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How to deal with legal/regulatory changes (using SAP EHS MANAGEMENT)?
What are the business needs to use SAP EHS MANAGEMENT?
In most of the countries chemical companies must fulfill local or global regulation/legislation needs to e.g. produce chemicals and to sell them. SAP EHS MANAGEMENT can be used to fulfill those demands. Now with the starting of “Management of Change” (http://help.sap.com/managementofchange) approach the whole management of changes (either data or document content et.c) process might be integrated better in SAP but the use of SAP EHS Management itself is a matter of internal organisation of a company as well.
About SAP EHS Management
Document SAP EHS Management for Beginners gives (tries to give) an overview of the many SAP modules in SAP EHS Management. The below listed topics are mainly related to the modul called: SAP EHS Management as Part of SAP ERP. It does not cover the options and challenges in context to the other SAP solutions listed there.
Challenges in the use of SAP EHS Management as Part of SAP ERP
What are the “basic needs” and why might SAP EHS Management help?
a.) in most of the regions you need to create a Safety Data Sheet and you must provide it to the customer who receives the corresponding material/chemistry=> this can be fulfilled clearly with SAP EHS Management
To create a SDS/MSDS according the legislation/regulation you need to consider
- you need data maintained (e.g. on REAL_SUB, LIST_SUB, PURE_SUB etc.) level. To do so you will need: 1.) phrases, identifiers, propertry tree content and other stuff (customizing must be done, phrases must be available etc.). And you need “legal content”
2.) “Legal content” does mean: you need data maintained as OEL, labeling data etc. This data can be maintained by your own or you can buy legal content. The “legal content” will in most cases change once per year; so there is the need to make sure that you have corresponidng data in the system. This is not only related to LIST_SUB level but data on LS_UN_SUB level as well
3.) to facilitate the preparation of “add on data” needed for SDS/MSDS you can use “rulesets” which are delivered as well by content providers
4.) At the end you might have the need to update your corresponding WWI layout because of changes in the legislation
b.) in most of the regions you must make sure that you fulfill the transport regulations. Part of that (and sometimes “ignored” a little bit) is the topic of “packaging” as your are only to transport the chemical by using proper packaging => this can be fulfilled clearly with SAP EHS Management
- 1.) As mentioned above: some part of data maintenance can by simplified by use of “content providers”
- 2.) You can get data but e.g. updates on rulesets as well
BUT in context of DG topics the support is “limited” (e.g. mainly in context of the packaging part)
c.) in many regions you must make sure that the chemical is stored properly (without risks to humans and the environment) => this can be fulfilled clearly with SAP EHS Management
Storage does mean here: store together; make sure that you can create e.g. SARA reports, fire brigade lists, and similar stuff
d.) on the top there is the need sometimes to prepare “Standard Operating Procedures” => this can be fulfilled clearly with SAP EHS Management
e.) and SAP EHS Management can be used as well in the process to get permission to build a new plant (e.g. Seveso etc.)
=> this can be supported/fulfilled clearly with SAP EHS Management
f.) and you can use SAP EHS Management in context of e.g. chemcial weapon convention and other “legal trade” regulations
=> this can be fulfilled clearly with SAP EHS Management
g.) There is the need to create “chemical inventories” (German: Gefahrstoffkataster) =
=> this can be fulfilled clearly with SAP EHS Management
h.) You need to take care e.g. regarding REACH, TSCA, CEPA topics (management of amount of substances to be registered)
=> this can be fulfilled clearly with SAP EHS Management
i.) there is the need to exchange data using e.g. XML in many contexts (either for industry purposes (IMDS) or for legal reasons (REACh)
=> this can be fulfilled clearly with SAP EHS Management
j.) there is the need to manage company internal changes in regards oc legislation. (e.g. now option of Management oF Change is delivered; some aspects are as well part of SAP Product and Reach Compliance Suite)
=> this can be fulfilled clearly with SAP EHS Management
k.) there is the need to handle the chemistry as such within company (e.g. now more related to “Component Extenstion for SAP EHS Management)
=> this can be fulfilled clearly with SAP EHS Management
etc.
BUT KEEP IN MIND. REGULATIONS ARE CHANGING. NEW REGULATIONS CAN COME UP FAST ETC. Example: Korean Reach compliance
But taking all that into account what does that mean on daily basis?
You as chemcial company must make sure that you manage the “change of data”. E.g. many companies do use external providers to get updates in regards of e.g.:
- phrases
- rule sets
- WWI layouts
- legislation data
On the top SAP is now delivering a lot of additional services and there is clear trend of use of Cloud based solutions or to manage the data/documents using “services”.
Based on the permant changes in legislation SAP is reacting on that by e.g. delivering up to date property trees. But not all of the topics are covered and/or must be dealed with by using additional services from SAP:
Examples are: sometimes you need new identifiers etc.
