New Trend: Fidget Spinners
What EHS legal requirements does a fidget spinner manufacturer need to comply with?
Well, this question alone can be broken down into several further questions:
What EHS regulatory requirements will impact the fidget spinner as a Product?
- At the design stage?
- What chemicals or other component ingredients can (or should) we use?
- Which substances can I definitely NOT use (now or in the future)?
- What will happen to the product when it reaches the end of its useful life?
- At the market stage?
- What labels do I need to put on my packaging?
- Will there be any import restrictions?
- At the end-of-life stage?
- Do I have extended producer responsibility obligations on this product?
- Can it be recycled?
Given that the fidget spinner is probably sold in X number of countries, you can multiply these questions by a factor of X. However, it doesn’t stop there…
- What EHS obligations will apply to the factory Operations where the fidgetpinners are made?
- What are my environmental legal obligations?
- Which air emissions restrictions apply to my manufacturing site?
- What are my wastewater dischargers limitations?
- What obligations do we have to manage hazardous waste generated?
- What environmental fees and taxes do we need to pay?
- Do we have the right, valid, permits?
- Where is my site location?
- What are my regulatory requirements regarding health & safety of my employees?
- What are the employee permissible exposure limits (PELs)?
- Do I need to provide personal protective equipment (PPE)?
- What are the restrictions on youth/minor workers in dangerous workplaces?
- What are the lockout/tagout and guarding requirements for machinery?
- If we carry out welding, cutting and hot work activities at the facility, what precautions do I need to take?
- If something does go wrong, what are my injury and illness reporting requirements?
Again, depending on how many factories your company has producing products around the world, these countries may also have regional or provincial legal obligations, the questions you need to ask for each product may swiftly increase in number.
The questions here are just a few examples, condensed to fit into this blog post! Everything that goes into making a product and getting it into the hands of a consumer must meet hundreds of jurisdiction-specific EHS requirements.
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