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To coincide with the general release of SAP REACH Compliance 1.1, BPX has sponsored a recorded Webinar On-Demand of the first official solution demo. In the first demo unveiling of its kind on BPX, Dr. Marko Lange provides a step-by-step commentary as he presents the executive offline demo for SAP REACH Compliance.

 

The community has played a large part in the discussions around REACH and the associated application in recent months, so it’s quite fitting that the first application demo should be launched through BPX.

 

Running time is approximately one hour and the Webcast promises to clarify the impact of REACH on business processes, showing also how IT can help to manage compliance.

 

 

Central to the Webcast is Marko Lange’s description of the SAP REACH Compliance Process Flow, which I’ve paraphrased and reproduced below:

 

REACH Compliance Process Flow

Complementing IUCLID5 for the electronic submission of substance data and registration dossiers, SAP REACH Compliance facilitates management of all REACH-related activities.

 

  1. Assess materials/substances according to their REACH relevance.
  2. Determine communication needs, based on your initial assessment of REACH-relevant materials/subtances together with additional data from the logistics modules for purchasing and sales & distribution.
  3. Manage and document communications, supported by a process called Supply Chain Communication.
  4. The information generated through Supply Chain Communication (determined on substance/material level) is assigned to each substance/material and enriched by additonal substance-related REACH data.
  5. Begin registration processes, using this central store of substance/material data.

 

The business scenario covers management of:

  • Organizational data
  • REACH-relevant data for materials and substances
  • Each individual registration

 

  

 

Further Reading

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4 Comments

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  1. Anbazhagan Sam Venkatesan
    Dear Mr.Connor,
    It must be a landmark event to come up with the REACH compliance solution, indeed.

    But the one thought that is repeatedly coming to my mind and what I wonder  is that whether BPX could do more and help SAP customers to transcend mere compliance!
    That is where real challenge would be, I feel. This is purely based on certain related readings and of course my work experience in the area of safety and environment.

    For SAP who aim at excellence in all spheres, Perfect Plant being one such attempt, helping SAP customers with mere compliance would look like remaining somewhere in the

    middle of the 5-point scale of performance!
    Mere compliance as an aim, also appears a subject of yester years.
    Hence the suggestion, in order, that SAP customers do not lag behind but go beyond compliance, with help coming from BPX.

    In relation to chemical sector,keeping track of the work in SAICM (Strategic Approach to International Chemical Management), and/or associating with them right from the

    beginning ,as is done by ICMM,may be one way thereby the BPX community could provide support to SAP customers well in advance.
    In this connection, may please refer to an article “Finding a framework for sustainable chemicals management” by Ivor Kirman, President, Nickel Institute, in the ICMM

    Newsletter of February 2006 (www.icmm.com).

    It is said that a study undertaken by Booz, Allen & Hamilton in 1991 of top executives in the chemical industry in the US, revealed that the leading chemical companies believe

    that an integrated and holistic approach to the environment is required in order to incorporate it into the overall business strategy (Rushton,1993). This, in turn, requires the

    adoption of a proactive environmental strategy, as opposed to a passive or reactive strategy (Norcia et al.1993; Little,1991). This is equivalent to a shift from compliance to

    ‘excellence’ and ‘leading edge’
    In Roome’s strategic Options Model (Roome,1992) and Newman et al (1993), while a passive or a reactive strategy focuses on doing the minimum that is required by law, a

    proactive approach aims at moving beyond compliance, in order to gain an edge over competitors.
    – Corporate Strategy and the Environment: the Theory, Sangeeta Bhargava and Richard Welford
    In ‘Corporate Environmental Management’, Ed.Richard Welford,Universities Press,1996

    With regards.

    Anbazhagan

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    1. Kieran O'Connor Post author
      An excellent comment, Anbazhagan. Indeed REACH compliance is a reactive solution and, as you rightly say, we have the capacity to go beyond mere compliance.

      I would argue, however that compliance is also progressive to the point that it heightens awareness and opens the discussion on global initiatives such as SAICM.

      And the whole debate on waste – whether it reflects dealing with treatment and containment of hazardous by-products of the chemical industry or the mining and oil&gas industries’ large-scale management of toxins in tailings ponds – needs to be opened and analyzed through the community.

