Navigating the Complex World of GHS/CLP and REACH Compliance and Impact on the Workplace

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1 Navigating the Complex World of GHS/CLP and REACH Compliance and Impact on the Workplace Louise Bernstein March

2 Agenda Supply Chain Roles Which are you? GHS/CLP Downstream Obligations Impacts to the workplace REACH Downstream Obligations Impacts to the workplace GHS/CLP & REACH: General Impacts to the Workplace 2

3 Supply Chain Roles Which are you? Manufacturer A company manufacturing a chemical substance Importer/Distributor A company that imports a chemical substance into a country for own use or passes chemical substances onto third parties e.g. a retailer Downstream User - Companies that buy chemicals and use in industrial or professional activities 3

4 GHS/CLP Obligations Hazard Classification - Classify hazards to GHS categories Hazard Communication - Update SDS and product labels to GHS standards Manufacturer (Upstream) Employer (Downstream) Hazard Communication Received GHS SDS available to employees for hazardous products onsite Update internally created labels/signs/risk assessments, etc. Train employees 4

5 GHS/CLP Downstream Impacts Quantity and use limitations for products deemed more hazardous Alternative, less hazardous purchase choices for employees and finished goods Storage, PPE, new waste considerations Purchasing 5

6 GHS/CLP Downstream Impacts Finished goods may become more/less hazardous to manufacturer and transport due to new available data Market restrictions for raw materials deemed carcinogenic, mutagenic, or toxic to reproduction Reformulation to lessen a finished good s hazard category Product Stewardship 6

7 GHS/CLP Downstream Impacts Classification impacts to existing responsibilities e.g. EU s Seveso III, CMRs Monitor regulations to capture ongoing changes Regulatory Reporting 7

8 GHS/CLP Downstream Impacts Educate employees One size doesn t fit all coordinate classification of finished goods between countries Questions, document requests from customers downstream Stakeholder Awareness/ Alignment 8

9 Downstream REACH Obligations Provide use information to suppliers Take action if use not accounted for/rmm advice inappropriate Implement measures specified by supplier to ensure safe use Upstream communication of new information on substance hazards Evaluate options when using a restricted substance REACH Registration for product that is not your own - Ensure SDS submitted is latest version 9

10 Downstream REACH Obligations Provide use information to suppliers Take action if use not accounted for/rmm advice inappropriate Implement measures specified by supplier to ensure safe use Upstream communication of new information on substance hazards Evaluate options when using a restricted substance REACH Registration for product that is not your own - Ensure SDS submitted is latest version 10

11 Downstream REACH Obligations Provide use information to suppliers Take action if use not accounted for/rmm advice inappropriate Implement measures specified by supplier to ensure safe use Upstream communication of new information on substance hazards Evaluate options when using a restricted substance REACH Registration for product that is not your own - Ensure SDS submitted is latest version 11

Downstream REACH Obligations Provide use information to suppliers Take action if use not accounted for/rmm advice inappropriate Implement measures specified by supplier to ensure safe use Upstream

12 Downstream REACH Obligations Provide use information to suppliers Take action if use not accounted for/rmm advice inappropriate Implement measures specified by supplier to ensure safe use Upstream communication of new information on substance hazards Evaluate options when using a restricted substance REACH Registration for product that is not your own - Ensure SDS submitted is latest version 12

13 Downstream REACH Obligations Provide use information to suppliers Take action if use not accounted for/rmm advice inappropriate Implement measures specified by supplier to ensure safe use Upstream communication of new information on substance hazards Evaluate options when using a restricted substance REACH Registration for product that is not your own - Ensure SDS submitted is latest version 13

14 Downstream REACH Obligations Provide use information to suppliers Take action if use not accounted for/rmm advice inappropriate Implement measures specified by supplier to ensure safe use Upstream communication of new information on substance hazards Evaluate options when using a restricted substance REACH Registration for product that is not your own - Ensure SDS submitted is latest version 14

15 REACH Downstream Workplace Impacts esds Size: Printing costs, hard to decimate, use avoidance Language: Most Exposure Scenarios are in English Availability: Very few esds in the market Supply Chain protection: Ensuring suppliers are engaging in REACH registrations of your raw materials Operational Changes Company s use of a product must match Exposure Scenario Sourcing Changes Sourcing from alternative suppliers that have accounted for a company s use of a product Raw materials removed from market as they are deemed SVHC, or supplier could not justify REACH registration ROI 15

