Chemicals are the building blocks of life. Everything you see, and even what you don’t see, like air, is composed of chemicals. But just as the moon has a dark side, there is also a dark side to chemicals. They can harm human health and the environment, and even kill living organisms. As a result, chemicals have been highly regulated for decades.
A stringent regulatory landscape and public pressure to eliminate the use of dangerous chemicals have led to significant chemical management challenges for industry. Thankfully, leading organizations learned how to address them by implementing best practices designed to effectively comply with regulations and proactively manage change. We share four such best practices in this post.
1) Assess Chemicals at the Product Design Stage
We’ve heard many times that it’s easier, and less expensive, to fix a problem when it is still small. The same principle applies to products that contain chemicals, whether they are articles that have components with chemicals, or chemical mixtures that include substances or other mixtures.
When a product is at the design stage and its components or ingredients are being determined, all chemicals that will go in the product should be assessed to determine if they include regulated or hazardous substances. If required, it’s easier to substitute components or ingredients at the design stage, rather than the manufacturing stage when materials have already been sourced. This can also help avoid non-compliance, product recalls or potential harm to consumers or the environment, which would bring bad publicity.
2) Screen Products When Regulatory Lists Change
Many jurisdictions maintain regulatory lists of substances subject to restrictions, authorization or notification requirements, reporting obligations, or even complete prohibitions. Companies that market products to many countries around the world are thus impacted by a multitude of regulatory lists. Even if only a small portion of lists change frequently, the high number of lists leads to many regulatory updates in the course of a year, which increases risks of non-compliance.
Through a central software platform embedded with regulatory content, make sure your products are screened whenever a regulatory list changes. If a list has a new or modified entry, impacted products should be flagged so you can determine if you need to take additional actions, or if you may need to substitute a component or ingredient.
3) Determine Impacts of Supply Chain Changes on Products
Most companies are part of complex supply chains. Any change in a supply chain can have a ripple effect. Suppliers are also subject to compliance obligations, which means they may modify, substitute or maybe even completely retire materials. Each time a supplier makes a change to a material you purchase, you should determine the impacts on your products that include that particular material. There may be new, modified, or even a reduction in compliance obligations associated with your products, or worst case you may need to completely substitute the material. Determining the impacts of supply chain changes lessens risks of non-compliance and helps avoid potential future costs.
4) Identify Quickly Affected SDSs if Products or Regulations Change
Not all products containing chemicals need a Safety Data Sheet (SDS) (e.g. articles, most consumer products), but those that do have an additional layer of complexity. A non-compliant SDS can lead to an inability to sell or ship your product into a country. In addition, products sold in multiple countries have multiple SDSs in different languages, thus increasing complexity.
SDSs must always remain compliant. That’s why it’s important to identify quickly, and in an automated way, SDSs that may potentially need to be updated if any of the following occurs: 1) Change in a product; 2) Change in a material; 3) Change of suppliers; 4) Update to a regulatory list; 5) Update to a pertinent regulation.
Whenever any of these changes occurs, you should: a) Identify affected products; b) Identify affected jurisdictions; c) Identify affected SDSs based on applicable product/jurisdiction combinations; d) Evaluate if affected SDSs need to be updated.
If you want to learn more about chemical management best practices, challenges that you will face in 2018, including the REACH registration deadline in the EU, and how to address them, click on the image below to register for our webinar with Verisk 3E: