Compliance: Put Success Within REACH

Effectively meeting the mandate requires a new approach to environmental compliance management.

By Sebastian Pleister, SI PRO

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New product development and introduction (NPDI) is another area that needs to be considered. It’s here that the composition of a product is determined. EH&S often isn’t integrated into this process enough. Frequently environmental compliance isn’t checked until after a product has been developed or even sold. Furthermore, NPDI information systems, often part of product lifecycle management (PLM) systems, are separate systems and don’t interface with EH&S systems.

Along the supply chain, customers, vendors and other business partners usually don’t share information about environmental compliance apart from receiving and sending material safety data sheets (MSDSs). With REACH the activities of supply chain partners become extremely important for achieving compliance. This, in turn, requires more open and proactive communication.

The following recommendations are starting points for a more integrated approach to ECM and more efficiently adapting to REACH:

Integrate environmental compliance into supply chain management (SCM) and NPDI organizations and processes. A company must change its approach to chemical compliance and needs to think across all operations. It must embed ECM into supply chain organization and activities. Processes need built-in compliance.

The goal is to check and track the registration status of substances and their respective volumes through all planning and execution phases of the supply chain. For example, a firm must keep tabs on long- and midterm planned quantities against registered substance quantities, sellers must consider whether potential sales volumes are within the REACH limits, and purchasing must ensure the registration status is okay for all items to be bought. Likewise, environmental compliance must be part of every design decision during NPDI.

Increase supply chain visibility. Activities of its business partners are essential for a company to become and, more importantly, stay REACH compliant. So, supply chain communication is a major part of REACH registration activities. To maintain REACH compliance, this communication must become part of regular business communication. The gathered information must be visible within the company and throughout the supply chain.

Every step of the value chain requires ready access to the following information (Figure 1):

• What is the substance composition?
• Who are the business partners?
• What is the registration status for each material?
• How is the substance being used (usage scenario)?
• What is the exposure of users (exposure scenario)?

Provide an adequate REACH IT infrastructure. Environmental compliance only can be efficiently integrated into SCM and NPDI processes if EH&S information and compliance checks are available in logistics execution and PLM systems. Furthermore, the company must have automatic accessibility to REACH compliance information from its supply chain.

Implementation of this new approach to environmental compliance will help firms cope with REACH and existing chemical regulations and also will prepare companies for future regulations. Figure 2 summarizes the benefits of this approach.

The Importance of IT
IT is one of the determining success factors of every REACH initiative. REACH-specific IT requirements range from the use of third-party systems to collect data, register or collaborate, to requirements for internal systems to identify substances and their quantities, execute multiple registration projects in parallel, and enable collaboration internally and externally.

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