      In fairness, with compliance solutions we’re making a start. But, if we want to make the shift, as you say, to “excellence” or “leading edge”, then we need community-wide thought leadership on envioronmental health and saftey.

      I feel your experience and studies in this area would greatly benefit BPX.

      Would you care to take a lead in elaborating on the topics and help us to explore the challenges where business processes can be changed and IT solutions and infrastructures can support?

      I’ve just added a couple of links to support some of the references:

      Finding a framework for sustainable chemicals management” by Ivor Kirman (ICMM Newsletter February 2006 – go to page 8)

      Strategic Approach to International Chemical Management (SAICM)

      Toxic waste boils up from covered tailing ponds at N.W.T. mine sites (Canadian Broadcasting Corporation)

      Unconventional Oil – Scraping the Bottom of the Barrel (World Wildlife Fund)

      Looking forward to more contributions Anbazhagan.

      Regards,
      Kieran

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  2. Anbazhagan Sam Venkatesan
    Intro

    That is very encouraging.
    I would like to elaborate ‘Going Beyond Compliance’, in general.
    I would not like to elaborate on Going Beyond REACH right now!
    I would like to read all the related material and must take time.
    I would base my elaboration on my plant experience and other readings, for the present.
    It runs lengthy. It is generic.

    The wish is to elaborate and establish the reason for going beyond mere compliance in any area.
    Hope BPX community would bear with the length and the different tone!

    1
    True. Compliance is certainly a step in the path to progress.

    2
    It is very helpful to recognize that we can move beyond compliance.

    To elaborate and establish reason for going beyond compliance:
    For instance, compliance regarding water usage:
    In our situation, the State Pollution Control Board authorizes a company for use of water for industrial purposes.
    The authorization is called Water Consent.
    Apart from certain testing requirements, a cess is also levied on the quantum of water consumed.
    It was felt that because one is paying the cess, one can consume as much as one wants.
    It took a long time to realize that the SPCB is not levying the cess for revenue sake but to keep it as a deterrent for unreasonable consumption.
    Authorization to pay and use is not a license to waste.
    But since the amount paid as cess was not financially significant, it did not get noticed.
    But when water became a scarce resource at the location, realization dawned to institute conservation measures.
    In fact the cess was imposed by the authorities to inculcate conservation measures by the user.
    Thus the company moved beyond compliance only after feeling the pinch.
    To do it earlier, there was a need to understand the rationale behind the rule.

    3
    With respect to energy:
    In our country an Energy Conservation Bill was promulgated in the year 2000.
    It became an Act and then the related Rules were issued.
    A nodal agency was appointed to monitor the implementation of the Act.
    Industries had a grace period of 5 years to streamline their energy management and comply with the requirements.
    After the 5 year period, an energy Inspector would visit the premises to audit.

    In compliance mode, one would wait for the inspector to come.
    Some may wait till the Rules arrive.
    Some others may wait till the grace period expires.
    But those who have a tendency to go beyond compliance have started an Energy Management System to manage energy.
    As it is mentioned in the “In Pursuit of the Perfect Plant”, that EM is no different from QM;
    such companies did reap benefits early by going beyond compliance.
    They also were confident of putting a brave face to the inspector.

    4
    Ours was a plant making pellets from iron ore concentrate.
    Dust emanation was an environmental aspect.
    SPM (Suspended Particulate Matter) in air was an item to be monitored, in the premises as well as in the ambience – at certain periodicity, at certain places and tested as per a stipulated method.
    It was also an Occupational Health issue, to maintain the SPM at stipulated level.

    De-dusting equipment was in position.
    While the production equipment was members for condition monitoring and related maintenance, this was not;
    Whereas the production equipment was hooked on to the process control system, this was not, though provision existed.
    Compliance reports were sent diligently and even during the visit of the inspector everything was fine.

    It was after some effort through a Management System audit that we realized the need to treat the de-dusting equipment at par with production equipment.
    It was an eye opener as to how to see the compliance conditions and by going beyond it derive benefit for ourselves.

