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ERA's Environmental Compliance Management Blog

Making the GADSL List: Hazardous Chemical Inventory Update

Posted by Alex Chamberlain

Alex Chamberlain is a writer for ERA Environmental Management Solutions.

Chemical Inventory System for GADSL The Global Automotive Declarable Substance List (GADSL) is a voluntary, automotive-specific, environmental reporting program that provides a framework for automotive manufacturers to report on their use of potentially hazardous substances.

The strength of the GADSL is that it can be used by any automotive manufacturer looking to improve their environmental reporting, anywhere around the world.

It’s the closest thing the automotive industry has to a standardized approach to EH&S reporting, which is proving to be vitally important to big-name manufacturers that have facilities in many countries around the world, but are using a single chemical inventory management system.

The list of hazardous substances is comprehensive, constantly growing, and infinitely useful.

But what substances are put on the GADSL’s watch list, and how are these decisions made?

Making the Cut

Here’s how it works:

GADSL is all about reducing and reporting consumer contact with hazardous chemicals. GADSL only covers substances that are expected to be found in the materials and parts that remain as part of the vehicle or auto part at the point of sale.

If a substance is anticipated to remain within a vehicle or car port once it enters the public domain, it will be included in the GADSL if:

  • It is regulated or projected to be regulated by any governmental agency or authority
  • The substance is proven, through testing, to possibly pose a significant risk to human health and/or to the environment if it is present in a finished material.

A substance could also be included in GADSL if it presence in a vehicle’s design could result in a functional problem, if it exceeds a level shown to be problematic by an international industry standard test.

When a substance gets added to GADSL, it is assigned one of 3 reason codes.

1. FA (For Assessment)

A substance that was projected to be regulated by government agencies, and so was added by the Global Automotive (GASG) Stakeholders Group Steering Committee.

2. FI (For Information)

A substance that has been added to GADSL for tracking purposes only, determined by the GASG.

3. LR (Legally Required)

A substance added to GADSL because its use in vehicles or parts poses a significant risk to human health and/or the environment. The substance may be legally regulated by one or more federal governments to be classified LR. Even if your country of operations does not regulate a particular LR substance, you will need to include it in your own GADSL report – that is, after all, what makes GADSL a globally-useful reporting program.

Once a substance has been added to the list, it is either classified as Prohibited or Declarable.

Prohibited materials (marked with a P) are either completely prohibited for use in certain applications or may be prohibited according to regulated threshold limits.

Declarable materials (marked with a D) must be included in your GADSL report if they exceed their reporting threshold. When determining these reporting thresholds, the GASG group generally uses the strictest regulatory threshold in use by any of its associated federal governing agencies.

If no declaration threshold is indicated in the GADSL documentation, you should assume a reporting threshold of 0.1%.

GADSL At Work

Let’s take a closer look at some of these GADSL entries:

GADSL treatments for Asbestos

As seen above, Asbestos Fibres are Prohibited, for Legally Required reasons. It has no threshold, as any intentionally added content is not allowed.

Asbestos Minerals, however, are only Declarable, For Information purposes. It has no minimum reporting threshold, as any amount of the substance should be reported under GADSL.

GADSL treatment for Benzene

In this second example, Benzene is considered both prohibited and declarable, depending on how it is used. Normally, benzene is considered prohibited at a concentration threshold of 0.01%. However, when it is used as an additive in fuels, it is declarable once it exceeds a threshold of 0.1%.

It is also worth noting that the different treatments of benzene are included in GADSL for different reason codes.

Currently, GADSL covers 94 substances, though many substances have more than one treatment.

You can learn more about GADSL by reading our short introductory article here.

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ERA Environmental Alex

About the Author: Alex Chamberlain is a writer and blogger who regularly contributes to ERA Environmental Management Solutions' blog. You can find Alex on Google+LinkedIn & ERA's Environmental Compliance Blog

(Image credit: Peretzpup)