As we head into 2012, the regulatory landscape remains volatile and unpredictable. OSHA’s adoption of the Globally Harmonized System (GHS) was announced in March, significant progress is being made on the Safe Chemicals Act and the new requirement to produce REACH exposure scenarios (ES) further burdens manufacturers and distributors who already are struggling to conform to REACH’s initial requirements.
Critical regulatory and product data often serve as the cornerstone of a successful EHS regulatory compliance program, and are leveraged for initiatives throughout the company, including product stewardship, risk management and corporate social responsibility. In addition, the data is needed to benchmark performance and measure success against goals and obligations.
Unfortunately, regulatory and product data increasingly has become difficult to manage in-house, as it often demands specialized domain expertise and complex, supply-chain communication processes that may not be available in many companies. The difficulty in part is due to the sheer volume of regulations that may impact a company at any given moment in time.
Regulations, initiatives and directives are devised and enforced by regulatory and governing bodies throughout the world, and are individually published in a variety of formats and locations. The information is scattered among hundreds of disparate sources and is not easily shared between stakeholders within a company who need to reference it. Without centralized access to current global chemical, regulatory and product information, EHS, regulatory, supply chain and R&D professionals can spend a tremendous amount of time researching and maintaining this information, taking away time and energy from more strategic functions.
Given the complexity of managing the information, many companies are opting to partner with a service provider for these critical data requirements. It is a decision that should not be made without considering a variety of criteria to determine that the best data and the best service provider is chosen.
First, let’s explore the requirements from a data perspective. Substance-level data should encompass regulations, along with the rules, phrases and templates required for meeting legal requirements and providing accurate documentation for chemicals and products, based on their compositions, where they are produced and how they are used and distributed.
Substance-level data must include extensive coverage of hundreds of thousands of regulated chemicals, broad categories (such as mercury compounds), food additives and flavors throughout the world at multiple levels of jurisdiction. Frequent updates are critical, since rules and requirements constantly are changing and expanding globally.
At the product level, from its inception to the present day, the material safety data sheet (MSDS) has evolved into a document that goes far beyond its original purpose. It now serves as a source, foundation and clearinghouse for a range of safety and regulatory compliance data, including hazard communication, classification, transportation, environmental, ecological and disposal considerations. MSDS product-level data continuously should be updated with a service provider’s dedicated team, advanced documentation, information and search technologies, documented best practice methodologies and through direct data obtainment relationships with raw material and other chemical product manufacturers.
The chosen service provider should offer to provide the most robust substance-level regulatory data and product level MSDS data available that is broad in scope, current, high quality and accurate. This information must be developed, managed and maintained by highly qualified regulatory and geographic specific experts.
Companies also should find a provider that features data as its core competence with researching, sourcing, aggregating, enriching and maintaining EHS compliance-related data serving as the foundation of their business. The associated access and decision support products should make the data available to customers in a format that is easy and practical to use, and based on specific needs. Substance-level data and product-level data should be integrated to provide a view into the impact of regulatory changes across inventories in the enterprise.
Other unique and compelling factors when selecting a data service provider include the vendor’s knowledge base, which should be deep as well as broad, and include a variety of dedicated specialists in appropriate disciplines who provide maximum coverage for critical information such as MSDS and regulations on substances. Access to support is critical, as are experience and expertise.
With accurate, comprehensive and reliable data at the core of your EHS regulatory compliance program, the uncertainly of the regulatory landscape isn’t as daunting because you can be confident that the data fueling your processes and initiatives is sound. As an added benefit, this data also can be leveraged for other critical initiatives, as well as to reduce risk, promote a stronger brand and increase customer loyalty.
Scott Bauer is a Senior Solutions Engineer and Connie Prostko-Bell is a Senior Solutions Manager with 3E Co.