One can assume that at least once a year some minor update regarding all “technical” content is needed to still fulfill all legal requirements and clealry then ther eis the need to look for data and maintain them (and may be on top release WWI reports e.g. SDS). And this is only the technical part. The business upate process need to be triggered as well in a timely manner (e.g. REACh does have sometimes very short time limits which need be considered).
But now after you have imported the new data? What is the next step? Some companies create simply the new safety data sheet, some others try do identify: what does the new data mean? How many chemcial materials are effected etc.? How to deal with the set up of new WWI documents (new may be relevant version of safety data sheet)? Some companies use internal workflows (not using SAP system as IT system to support this process); less use the EHS workflow (as most of them might believe this might be to complex). Some use the automated SAP EHS mechanism to generate new Safety Data Sheets (but still need to handle in many cases the “Release” of the generated documents). But today this is not sufficient any more. You have to take care about content of label data and label reports as well etc. Correlate to that is the topic of “relabeling” need. At least tomake sure that you have the correct label available.
Therefore before you start a SAP EHS Management project you should be sure that you understood your external and internal needs, especially your internal organisation and you should have a plan established regarding roll out (by region? by SAP EHS module or other criterias).
But even if you have finished with the set up SAP EHS Management will not be stable because of the permanent legal changes and adaptions. And many companies have IS/IT governances taking care about the use of recent SAP software. Using the recent one provide chances to optimize processes. E.g. with SAP ERP ECC 6.0 EnhPack 7 more options are available in context of GLM. Therefore you have new options but you need to decide how they can help you in your daily business and how to get this improvement in place from technical perspective (and clealry sometime regression test are needed a trainings etc.)
Depending on the region there you act you man need to consider e.g. the use of EHS Substance Volumne Tracking and (e.g. REACh, TSCA, CEPA context) the use of SAP Product and Reach Compliance Suite.
Now as there is a tend to use the “Component Extension of SAP EHS Management” you have may be a further software layer to take into account: what will happen and what need to be done if a regulatory change happens?
SAP EHS Management itself does contain a lot of suitable tools and technique to help companies. It is “only” a matter to decide which of the IT processes are useful, need to be optimized etc.
Without a good a stable process (set up of organisation etc.) to deal with legal/regulatory changesyou will not suceed taking care regarding the many challenges.
What can we expect of SAP in the next years regarding that?
Tools to help the Management of Change process will be established more and more and hopefully integrated more and more. The software it self will get “better” (based on enhancements using e.g. Business Functions). The use of “what if scenarios” might be more simpler as now. And regarding the trend to “analyze” the data (business quality etc.) we can expect hopefully that SAP will support the chemical companies as this is a “basic” need to analyze and check: how compliant are we? Can we do better? There is a lack “information”? What will happen if we exchange raw material A by B (e.g. does it have an effect on labeling; on status of registration). Does it hinder us to do more business? There do I use “hazardous substance? Can I avoid them? what does the use of this substance means for the employee? Which risks need to be considered for him/her and for the environment. How to reduce the risks? What about if I use many recipes for doing the same? How to handle eg. in this case “FDA” requirements.
A workload on the top is: the customer is always asking for more information on the products. Therefore the option to prepare inquiries etc. to retrieve the information might be a critical fact itself. Here you need to dig deeper as SAP EHS Management can help you (check e.g. http://help.sap.com/saphelp_erp60_sp/helpdata/en/a7/286cb50a6c11d28a220000e829fbbd/content.htm; context “TREX” search engine). SAP BW and similar approached can help as well.
As with regulations like REACh one can expect that you need “enough” time to make sure that you are prepared as in many cases you need to maintain more data and most of the data is not available and therefore you have to check there to find that etc. And even if the legislations is in place you need to take care about changes in your organization, in market etc. (e.g in context of REACh: you must take care regarding new “uses” to register, to make sure that you have registered any substance in the correct tonnage band; you need to take care regarding GHS etc. etc.).
But at the end: even if the software might be “stable” neither legislation/regulation is stable nor the data related to that (e.g OEL Limits).
Therefore to a certain extent we are talking about “automating” of processes. Is there really the need to have an expert in place to check content of safety data sheet, about dangerous goods relation topics etc.
We will see how SAP can support this in the future.
This is clearly a challenge but without taking care we need to make sure that we understand e.g. REACh: No data no market
And this seems to be a “international” trend now. Let us hope that SAP provide to us new further innovative solutions and will provide tools in place which can be used for efffective data management and the management of the change of data and e.g the change of content of documents.
Please check as well these documents:
Determing Chemical Compliance with SAP HANA in Product Development
Achieving True Product Integrity
Featured Content for Chemicals
Best Practices for Chemicals – SAP Solution Manager
SAP REACH Compliance Solution Process Flow
How to Use SAP Best Practices for Chemicals During SAP Implementations
http://scn.sap.com/docs/DOC-1887
Bulk Transportation Scheduling for Chemicals Supply Chains
Bulk Transportation Execution for the Chemical Industry
Getting Started with Chemicals
Sustainability Strategies for High Performance in the Chemicals Industry
Get actual information about SAP for Chemicals
Are you capturing all information required? Can you prove and improve process compliance?
