Factory Compliance and Testing: What Should Keep Me Awake at Night?

Transcription

1 Factory Compliance and Testing: What Should Keep Me Awake at Night? Ben DeVito October 22, 2013 TÜV SÜD & Retail Services TÜV SÜD Product Services

2 Our heritage: 147 years of Safety Est Establishment of a Mannheim-based steam boiler inspection association by 21 operators and owners of steam boilers, with the objective of protecting people, the planet and property against the risk emanating from a new and largely unknown form of technology First vehicle periodic technical inspection (PTI) 1926 Introduction of the TÜV mark / stamp in Germany 1958 Development of a Bavaria-wide network of vehicle inspection centres in the late 1950s 1990s Conglomeration of TÜVs from the southern part of Germany to form TÜV SÜD and the expansion of business operations into Asia 2006 Expansion of services in ASEAN by acquiring Singapore-based PSB Group 2009 Launch of Turkey-wide vehicle inspection by TÜVTURK Today TÜV SÜD & Retail Services TÜV SÜD pursues a strategy of international growth

3 TÜV SÜD in numbers: Growing Through Safety 1 One-stop technical solution provider 150 years of experience 800 locations worldwide 1,900 19,000 million Euro in sales revenue 2012 employees worldwide TÜV SÜD & Retail Services

4 Your Global Partner You get to do what you do best, and so do we. Initially considered for our pricing and capabilities, but retained as a partner for our service and collaboration. Testing Inspection Auditing Programs

5 What Should Not Have Kept You Awake Did You Know. The USA Government (partial Shutdown) Federal Government Spending was just 17% under 2014 plan and just 13% less than last year! Federal Government spending during the partial shutdown was greater than when President Obama took Office! Slide 5

6 Factory Compliance and Testing: What Should Keep Me Awake at Night? What a Year 2 Factory Compliance 3 Testing 4 What s Next? Slide 6

7 Factory Compliance; What Should Keep Me Awake at Night? In 2013, You faced issues on many fronts Compliance Testing Is it possible and for that matter practical to prepare for and comply with all that is regulated and required? Slide 7

8 Factory Compliance; What Should Keep Me Awake at Night? What a Year 2 Factory Compliance 3 Testing 4 What s Next? Slide 8

9 Factory Compliance; What Should Keep Me Awake at Night? In 2013, There is no doubt, compliance news was dominated by the multiple tragedies in Bangladesh October 8 Aswad Knit Composite Mills Ltd -Fire April 24 Rana Plaza Building Collapse November 24, 2012 Tarzeen - Fire Slide 9

10 Factory Compliance; What Should Keep Me Awake at Night? WRAP Worldwide Responsible Accredited Production Arlington, USA ETI Ethical Trading Initiative London, UK Code of Conduct audits SA8000 Social Accountability International (SAI) New York, USA BSCI Business Social Compliance Initiative Brussels, Belgium Europe Slide 10 TÜV SÜD 22 October 2013

11 Factory Compliance; What Should Keep Me Awake at Night? Industry Has Reacted Accord on Fire and Building Safety Mostly European Brands Nearly 1,600 factories in Bangladesh Alliance for Bangladesh Worker Safety Mostly North American Brands Nearly 620 factories. Slide 11

12 Factory Compliance; What Should Keep Me Awake at Night? Child Labor and Trafficking - Child labor (Uzbekistan Cotton) - Ca. SB Dodd-Frank (Conflict Minerals) Slide 12

13 Factory Compliance; What Should Keep Me Awake at Night? Trafficking; 1. An estimated 27 million children, women and men are caught in the cycle of trafficking 2. Every minute, two children are sold into slavery 3. The average cost of a slave is $90 4. The average age of entry into the exploitation industry is 12 years old 5. Approximately 80% of trafficking victims are women, and up to 50% are children 6. Total yearly profits generated by human trafficking is $32 billion Slide 13

14 Factory Compliance; What Should Keep Me Awake at Night? California Transparency in Supply Chains Act of 2010 (SB 657) Signed into law by Governor Arnold in September of 2010 It is a disclosure law Companies that meet certain threshold requirements must disclose their efforts to rid their supply chain of human trafficking and slavery. (There are a number of generic disclosure statements that are available) The goal is to provide California consumers with information so they can make informed purchasing decisions Slide 14

