The foundation of REACH (Registration, Evaluation, and Authorization and Restriction of Chemicals) is knowing which chemicals are present in your facility and in your final products.
Seems straightforward enough, but the reality is that manufacturers typically purchase a large variety of (potentially changing) chemical materials all the time. It makes keeping up with your chemical inventory difficult.
REACH bans certain chemicals, known as Substances of Very High Concern (SVHC) from being in any product exported to the European Union. To (over)simplify it, REACH compliance is all about locating SVHCs and removing them from your processes & products.
Removing SVHCs can be a challenge in itself but the very first step is locating the chemicals in your own facility.
A Systems Approach to Chemical Tracking
The most effective EH&S managers are those that understand how their facility works as a whole and can chart out the different systems in place that interlock to build their business.
Tracking chemicals as they enter your facility and get used throughout your facility is about understanding the systems at work in your chemical inventory & chemical processing management.
The best technique for improving these systems is to make them transparent and accessible: in most cases this means applying three basic principles:
- Centralize – put all your data about the system in one place. This improves access to information and highlights how data points are interrelated.
- Digitize – during the centralization process, convert any paper documents into a digital format. This allows for easier searching of SVHC and general data management.
- Automate data processing – once data exists in a digital format, you can implement programs that automatically search for SVHCs and other chemicals on demand and at fixed times.
It’s worth noting that the type of automation described in brief above is just one type of automation that can be programmed for your chemical database. Automation can also include crunching the numbers to do your VOC emission reports or vet incoming materials.
Prioritizing Chemical Data
Looking at those three basic principles of taking a systematic approach to chemical tracking for REACH compliance, it’s important to keep in mind that the data being collected and stored is complex chemical data. For whatever type of system you choose to implement or build as part of your REACH compliance, make sure to prioritize the ability to store and track complex chemical data – this means a free spreadsheet software probably won’t cut it.
Look for a system that can track more in-depth data points, like default chemical states for example. Even if not all of this information is needed for REACH compliance, it will be useful for other environmental reports. If you’re taking the time and resources to improve your system, it’s worth making it useful for more tasks than just REACH compliance.
Communication is Key
Being able to track chemicals as they enter your facility and get used in processes is only half the battle. Making sure that data is effectively communicated is also essential for proper chemical inventory management and for REACH compliance.
Having located SVHCs and other undesired chemicals in your site, the next step is to communicate this information with the person(s) in charge of chemical purchasing and regulatory compliance.
Depending on your organizational structure, you might be responsible for chemical inventory management and purchasing, or you might be a member of a large EH&S team that needs to bring SVHCs to the attention of executives.
Although no two organizations are the same, there is a basic blueprint for chemical data communication. The more of this blueprint you are able to implement, the easier compliance with REACH, or really any regulation, will be:
- A database with built-in reporting. Use a centralized digital database capable of producing reports on chemical data. Look for a solution that lets you filter your database to show all criteria chemicals and products, identify where they come from and where they are used, and export this data.
In-depth reports will also be needed if you ever decide to apply to have any SVHCs authorized for use in your products. Authorization can be applied for if there are no reasonable chemical alternatives available and the EU believes it makes economic sense. Authorization is a time-consuming process that will require in-depth paperwork & reports.
- Accessibility is key. Make this chemical database accessible to your entire EH&S team and executives, but use secure log ins that track who views and edits data. This avoids having one person shouldered with being the Gatekeeper of Chemical Data and prevents data bottlenecks. You can even customize access to limit what employees see based on their authorization.
- Visualization and at a glance roll up. Even though built-in reporting is essential, most executives prefer to get at-a-glance roll ups of operational data presented in a more visual fashion. An executive dashboard is becoming a must-have feature for data communication up from your EH&S team to the C-level.
September 30, 2015