Environmental Compliance 101: The Basics of MILL Test and Full Material Disclosure

Two key components of product compliance are the MILL test and full material disclosure (FMD). In this article, the basics of these two concepts and why they are important for businesses to understand will be covered.

What is a MILL Test?

A MILL test is a procedure used to assess the quality and traceability of metal products (like steel) throughout the manufacturing process. The test evaluates a variety of data including the product ID, chemical analysis at the elemental level, and mechanical properties. A MILL test aims to ensure that the alloy meets the necessary specifications and standards for its intended use. The test results are reported in the form of a MILL test report (MTR), or material test report, which summarizes the findings of the test and provides information on the material’s quality and characteristics.

What is Full Material Disclosure (FMD)?

A full material disclosure (FMD), or full material declaration, is a document that discloses the chemical composition of a product, including any hazardous substances. This is designed to provide transparency and allows companies to make informed decisions about the products they use and sell.

FMD reporting can be generated using various documentation such as a material safety data sheet (MSDS) or a regulatory data sheet (RDS). These documents provide detailed information about the composition of the product, including any hazardous substances that may be present.

Why are MILL Test and FMD Important for Businesses?

Benefits of MILL Test for Environmental Compliance

MILL tests provide several benefits for companies seeking to comply with environmental regulations and meet sustainability goals.

Ensuring accurate and complete FMDs: MILL tests help to ensure that the information included in FMDs is accurate and complete, which is crucial for demonstrating compliance with environmental regulations and standards. This can help companies avoid fines, penalties, and reputational damage associated with non-compliance.

Identifying potential risks: MILL tests can help companies identify and address potential risks associated with hazardous materials, such as those that harm human health or the environment. Companies can then reduce their environmental impact and ensure compliance with relevant regulations and standards.

Enhancing supply chain transparency: MILL testing can also promote supply chain transparency and ensure suppliers comply with relevant regulations and standards.

Examples of Successful MILL Test in FMD Processes for Environmental Compliance

Many companies have successfully implemented MILL tests in their FMD processes to achieve environmental compliance. For instance, a manufacturer uses MILL tests to verify the absence of hazardous substances in their products and ensure compliance with regulations such as EU REACH and RoHS. Another company could use MILL tests to identify the composition of materials used in their metal alloys and reduce the environmental impact of their manufacturing processes.

The following highlights useful standards or guidelines for MILL tests or FMDs:

Standard	Description
IPC 1752	This IPC standard for material declaration and data exchange in the electronics industry provides a framework for sharing information about materials used in products to support compliance with environmental regulations for products designed for harsh environments or with extended life requirements.
EN 10204	A European standard defining the types of inspection documents that can be issued for metallic products, including MILL test reports. Specifies the different types of inspection documents that can be issued to certify that the metallic products meet certain requirements.
ASTM A370	A standard test method that covers mechanical testing of steel products, including tensile testing, bending, and impact testing. Commonly used in the steel industry for MILL testing.
ASTM E8	Standard test method for tension testing of metallic materials, including both ferrous and nonferrous metals. Used to measure the material's mechanical properties, including yield strength, tensile strength, and elongation.
ASTM E18	Standard test method for hardness testing of metallic materials. Commonly used in MILL testing to measure the hardness of metal products.
ISO 6892	An international standard that covers tensile testing of metallic materials. Provides guidelines for specimen preparation, testing procedures, and the calculation of mechanical properties.

Benefits of FMDs for Environmental Compliance

1. Meeting Environmental Regulations and Industry Standards:

First, full material disclosures help companies comply with environmental regulations and industry standards, which are becoming increasingly stringent. For instance, the European Union’s Restriction of Hazardous Substances (RoHS) directive restricts ten hazardous substances, such as lead and mercury, in electrical and electronic equipment. Additionally, it is worth noting that the family 6 RoHS Directive exemptions apply to lead-bearing metal alloys and must be considered when analyzing an FMD. By providing full material disclosures, companies can demonstrate compliance with these regulations and avoid penalties or legal action.