    5
    Why does a need for legislation arise, followed by Rules for compliance?
    The classic example is the crusade of Rachel Carson for legislation regarding use of pesticides.
    If we read her life story and her effort, we certainly would not wait for an enforcing authority to come to our premises and tell us what to do with respect to environment.
    We will align with the rationale with which she fought to bring up the legislation and that would be the guide for our action.
    Compliance would be incidental.

    6
    During the yester years, the enforcement officials were literate, educated and concerned.
    Workers and managers and owners were illiterate, uneducated and considered as not bothered about the subject, except about production.
    But presently we all are not only literate, but also educated and concerned.
    Hence we can see the reason for any legislation and go beyond compliance.

    7
    Working at the level of compliance has the risk of sliding down to non-compliance over a period of time.
    Working beyond compliance would save us and even if we slide down, we would be at the compliance level.

    8
    In some cases bringing in the legislation itself takes time in consultations, clarifications and managing oppositions.
    Take for instance the time taken to formulate REACH itself. Keeping in view its scope and reach it would have been necessary. The point to note is that it takes time.
    One more example is the time taken by ISO to come up with a standard for CSR.
    And after the legislation or publication of the standard, to bring companies to compliance mode would be an ‘effort’.
    The legislation in regard to the Differently Able Persons is a case in point. A review of the fulfillment would show how long it takes to reach a compliance level.
    As things are becoming urgent, going beyond compliance would save companies from facing any hurdle in the future.

    9
    If we read what is in small print, listen to what is told in the corridors too and
    implement them, we would remain one step ahead of the enforcement official!
    For example, if we read the ISO 14001:2000 standard, it has a small note that companies may implement OH&S system also along with this standard; but it would be outside the scope of certification under ISO 14001:2000 standard. In spite of that if one implemented a management system for OH&S they go beyond merely fulfilling the requirements of the standard.
    One has to humbly be a futurist to go beyond compliance.

    10
    Any visit by a person from any Inspectorate is a day of tension to the Corporate Head and the Plant Head.
    But if we are known for our Going Beyond Compliance stance, such visits would prove interactive and mutually beneficial.
    Such a state of affair would relieve all concerned of an anxiety and the time would be spent fruitfully otherwise, with head firmly on the shoulder!
    It is said that the labour practices of Tatas in India was so exemplary that it formed as a model for the Factories Act formulated by the State, long ago.
    It still works.

    11
    The tendency to go beyond compliance by a company in the developing world also helps, in these days of globalization, to align with the best practices of the well matured company.
    We, as a mining company, attempted to adopt the ICMM Principles in addition to complying with national rules, so that in case the company was taken over by companies such as Rio-Tinto or BHP Billiton, who are subscribers to the ICMM Principles, we would not see stars if we were asked by them to adopt to these Principles!

    12
    Compliance sometimes is different from truth. And at some later point of time, truth prevails. For such companies, if they move beyond compliance, it would be a saving grace.

    I think the more we think about it, the more reasons we can find.
    Hope others may join too with their views.

    Anbazhagan

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    1. Kieran O'Connor Post author
      Anbazhagan, you’ve got quite a lot of information here, covering areas that delve way beyond compliance.
      Since your material is condensed into a comment within a blog, I feel the danger is that it will remain quite hidden.
      You have enough material here to write a series of blogs, covering Compliance (and the need to look beyond), Occupational Health & Safety, and also EH&S.
      How would you feel about starting your own blog series? You could then elaborate on areas you mention here, such as:

      • going beyond mere compliance
      • the crusade of Rachel Carson
      • the growing awareness, education, and engagement of production personnel and management
      • risk of compliance “sliding down to non-compliance”
      • ISO 14001:2000 standard
      • example from Tata
      • compliance v truth

      We really would benefit from you vast experience and knowledge. And we have forums dedicated to CSR and GRC with input from very experienced BPXers, such as Paul Centen and Marilyn Pratt, who would be delighted with your incisive commentaries. Of course, I would also very much appreciate sharing your excellent perspectives with the Process Industry BPX forums on Chemicals, Oil&Gas, and Mining&Metals.
      Let me know if you need support setting up the blogger profile and posting the first blog (after that, it will be very easy for you).
      First point of reference would be to create your blogger profile:

      I really look forward to your blogs.

      Regards and thanks,
      Kieran

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