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Author's profile photo Christoph Bergemann

Chemical Regulations / A challenge

Dear all

based on a current thread placed here I would like to provide an example about how complex chemical regulation might be (at least the chemistry as such is sometimes as well not easy to understand).

Let us use the chemistry as known as Hydrogenchloride as an example. Using chemical nomenclature this is written as “HCL”. If you check now the many inventories and other regulations you will find this:

1.) we have one CAS number 7647-01-0
2.) we have two INDEX numbers as:

017-002-00-2 HYdrogenchloride as a gas
017-002-01-X Hydrogenchloride as solved in water

This “simple” example can show how complex chemical regulaiotns might be.

If you handle the “gas” then you have completely different topic to consider (more hazardous for environment and e.g. human beings)
If you handle it in a solution with water now the next complex issue come up. Based on concentration of Hydrogenchloride in water you will have different “Labeleing” information to be considered

In most cases the best option for EHS is: create two LIST_SUBs; one describing the gas and one describing the “solution”

IF you then check e.g. the CAS registry and looking for “real life chemistry” you will see that there are lots of similar complex examples. Many real life examples are related to either:
a.) complex mixtures or aliphates and aromates (oil industry etc.)
b.) polymers
c.) some times you have two CAS number by “modification” of a chemistry
d.) some times you have one CASE number for variants of “racemic mixtures”


Now the “big” issue is to define an approach: how to combine the “chemical” aspect (what is really inside; can I describe it) and then to look for CAS and other numbers which can be used to “link” to e.g. status of registration.

The next interesting challenge is then: how can you use the “content” provided by many companies to “load data” in your system?

We have seen only may be <= 10 threads in the last years discussing in SCN and in new platform this “regulation topic”

The reason is “simple”. This topic is not a “software” topic but how you would like to use the solution as delivered by SAP.

In the next years we can assume that the situation will get more complex (e.g. Korean like REACH regulation). So be prepared in your organisation to handle this

On the othere hand:

There is a permanent change of legislation. Therefore: you (as acting company) need to consider this and you need to define approches to handle this. One approahc is using “SERC/SERD” ┬áservecises. But even this might not be “good” enough as you need a good approahc to “migrate” from old solution to new one (e.g with REACH; Swicth of chapter 2 and 3 in safety Data Sheet etc.)



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