Other environmental regulations to pay attention to include:

Registration, Evaluation, Authorization, and Restriction of Chemicals Substances of Very High Concern (REACH SVHC)
Registration, Evaluation, Authorization, and Restriction of Chemicals Annex XVII (REACH Annex XVII)
California Proposition 65 ( Prop 65)
Persistent Organic Pollutants (POP-Halogen free)
Toxic Substances Control Act – Persistent Bioaccumulative, and Toxic (TSCA-PBT)
Waste Electrical and Electronic Equipment (WEEE) Directive

2. Keeping Up with Changing Regulations and Standards:

Second, by requiring full material disclosures, companies can track the composition of every material used in their products. This information allows for greater transparency and accountability in the supply chain, as companies can identify potential risks, such as the use of conflict minerals or hazardous chemicals, and take necessary steps to mitigate those risks.

3. Reduced Environmental Impacts:

Third, FMDs enable companies to identify opportunities to reduce the environmental impacts of their products. For example, a company that produces packaging materials can use full material disclosures to determine if any environmentally harmful chemicals are used. If so, one can find alternative, more sustainable materials. This reduces waste, lowers greenhouse gas emissions, and has a smaller environmental footprint.

4. Improved Product Design and Innovation:

Fourth, full material disclosures provide companies with valuable information on the composition and properties of materials used in their products, allowing them to make more informed decisions about product design and innovation. For instance, a company that produces consumer electronics can use full material disclosures to identify more sustainable materials for its products, leading to innovations in the design of more environmentally friendly products.

5. Cost Savings through Optimized Material Use and Waste Reduction:

Finally, FMDs can help companies optimize their material use, reducing waste and resulting in cost savings. For example, a company that produces textiles can use full material disclosures to identify the most efficient ways to use materials, leading to less waste and more efficient production processes. This can result in lower production costs and increased profits for the company.

Challenges of Full Material Disclosures for Environmental Compliance

Gathering Accurate and Comprehensive Data for Full Material Disclosures:

Indeed, one of the biggest challenges of implementing full material disclosures for environmental compliance is the collection of accurate and comprehensive data from suppliers. In fact, it often requires communication with multiple suppliers and gathering data from different sources. Additionally, some suppliers may not have the necessary data or may be hesitant to share it.

Also, environmental regulations and industry standards are constantly evolving, making it challenging for businesses to keep up with the latest requirements and ensure their compliance efforts are up to date. This requires ongoing monitoring and adjustment of compliance programs, which can be time-consuming and resource intensive.

Moreover, another issue is that some FMDs are at the atom level instead of the molecular level. This prevents the detection of restricted molecules such as PFAS. As a result, some FMDs list general CAS numbers. However, they fail to mention derivatives of the restricted chemical which have different CAS numbers. For example, lead has the CAS number 1739-92-1, but lead monoxide, a derivative of lead, has the CAS number 1317-38-8. This prevents the detection of a lead-containing compound which is restricted by many regulations. This can be the case for many regulated chemicals. Thus, being vigilant is crucial.

Need Assistance with this process? Let Enviropass’ dedicated team of experts help by scheduling your free consultation.

Ensuring Data Confidentiality and Intellectual Property Protection:

Some suppliers may have undisclosed secret recipes within their full material disclosure. This hinders the compliance process since the undisclosed chemicals could contain restricted substances.

Furthermore, another challenge is protecting the confidentiality of supplier data and intellectual property. Suppliers may be reluctant to disclose certain information, such as proprietary formulations, for fear of it being shared with competitors or becoming public knowledge.

Dealing with Supplier Resistance and Lack of Cooperation:

Additionally, some suppliers may resist the implementation of full material disclosures, either due to concerns about confidentiality or because they do not have the necessary resources or expertise to provide the requested data. This can create a challenge for businesses looking to comply with environmental regulations and industry standards.

Managing and Verifying Large Amounts of Data:

Moreover, FMD can generate a large amount of data, which can be difficult to manage and verify. This can lead to errors, inconsistencies, and data quality issues that can impact compliance efforts and overall supply chain performance To circumvent this risk, a BOM management / Product Lifecycle Management (PLM) software can be used. For example, electronic companies can use the free ChemSHERPA software to perform due diligence practices. Alternatively, the automotive industry can also use an International Material Data System (IMDS) to simplify compliance with regulations such as the End-of-Life Vehicle (ELV) Directive.

To learn more about how your company can implement a MILL test or a full material disclosure to comply with environmental regulations, contact Enviropass!

Our team of experts can help you navigate the complexities of MILL tests and FMDs and develop a customized compliance program to meet your specific needs.

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