Tackling the electronic sector's biggest chemicals management challenges: Q&A with Michael Kirschner

Michael Kirschner speaking

In March, we took the opportunity to catch up with Michael Kirschner, President at Design Chain Associates LLC, about some of the biggest chemical management challenges facing companies in the electronics sector. 

You can hear Michael speak on day two of our upcoming virtual conference, Chemicals Management for Electronics Europe (7-8 July), where he'll be presenting on Proposition 65 and electronics. Places are still available, so make sure you secure yours today. 

Register for Chemicals Management for Electronics Europe today 

What do you regard as the three most significant chemical management challenges in the electronics sector?

1.  Knowing which chemicals are present in the products manufacturers produce, where these substances are in those products, and their purpose. 

2.  Many manufacturers still do not know how and when to use such information when they get it from their supply chain (on top of simply knowing how to obtain it!)

3.  Staying on top of – and ahead of – the regulatory and customer-demand juggernaut. Many in the industry do not yet take the environmental and human health safety aspects of their products as seriously as is necessary. The electronics industry can’t compete with Echa. The level and amount of chemicals management and toxicology expertise based in the industry is generally concentrated in a few companies and, overall, is wholly inadequate given the regulatory nature of the environmental and human health safety requirements it faces. In a way, the industry is very lucky that enforcement in markets around the world has been so lax and that most markets that have implemented regulatory requirements have been more or less consistent with the EU’s implementations.

How might those involved in the electronics sector meet those challenges?

1.  Do a better job of integrating environmental and chemical-related requirements into the product lifecycle process. This is no less important than safety, electromagnetic and radio frequency (RF) compliance and has the potential to damage ill-considered business models.

2.  Bring on more chemical and toxicological expertise. Regulators are trying to tell us that we are not addressing the chemical issues in the way that we should be, and they are trying to force us to do so.

Looking beyond 2020, what do you think is the biggest issue on the horizon for chemical management in the electronics sector?

electronics waste

In the near-mid term, dealing with Echa’s Scip (substances of concern in products) database. Beyond that, the long-term implications of the database and the push for a circular economy, of which Scip is an aspect, will be our major issues. Scip’s purpose is to inform the Commission about where substances of concern are located so they can determine proper regulatory requirements. This could lead to challenges manufacturers are not prepared for.

What are the biggest challenges for companies in the electronics sector that need to comply with Prop 65?

Primarily understanding what the regulation requires and having the toxicological expertise available to understand when and why to label. It is unlike any other chemical-related product regulation the industry has to address, and that leads to all kinds of bad assumptions. There’s an incredible amount of misinformation out there, from suppliers, software vendors and others. While quite a few electronics industry manufacturers have felt its wrath over the past couple of decades and now understand how to deal with it, it’s still a minefield that many remain unprepared for.

Why are you looking forward to attending Chemicals Management for Electronics Europe 2020?

It’s always such a great and interesting conference! I love hearing directly from regulators, manufacturers and others and having access to them during the conference, as well as seeing, talking to and otherwise hanging out with my colleagues, friends, clients and others.

Register for your place at Chemicals Management for Electronics Europe 2020 today: