Substance of Concern (SoC)
1. Objective
This procedure set up for clarifies the regulation of control to eliminate the hazardous chemicals. As part of
preserving the global environment, reduce substance of concern (After that “Substance of Concern” was called
“SoC”) is necessary to realize.
2. Scope
This procedure applies to all parts and raw material which manufacturer distribute to T.RAD.
Control group of hazardous chemicals were as follows;
(1) Hazardous chemicals which T.RAD settle as follow the End of Life Vehicle (ELV) regulation, recycling
in the European Union and the WEEE and RoHS (Waste Electrical and Electronic Equipment Directive :WEEE
and Restriction of Hazardous Substances Directive: RoHS)
(2) Hazardous chemicals which customer of T.RAD settles in term of environmental management.
3. Definition
SoC (Substances of Concern) means substances that are environmental burden caused by industrial activities,
and other.
T.RAD Standard No.003-01-01A means standard of control SoC in T.RAD, list of SoC perform as
attachments.
So that, divide the list of chemical as group as below;
(1) Controlled substances: Six main types of controlled substances are controlled by ELV, RoHS such as cadmium, Hexa valencromium, lead, mercury PBB, PBDE, including the chemicals substance that refer from TS No.003-01-01A (Table #2).
(2) Other: Substance that is beside from controlled substances.
(3) Chemicals banned: T.RAD settle chemicals banned that is harmful the environment and the human body. The law prohibits the production etc.
(4) Chemicals monitoring: T.RAD settles chemicals monitoring that consider the social and technology
trends. Thereby, these chemicals are harmful to the environment and the human body. The law prohibits the production.
Revision 3 T.RAD (THAILAND) Section 10
Issued date 20-Feb-12 Page 1 of 10
4. Control the SOC in drawing
Part drawing, which specifies to control the SoC, should show the item of control SoC at remark. So that should specify T.RAD Standard No. 003-01-01A on drawing as example at the article 2 in the picture.
In addition to, the customer of T.RAD should specify the customer standard for each part on drawing too.
4. Standard Control of SOC
Standard score of control depend on rank A or B in TS No.0003-01-01A (Table#2), in order that, chemicals which are not specify to rank A or B, should used in rank A.
Rank A: use to the automotive industry group and the heavy machinery and construction group. Rank B: use to the appliances and electrical equipment and the electronic industry.
(Remarks)
・Substance is controlled by customer requirement, laws or beside from mentioned above and
chemicals substrate control, should clear specification the criterion score in drawing.
・Substrate value that is not apply intentionally contamination but objective intentionally contaminate
for processed, character, function of performance. No matter how much it is, these violate the ELV regulation.
・ELV regulation, there are some exceptions for substrate value, see also in Annex II ( List of
exception applies).
In order that, customer require for additional control as above the T.RAD’s standard. This should stand the control item of each customer. Then T.RAD should inform to manufacturer is case by case.
Revision 3 T.RAD (THAILAND) Section 10
Issued date 20-Feb-12 Page 2 of 10
5. Demonstration for Control of Hazardous Chemicals
Demonstrated by analysis data, furthermore, beware of this following when measurement and demonstration.
1) In case of, know how of mixture cannot be revealed, should inform T.RAD. The chemical examination data of target group still require.
2) The document has been approved from government or private enterprise credibility should specify the date, method and equipment of measurement, including detectable minimum value and clear result of measurement.
Even though the quantity of chemical mixture more than or less than the substrate, must specify clearly the
category is “intentional” or “not intentional”
3) In case of the same substance, even though how much is the thickness or width etc., should separate
analysis of each substance.
4) Owing to the accuracy of MSDS is not consistent with the proportion of contamination of threshold value in ELV regulation, so it is not consideration to be the certification of non-contamination.
5) Notice of determination (Analysis)
- In quantitative analysis, the resolution of measurement; if the threshold value equal 0.1, the detectable
minimum value must not more than 0.01.
- In qualitative analysis, could specify “have” or “not have” but reliability level of detectable minimum
value must concern.
6. General regulation to control SOC
6.1 Clarity of supply chain
6.1.1 List of procurement of all items (raw material, part, and support material) should clear the name
list as following;
- Raw material and part should specify product’s code, product’s name, product’s vender (in case of
merchandising, should specify the manufacturer).
