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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The most prominent third-party tool is IUCLID 5, which is provided by ECHA. IUCLID 5 is used to collect data points and generate registration dossiers. SIEFreach is an IT system initiated by CEFIC (the European Chemical Industry Council, Brussels) for collaboration in substance information exchange forums (SIEF). Other tools, e.g., to generate exposure scenarios, carry out chemical safety assessments and produce chemical safety reports, are under development.

However, many companies are still struggling with a bigger issue: How to internally manage REACH registration and ongoing REACH compliance?

So far, most organizations have relied upon quick fixes and a lot of manual data manipulation to get started and meet initial due dates. Several IT systems are available that promise to address REACH compliance on a stand-alone basis or as part of an isolated EH&S package. The downside to many of these solutions is that data must be (semi-)manually fed into the system and no access to actual transactions in ERP systems is available. While such solutions can help companies get started or may suit organizations with very limited exposure to the EU market, they aren’t a long-term solution for any larger company taking environmental compliance seriously.

The new approach to ECM must trigger a re-evaluation of the role of EH&S information systems. Frequently, these have been seen as isolated systems to support a very specialized “exotic” corporate function. Companies have implemented few, if any, interfaces, e.g., for MSDS shipments or dangerous goods declarations on transport documents.

With the ever increasing importance of environmental compliance, organizations should view EH&S functionality as one of the core business IT functions. The goal must be to implement an environmental compliance solution that’s fully integrated into the existing ERP landscape. Such a holistic approach enables compliance objectives to be considered on a transactional level, e.g., with substance volume tracking or online compliance checks, and on a planning/strategic level with adequate business intelligence and planning functionality. At SI PRO, our approach is based on SAP.

An integrated IT architecture for environmental compliance should have a number of critical characteristics, such as:

• It must be based on an integrated compliance data model that has a comprehensive data structure that can be easily enhanced and links EH&S data objects to logistical and PLM data objects like products, vendors, clients, sales orders, recipes, formulas, etc.

• There also must be access to standard PLM and logistical functions, e.g., to generate data, evaluate transactions or block processing. An example is substance volume tracking functionality that aggregates manufactured and imported quantities from production and purchasing orders.

• A central compliance check engineis needed as a central repository for compliance rules with predefined integration points into logistical processes to execute compliance checks and access logistical and EH&S master data.

• Additional features like project management with integration into accounting or document management can expedite compliance management and, especially, REACH registration. Furthermore, standard tools can foster internal and external collaboration and supply chain communication.

The Right Way Forward
The time and effort to execute such an integrated IT architecture for environmental compliance, of course, exceed those for a quick-fix stand-alone system. Furthermore, implementation can only be achieved with a step-by-step approach. But opportunities to increase environmental compliance and to automate transactional ECM tasks definitely are worth the time and effort. In addition, an integrated compliance management solution will dramatically reduce the pain of adopting future environmental compliance regulations.



Sebastian Pleister is an associate of SI PRO Consulting, which is based in Boston, Mass., and Mannheim Germany. E-mail him at sebastian.pleister@si-pro.com.

 

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