16 GHS/CLP & REACH: General Workplace Impacts Importance of gathering accurate documentation (e.g. SDS) per product Increased product information requests up and down supply chain Purchasing changes due to changing/more complete product information available new Personal Protective Equipment (PPE) Increased employee training Update internal documentation Safety Cards/Risk Assessments/Labels/Placcards Need to integrate information between platforms - purchasing/product stewardship/regulatory teams 16

17 Daunted? Don t be! ECHA 17

18 Challenges in Global Workplace Safety Compliance in the World of GHS/CLP and REACH 18

19 Agenda Benefits of global program management Global implementation best practices that achieve compliance assurance Selection requirements Roll out options Best Practice GHS/CLP and REACH activities, with 3E Online Support (demonstration) 19

20 Global EH&S = Tightrope Walk! Differing and Changing Regulations (or lack of) Resources Adhering to Corporate Strategy Budget Allocation Local Considerations - Logistical and cultural 20

21 What is Global SDS Management? Managing one system for all global locations Application: Information is stored, viewed, and downloaded from centralized access point Document management: Procedures created to ensure information is kept current 21

22 Why Global Management? Sharing data and documents One single version of the truth One reference point 22

23 Why Global Management? Compliance Administration Ensure local and corporate due diligence Centralization One system for all locations/depts., inventory consolidation and transparency, analysis Productivity Removal of duplication of work and reduction of overall SDS management, enabling a focus on other tasks. More is achieved. Cost Reduction/Avoidance Increase in overall efficiency removes operational costs. 1:N management e.g. 1 SDS can be updated for all locations using it All sites have access to time saving tools SaaS module no IT time, hardware to purchase, 1 system for all locations Data repository Centralized data and SDS used for multiple purposes; regulatory tracking, supply chain analysis, integration with internal tools Authoring, BOM, ERP, Purchasing, etc. 23

24 Global Management Roll Out Steps Research Current Systems Regulatory Awareness Select System Standardize & Localize Communicate Phase Roll Out 24

25 Roll Out Steps: Selecting System One access point Support for the wide breadth of regulations Ability to adapt when regulations change e.g. GHS/CLP Ensure multilingual capabilities to support multinational workforce Scalability geographically, technologically (infrastructure & IT personnel), increased volume of data stored 25

26 Global Management Roll Out Steps Research Current Systems Regulatory Awareness Select System Standardize & Localize Communicate Phase Roll Out 26

27 Global Management Roll Out Steps: Phased Roll Out 1. Geographies Similar time zones, regulations, languages, logistically easier to travel around 2. Business Unit/Location Groups Employees are usually acquainted, similar products, usually share policies and systems 3. Regulatory Requirements Focus on countries with immediate regulatory priorities. GHS & REACH, for example 4. Current Systems Roll out based on implementation similarities 27

28 Best Practices REACH & GHS/CLP Activities and 3E Online Support 28

29 Shared GHS/REACH Activities 1 Sourcing Updated Supplier SDS 5 Training (Throughout cycle) 2 Distributing SDS to Employees 4 Utilizing New Information 3 Evaluating SDS Changes 29

30 3E Online: REACH Support esds RMM Timeline Commencement Report REACH Annexes Cross-referencing & Tracking esds Flagging REACH Registration Number Reporting & Tracking esds Obtainment & Update Alerts Most Comprehensive Downstream REACH support on the market REACH Role/SVT Reports 37

31 3E Online: GHS Support GHS extraction and comparison reports Revision Alert to compare changing GHS information Labels Sized for use around the world GHS classification and labeling inventory lists, e.g. European, Korean, and Japan Full multilingual GHS data extracted Data integration into other platforms (3E & third party) Obtainment of GHS SDS Most comprehensive downstream GHS support on the market GHS Employee Training Tools (US) 38

32 Thank You 39

Corporate Overview. Intelligent compliance. Sustainable progress. A safer world. 1

Corporate Overview. Intelligent compliance. Sustainable progress. A safer world. 1 Corporate Overview Intelligent compliance. Sustainable progress. A safer world. 1 Intelligent compliance. Sustainable progress. A safer world. Regulatory requirements that directly impact business activities