- Support material should specify vender’s name, manufacturer’s name and product’s name
(product’s code)
6.1.2 Appoint the responsible personnel for control SoC of procurement (raw material, part and support
material)
In order to, procurement of raw material and part suspected to be direct or indirect contamination,
prohibit procurement and application until permission from responsible personnel.
6.2 Subcontractor control
Revision 3 T.RAD (THAILAND) Section 10
Issued date 20-Feb-12 Page 3 of 10
6.2.1Responsible personnel to control the SoC of subcontractor clarify the regulation for control the SoC
and operate strictly.
6.2.2 Production process survey of subcontractor or vender, should survey periodically the SoC control
system and at necessary time. The item for examination should follow this manual.
6.3 Production process control
6.3.1 When production process change such as settle a new production process, production method
change, production line change and the support material change etc., should consider carefully the mixture of
SoC and then assessment.
6.3.2 Daily monitoring in production process, should confirm the examination of SoC. Is it concern
dangerously?
6.3.3 Production standard is controlled by regard the non-contamination and prevention of SoC
contamination. Fill in the content of control system into production standard.
6.3.4 Unusual case management such as the contamination, SoC sticking and etc.
- Resolved immediately and strengthen the scope of the target group.
- If the defect of unusual case escape to T.RAD, should inform immediately and follow the instruction
of T.RAD.
7. Responsibility of Manufacturer
7.1 For new model, first order of part, and raw material from T.RAD or raw material change, should examine
and analyze the raw materials and support materials. Is it has the SoC in control list, which T.RAD settle? The
examined report should come from the government institute or private enterprise creditability. In order that, the
coating part or dipping part should separate the examination between before and after coat. Coating part should
examine only the appearance.
7.2 When manufacturer received the result of examination and analysis, the responsible personnel of control
SoC verify the result. The examination shows the result that is consistent with the criterion of T.RAD, conclude
into “Survey sheet of Environmental Impact Substances” (Form No.EF-QC-01-001) and then send to T.RAD for
approval.
In case of, the result show “not pass”, should inform immediately to T.RAD for improvement.
7.3 The examination of other controlled substances, as apart from above the six main type’s chemical, should
examine the chemical contamination that refers from T.RAD Standard No.003-01-01A. Examination of raw
material, support material and other that related with the part. Is the controlled substance contaminates the part?
And then verify the CAS No. from any place such as MSDS, Material Certificate, and original manufacturer.
Revision 3 T.RAD (THAILAND) Section 10
Issued date 20-Feb-12 Page 4 of 10
Then conclude into the form “Nonuse Declaration of Banned & Monitor Substances (Form No. EF-QC-01-002)
and specify “have” or “not have” which the list name of chemical use and then send to T.RAD for approval.
In case of the examination has the controlled chemical, manufacturer should inform immediately to
T.RAD for improvement.
8. Guidance for prepare the “Survey sheet of Environmental Impact Substances”
8.1 Form of “Survey sheet of Environmental Impact Substances (Form No. EF-QC-01-001)” as below;
8.2 Detail in the Survey sheet of Environmental Impact Substances
(1) Date issue is date of prepare the document.
(2) Company Name is name of manufacturing company.
(3) Name of answer section is name of the preparation section.
(4) TEL is a telephone number of responsible personnel.
(5) FAX is a facsimile number of responsible personnel.
(6) E-MAIL is an electronic mail (e-mail) of responsible personnel.
(7) Part No. is number of main part, shall be reference from drawing.
(8) Part Name is name of main part, shall be reference from drawing.
Revision 3 T.RAD (THAILAND) Section 10
Issued date 20-Feb-12 Page 5 of 10
(9) Part for is group of part, divide as below;
Group A is the group which use to automotive industry, heavy machinery and construction
industry (Automotive/Construction machinery/Motorcycles/Multi-purpose)
Group B is the group which use to appliance and electrical industry-electronic industry
(Electronic device / Consumer electronics)
(10) Weight (g) is the part’s weight, the unit is gram.
(11) Manufacture's name is the name of manufacturing place.
(12) Type of submission is the type of sending the investigation result, divide as follow;
New model is a new part which never sending to investigation.
Material change is a case of changing raw material.
Yearly confirm