help Desk Report,” which gives information and advice on addressing the most common current reporting challenges in IMDS and may include the top help desk comments on the most recent IMDS releases.
2023 IMDS Release Session Highlights
Here are the IMDS release session highlights from the 2023 conference with some updates added to bring it current to today.
“One of the things that our team has done to try to work a little faster and more effectively is we’ve changed the method we develop things," LePard shared, noting that they get feedback from OEMs during the draft stage instead of at the end. “It’s much more of a friendly, interactive process.”
Looking at IMDS release history, releases used to be out for several years but have become much more frequent, say two or three minor releases and a major release a year, LePard noted.
“I find this really exciting,” LePard said. “A lot of functionality is happening a lot faster, which means you don’t wait as long, but it also means there’s a bigger learning curve.”
IMDS Release 14.1
Out August 2023, 14.1 addressed inbox and outbox display issues and fixed how IMDS-AI Customer-Specific MDS files were excluding certain recipient-specific information.
“We changed some things in IMDS that were pretty fundamental,” LePard noted. “We’ve had really good feedback."
Release 14.2
Out November 2023, 14.2 added search criteria for valid MDSs when searching published MDSs, added gold to “Chk: Classification 1-4 w/o silver” to permit a high percentage of gold in classification 7.2 Glass/Ceramics, and amended the 14.0 filler (dual use) check for filled thermoplastics.
“It just has a couple of little changes to it, but some of these are pretty handy,” LePard shares.
Releases 14.3, 14.4, and 15.0
Release 14.3 and beyond were not out at the time of LePard’s 2023 presentation, so he made the following forward-looking statements, which we supplemented with updates here.
For Release 14.3, which came out in March 2024, he noted, "What we will be talking about is adding the ability to do recyclate for materials classification 7.1 with the bio-based reporting that we added in 14.0 for some of the polymers and such. Originally, we didn’t think it was appropriate for 7.1; we’ve learned otherwise, so we’ve added some capabilities there. There are also some major life changes to how the polymer symbol wizard is going to work.”
LePard foresaw that psuedo-substances that could represent multiple plasticizers or flame retardants would be deactivated, and many would have replacement psuedo-substances added to the IMDS basic substance list for use where the actual substances are not declarable or prohibited.
Release 14.4 came out in July 2024, introducing a check to analyze MDSs for the presence of material using classification 8.1 (electronics) or 8.2 (electrics); if such a material is present on any level in the MDS (not only direct references), a warning message will be displayed. Classifications 8.1 and 8.2 were deactivated as part of Release 13.0 in May 2021, after which materials with one of those classifications could no longer be created or released.
Regarding Release 15.0, LePard envisioned Life Cycle Analysis, Product Carbon Footprint, and MCCP among the big topics that need to be addressed.
“This Life Cycle Analysis (Product Carbon Footprint) is opening a door that I hoped IMDS would never have to open today,” LePard stated. “IMDS is completely about what’s in my product. PCF starts to get into the area of what are the things that are done in the process to produce my product that generate emissions.”
LePard continued, “Just like we added the recyclate and then it was optional, or we added chemistry manager and it was optional, but now it’s getting phased in as required in the near future, I think that’s going to be the pattern we’re going to see (with PCF reporting). Let’s get it out there in an early draft, see what works, see what doesn’t, get some data, figure out how to make it better and then refine it. And once we’ve got it refined to something that’s useful, make it required.”
Beyond 15.0
Projecting beyond Release 15.0, LePard shared a list of 20 items requested by the Steering Committee, including five items from supplier organizations.
“Some of these are a big deal,” LePard noted, such as the ability to mark accepted MDSs as obsolete.
He ended encouraging people to explore artificial intelligence (AI) as a tool: “Talk about AI and see if it might be the right answer. The analysis and reporting module in AI will let you have all of your declarations in memory in a virtual computer at once. You can do queries that would take an hour in IMDS that come back in seconds.”
Get Involved
To join the AIAG Chemical Management and Reporting Work Group and the Recommendations and Documentation Subgroup, contact Lecedra Welch Jones at LWelch-Jones@AIAG.org or Mark Mroz at MMroz@aiag.org.