Tips to help gain full material declaration:
• Educate the supplier on why disclosure is necessary. For a number of banned or approved chemical lists, there's no minimum threshold for exemption of an ingredient. Also, a product often is built from blending multiple raw materials; the percentage of the same ingredient must be added if it appears in multiple raw materials.
• The product stewardship department must work together with the purchasing department to make the disclosure a condition of purchase.
• Commit to a nondisclosure agreement with the supplier.
• Allow a supplier to indicate certain ingredients are proprietary or trade secret and then to withhold specific identification, provided it discloses the hazards and regulatory status.
PILOTING AND PRODUCTION
During the pilot and initial production, a company must develop extensive labeling and safety documentation before market rollout. It's important that all hazardous and controlled materials are identified for proper labeling. Using centralized regulatory content, each set of individual regulatory documentation must be harmonized across all geographic locations to preserve product branding and corporate identity standards. To ensure the safety of workers, the firm must quickly and efficiently write health and safety documents in local languages.
Tips to ensure accurate local labeling:
• Consider local language idiosyncrasies so that critical health and safety warnings aren't lost in translation.
• Take a standardized, centralized and global approach to labeling.
Any launch requires supporting product documentation. With heightened demand for public safety and public awareness of potential exposure and consequences, product documentation has become increasingly complete -- ratcheting up the pressure on a company to provide accurate, detailed information about its products and their potential consequences. Many types of documents must be produced with country-specific requirements. A firm with global distribution channels must ensure regulations are met around the world prior to shipping.
"With operations that span Europe, South and North America, and Asia-Pacific, staying on top of changing regulations that differ between each of these regions was becoming quite a challenge to our team in terms of capacity," notes Dr. Sylvia Huber, head of material safety within the material compliance management department at Klüber, Munich, Germany. "For instance, in addition to the new regulations recently introduced in Europe, Asia-Pacific is currently issuing its own regulations and, in the future, will no longer accept safety sheets and labeling based on European regulations. This region now requires all companies to comply with [its] local version of GHS, and a similar request is expected from South America."
Tip for document accessibility:
• Enable customers, employees, authorities and transportation personnel to view and print safety documents anytime from any geographic location via a secure web site.
Most companies today are part of an extensive global supply chain spanning many industries and regions. The reality of such an interdependent environment is that a company's compliance status is greatly impacted by other members in its supply chain. Once a product is introduced, the ability to track products through all stages of the supply chain becomes paramount. The key to an effective traceability system is good communication and management between the successive links in the supply.
REACH legislation requires a manufacturer to understand the uses for its products so appropriate exposure scenarios can be developed. This makes communication with downstream users essential for grasping how and under what conditions products are being used. Over the next eight years as REACH becomes fully implemented, iterative communications will be needed both upstream and downstream.