15 Factory Compliance; What Should Keep Me Awake at Night? Dodd Frank Wall Street Reform and Consumer Protection Act (commonly referred to as Dodd-Frank) Signed into law on July 21, 2010 and the Final Rule adopted by the Securities and Exchange Commission (SEC) on August 22, The SEC Final Rule applies to all products manufactured on or after Jan 31, The first report is due to the SEC by May 31, Section 1502 deals with Conflict Minerals This law will affect many Publicly Traded Companies in the USA as well as those who supply them. Slide 15

16 Factory Compliance; What Should Keep Me Awake at Night? What are the goals of your C of C or Social Compliance Efforts? Keep my name out of the papers Protect the Brand What these phrases have in common is the focus is on us. If you worked in a garment or footwear factory what would keep you awake at night? Slide 16

17 Testing; What Should Keep Me Awake at Night? What a Year 2 Factory Compliance 3 Testing 4 What s Next Slide 17

18 Testing; What Should Keep Me Awake at Night? Historically, we have tested; Regulated Testing Flammability Care/ Content Content Drawstrings Performance (Slip resistance, heel attachment, heel impact) Physical (including use and abuse) Chemical Such as ph Formaldehyde, Azo Dyes Slide 18

19 Testing; What Should Keep Me Awake at Night? CPSIA Testing and Certification Rule (Mandatory as of Feb 8, 2013) Testing and Certification Rule (Mandatory as of Feb, 2013) Certificates - CPC (Children s Product Certificate i.e. GCC ) Production/Periodic Test Plan sample selection process and test interval Failure Response- and remedial action plan Material Changes (product specifications and BOM) - Recertification Undo Influence need a corporate policy and training Record keeping 5years, including test reports/available to the CPSC within 48 hours Standard - High Degree of Assurance pretty sure that each unit produced is in compliance Slide 19

20 Testing; What Should Keep Me Awake at Night? Component Part Testing Rule (Voluntary), does not require the use of CPSC accepted labs: Identification of component - Lot/Batch Number Traceability of component to final product Appropriate CPSC testing rule Identification of test methods and sample protocols Dates when component part was tested Component part test certificate and test reports Traceability Attestations o the supplier and IOR must attest they did nothing to compromise continued compliance with standards (Comingling) o The lab has to attest we followed required CPSC test procedures, incorporated into the report. Standard Due Care Slide 20

21 Testing; What Should Keep Me Awake at Night? Proposed Rule published in United States Federal Register on May 13, 2013 Proposed changes do not amend rules for testing and certification, but rather increase and/or modify the requirements for reporting and submission of the Certificates. Who Must Issue Certificate Additional Information Required on the Certificate Production Information - Place of Production, street address/ City/ City The factory name may also be required Attestation I hereby certify that the finished product(s) or component part(s) covered by this certificate comply with the rules, bans, standards, and regulations stated herein, and that the information in this certificate is true and accurate to the best of my knowledge, information and belief. I understand and acknowledge that it is a United States federal crime to knowingly and willfully make any materially false, fictitious, or fraudulent statements, representations, or omissions, on this certificate. Certificates may be required for those tests that are currently exempted from testing Flammability Lead in Textile textiles have been exempted from lead testing, a certificate must still be issued claiming the reason for the exemption. Slide 21

22 Testing; What Should Keep Me Awake at Night? Are you ready for real globalization and the international testing requirements? RSL / Green Chemistry / Sustainability GB Testing for China INMETRO for Brazil EU Other International Requirements Slide 22

23 Testing; What Should Keep Me Awake at Night? China - Did You Know? In about 2 decades, 1 in 8 people on the planet will be living in a Chinese City 8.7 in 2033 billion people 1,087,500,000 in a Chinese City That a lot of feet! There are currently 200 cities in China with populations over 1,000,000 Slide 23

24 What s Next?; What Should Keep Me Awake at Night? What a Year 2 Factory Compliance 3 Testing 4 What s Next Slide 24

25 What s Next?; What Should Keep Me Awake at Night? Who knows; but some things are predictable and under our control. we will continue to react to tragedies there will always be Ca. Prop 65 notices New regulations from the CPSC Increasing competition and globalization More emphasis on sustainability and chemical testing Slide 25

26 What s Next?; What Should Keep Me Awake at Night? Our goal is for nothing to keep you awake at night The industry is reacting Your lab partners are adapting So you can anticipate, prioritize and plan Slide 26

27 What s Next?; What Should Keep Me Awake at Night? Slide 27

28 Thank you! Your TÜV SÜD & Retail Team Contacts: Manny Robles Global Sales Manager Mobile Ben DeVito Technical Manager Mobile TÜV SÜD & Retail Services