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OEM/Supplier Panel Says OEMs Do Check Vehicles for Prohibited Substances, But Also Trust Suppliers and Expect Them to Report Correctly

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One of the most popular segments of AIAG’s annual IMDS Conference is the OEM/Supplier Panel discussion. On September 26, 2018, at the Suburban Collection Showcase in Novi, Michigan, a robust panel of experts took live questions in an open-mic session on data quality and other challenges the industry faces in complying with IMDS and product chemical reporting requirements.

Here are a few highlights from the session.

  • Why isn’t Prop65 part of IMDS? Ford Motor Company’s global material management program manager, Bing Xu, said Prop65 is part of IMDS, but just in a different way. He confirmed that another 20 Prop65 substances will be added in the next few months.
  • Why is GM’s restricted substance list different in GADSL versus IMDS? Kirankumar Jagatap, senior performance engineering for product chemical regulatory compliance at General Motors, said that the only difference is in six substances, but there are no major differences.
  • Is GADSL a compliance list? Acknowledging that GADSL is “sometimes slow,” Ford’s Xu said that it is not a compliance list, but rather, more of a reference list. “You can’t assume that if you meet GADSL then you’re all set,” he said. “We are trying to improve GADSL.”

Timo Unger, manager, environmental affairs for Hyundai Motor Europe Technical Center GmbH, added that the updating period is a “compromise between workloads and compliance.”

The OEM panel turned the tables and asked the audience how many times a year they would like to see GADSL updated. The general consensus was two to three times a year.

  • What are the panel’s thoughts on artificial intelligence and blockchain? There was agreement on the panel that AI and blockchain will have “a huge impact” on supply chain data management moving forward.

Chuck LePard, senior consultant, product engineering, manufacturing, compliance, and sustainability for DXC Technology, pointed out that IMDS doesn’t address data exchange between two systems. “IMDS’s job is to keep supplier data confidential,” he said. “When all your data is in IMDS, there’s no need to talk between two systems. When anyone  participates in AI or blockchain, their personal data becomes public, and IMDS is concerned about that.”

  • How are OEMs approaching data management? Ford’s Xu said, “We’re focused on data management as it relates to current and coming regulations.”
  • How do OEMs check for prohibited substances that make it on to the vehicles and what are the fines? Amanda Bishop, global compliance manager for Visteon Corporation, clarified that there are commercial and legal ramifications. “We are trying to exchange information up and down the supply chain for the purpose of complying with the law,” she said. “If we see a supplier declaring a prohibited substance, we appreciate that. We need to know the story around that part. If it’s being declared in good faith, there’s no consequence — but we do have to deal with it.”

Bishop added that if they find out about it later after the vehicles are sold, it causes a much bigger problem “because they all have to be tracked down.”

In response to a follow-up question from the audience regarding whether all this tracking and reporting is really working, the panel assured attendees that they are checking the vehicles to see if prohibited substances are getting into them or not. The bottom-line, said the panel: The expectation is that companies will comply.

“We scrutinize very carefully for substances — every single part,” said Jim Raymond, program manager — Product Chemical Management Group for Toyota Motor North America.

While some OEMs said they sometimes spot test a part at their own lab, Pam Carey, divisional product environmental coordinator for Molex Automotive Division, said they “look carefully at the suppliers’ tests and will frequently follow up.”

Hyundai’s Unger added, “We rely on our suppliers to do their reporting correctly. We do analyze our data and sometimes problems come up with IMDS when we do. The biggest problem is when data is not updated. It is the supplier’s contractual duty to keep their data updated.”

Ford’s Xu agreed. “We trust our suppliers and expect them to do things appropriately,” he said.

  • What about future changes in the reporting of electronics in IMDS? Unger said he is convinced that “the way electronics reporting is happening today will not be acceptable in the future. Electronics reporting is still on a very low level, and that’s why it has to change.”

“If you are supplying to an electronics company, follow the written recommendations, which means you have to have a dataset to draw upon,” said Visteon’s Bishop. “Cars are going to have more and more electronics. You need the data. You can’t just use your judgement, even if it is sound judgement.”

Carla Kalogeridis is a contributing writer to AIAG’s CR e-newsletter.