Take a look at SAP for Chemicals to get more input
BI Reporting
SAP is delivering a lot of BI reporting stuff in context of SAP EHS Management. E.g. check:
SAP EHS Management – BI Content & BI Content Extensions – SAP Library
http://help.sap.com/saphelp_ehsext30/helpdata/en/2c/5ac523a1244780b535f08340308828/content.htm
SAP EHS datasources and extractors list for BW (Environment, Health and Safety – )
All these tools and techniques can support you dealing with legislation changes and these can be used on regular basis to get a report/status about compliance in your company. There is as well a trend to use Dashboards and similar stuff and we have more SAP mobile solutions in place.
Compliance Checks
Examples to execute compliance checks either in SAP EHS only or together with GTS are listed here:
| Link | Type | Remark |
|---|---|---|
| Examples of Integration of SAP EHS Management into other SAP Solutions | SDN Document | To give an overview |
| http://help.sap.com/saphelp_gts80/helpdata/en/40/ef2d1b7a774addb6f988a0c499f409/content.htm | SAP Document | Integration EHS <=> GTS |
| EHS Integration points with GTS | SDN Document | Integration EHS <=> GTS |
| Dangerous Goods Information (EHS) in GTS | SDN Document | Integration EHS <=> GTS |
| SAP Product Compliance Managers Summit | SDN Document | |
| Compliance Check (EHS-BD-CCK) – SAP Library | SAP Document | |
| EHS Compliance checks | SDN Document | |
| consolut – RMS_COMPL_CHECK – Set Up EH&amp;S Compliance Check for Recipe Management | Other Document | Compliance Checks / Recipe |
Appendix
Will be enlarged in the future
Dear Chris,
The document seems to be an eye opener for regulation. i was expecting the methods to handle regulations in SAP EHS which seems to be missing. Will that be part of your enxt document??
Dhinesh
Dear Dhinesh
what are you "looking" for? (" methods to handle regulations in SAP EHS which seems to be missing")
On high level: SAP is delivering a STANDARD property tree. The STANDARD property tree is enhanced regularly by SAP taking into account feedback of e.g. chemical companies.
Depending on the needs and internal organization within your company many companies use on the top "content" (they buy them).
Content does mean e.g.:
1.) new or update layouts (MSDS/SDS)
2.) new or updatded phrases
3.) new or updated expert rules
4.) etc.
Regarding some topics there is no SAP standard set up (or only very low level): e.g. SVT, IHS, GLM.... and you need to take care regarding them in most cases as well.
Even if you (as company) are not buying content: you will check on regular basis the regulation/legislation needs and compare it with your SAP set up. If needed you will create own properties/value assignment type, new phrases etc. to take care regarding new regulations. Main drivers in the last years are: REACh, GHS and other regulations. These have been clearly prepared by SAP as well. But "local" regulations are not always considered by SAP in delivering e.g. STANDARD tree.
Therefore the processes/methods to take care regarding these demands are different per company.
Therefore: Which type of content you are looking for in a document which might be prepared in the future?
C.B.
Thanks for your wonderful information CB.
Hi CB,
I have a quick question on Management of Changes ?
Technically MOC process is the same process as ECM (Engineering Change Management), but what makes the difference between ECM and MOC, why we need separate module for MOC ?
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At one level, ECM and MOC are very similar. At another level, they differ. ECM tends to focus on changes to the product and how to track the effect of those changes once they go into effect. For example, tracking which serial numbers have the new part. MOC tends to focus on the process for producing the product and ensuring that changes to the manufacturing process do not unintentionally add more risk. Particularly in oil & gas and chemical industries, there are regulations that specify that this type of risk assessment and approval process must be conducted for hazardous chemicals that have potential for large-scale environmental and community impact. However, using an MOC process is a best practice and many companies use it for every change that is not a replacement in kind. MOC focuses on collaboration between experts, and ensuring that all angles have been considered (regulations, policies) and that activities are managed (such as a pre-start-up safety review or PSSR.) You could tie MOC and ECM together for a hybrid situation where both the product change and the process change need to be managed.
Thanks Mary,
Then I think in MOC, we may have some change number which will control the process ?
More over its looks like its a part of cross functional application, but I don't see on my system under cross functional application, not even in SFW5 ?
Which part of SAP is this MOC licensed ?
Appreciate your help.
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Hi - you will find the documentation here: http://help.sap.com/managementofchange
It is licensed separately from the Business Suite.
Thanks Mary.
Appreciate your reply.
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🙂
Thank you for sharing Christoph. Love your contributions to our SAP for Chemicals community!