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Chemical Supply Chain
Chemical Supply Chain
Chemical Supply Chain
Chemical Supply Chain
Chemical Supply Chain
Chemical Supply Chain
Chemical Supply Chain
Chemical Supply Chain
Chemical Supply Chain
Chemical Supply Chain
Chemical Supply Chain
Chemical Supply Chain
Chemical Supply Chain
Chemical Supply Chain
Chemical Supply Chain
Chemical Supply Chain
Chemical Supply Chain
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Chemical Supply Chain
Chemical Supply Chain
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Chemical Supply Chain
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Chemical Supply Chain
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Chemical Supply Chain
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Chemical Supply Chain

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What Supply Chain Managers need to do to meet effectively comply with REACH ? …

What Supply Chain Managers need to do to meet effectively comply with REACH ?

By Philip Capel

LogiChem 2011 will be the event's tenth anniversary and an opportunity for the most senior chemical supply chain & global logistics directors from the European chemicals community to come together once again share experiences, make new contacts and benchmark the latest chemical supply chain initiatives.

Not only will LogiChem 2011 be a chance for the chemical industry to reminisce about the last ten years but an opportunity to shape the next decade. To celebrate a decade of LogiChem, there will be an exciting three day programme filled with networking opportunities in our new location, Antwerp.

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  • 1. What Supply Chain Managers need to do to meet effectively comply with REACH ? Philip Capel, European Sales Director REACHLaw LtdCopyright © 2008 REACHLAW Ltd. All rights reserved.
  • 2. Topics to be covered Introductions Current status of REACH The role of supply chain in REACH and key responsibilities Alternative strategies Future of REACH and impact on supply chain Conclusions & summary
  • 3. REACHLaw’s mission REACHLaw Ltdexists exclusively to provide full set of REACH services and timely solutions to its clients by offering unique combination of expertise in REACH, legal, chemistry, environmental and business Key capabilities of REACHLaw: Industry knowledge, Legal REACH knowledge, Chemistry,Close Cooperation with ECHA and Helsinki REACH Centre, Independence
  • 4. REACHLaw Ltd today : World class REACH service provider Partners CustomersOur customers: > 200 major manufacturers in more than 30countries with 2500+ substances
  • 5. Topics to be covered Introductions Current status of REACH The role of supply chain in REACH and key responsibilities Alternative strategies Future of REACH and impact on supply chain Conclusions & summary
  • 6. What is REACH? REACH is the new chemical legislation in the EU affecting the sale and manufacture of all chemicals unless specifically exempted REACH (and CLP) are in force NOW! No registration – no EU marketCLP: Classification, labelling and packaging
  • 7. REACH is complexREACH text is 849 pagesDifficult to understandNew and unclear definitionsIT tools are still under developmentProcesses are unclearResponsibilities unclear (Commission, National, ECHA, Enforcement)Guidances more than 20.000 pages (still in development)Failure to comply may lead to halt of production and eventuelcriminal penaltiesFor a company it is an exercise in knowledge management
  • 8. Supply Chain vs REACHSupply chain manager REACH Raw materials, Products, Substances, Mixtures, SKU,s Articles INCOTERMS, POM (place on the market) Distributors, Customers, Manufacturer, Importer, Suppliers, Formulators, Downstream User (OR) toll-manufacturers, warehousing
  • 9. Different Actors in the REACH SupplyChain“Only representatives” established in the EU and appointed by amanufacturer, formulator or article producer established outside the EU tofulfil the registration obligations of importers
  • 10. ECHA Statistics : pre-registrations Total number of pre-registrations 2,750,000 pre-registrations 65,000 companies signed up in REACH-IT 146,000 different substances pre-registered Volume about 15 x expected by ECHA Number of pre-registrations to be safe ? Non-EU pre-registrations ? Importers ? Our conclusion: Far fewer ”real” registrants involved as the work really gets going
  • 11. Some implicationsOriginal estimate Pre-registration Current status Key concerns 2.300 How to get the substances with work done, Lead Registrant costs ? 6.700 How to get the substances whereECHA 9.000 55.000 work started ? LR needed (HPV, substancesCMR’s etc) with 2010 deadline 0-46.000 (?) wrong pre- Which ones ? registrations Replacement 0-46.000 (?) of substances, substances which change of will disappear processes ?
  • 12. Key concern : Current (=real) status of REACH work, outcome 2010 ?
  • 13. Availability of chemicalsSubstances not covered currently 2010 deadline, no progress yet A huge risk: no registration Only solution: Industry must take the responsibility and some major manufacturer must show up as Lead Registrant, otherwise no registration
  • 14. Topics to be covered Introductions Current status of REACH The role of supply chain in REACH and key responsibilities Alternative strategies Future of REACH and impact on supply chain Conclusions & summary
  • 15. Fig. 2: REACH & CLP: Main issues for sourcingand delivery Main issues for sourcing: • availability of raw materials? Non-EEA EEA • coverage by upstream registrations? • REACH-SDS and CLP-labels? • risk of non-compliance mitigated? Formulator Manufacturer Consumer Manufacturer OR Final professional user Your company Distributor Sour Deli Formulator EEA supply chain cing very Distributor Main issues for delivery: • REACH-SDS and CLP-labels? Article supplier Supplier • exposure scenarios for customer uses? • risk of non-compliance mitigated? • Article 33 SVHC communication
  • 16. REACH and CLP (Classification Labelling and Packaging)REACH All chemical substances must be registered by manufacturer or importer unless exempted Requires an extensive technical dossier including tox/ ecotox data and uses Only applies to volumes above 1 ton per yearCLP Derived from the GHS UN to be implemented in EU Requires notification of hazard classification and labelling by manufacturer and importer Re-labelling, re-packaging by suppliers of hazardous substances and mixtures Applies to all substances and mixtures regardless of volume (very limited exemptions)
  • 17. Supply Chain Communication REACH Role & ResponsibilitiesRegistrants duty of communication As a part of Registration Dossier collect info on uses Provide SDS to customerDownstream Users Communicate new info on hazardous properties Duty to identify apply & use recommend RMM Report info to ECHADistributors To pass the info on next actor in supply chainArticle suppliers Info on SVHC in articles acc to Art.33
  • 18. Main REACH & CLP tasks in the supply chain for 2010 / early 2011 (simplified) What REACH Registration CLP Notification CLP Classification, REACH compliant SDS ² REACH REACH Candidate List & when 30.11.2010 ¹ 3.1.2011- Labeling & Packaging ² Continuous Restrictions for Authorization (for substances) Continuous ContinuousWho 1.12.2010-Manufacturer / Required Required Required Required Required Mainly ’early warningimporter of unless only unless only For dangerous system’ (consider phase-substances (on their representative does for representative registers substances and mixtures out of substance)own or in mixtures) importer beforehand incl. CLPDownstream user Not required Not required Required Required Required Mainly ’early warningof substances (e.g. but check if registration but take over supplier’s For dangerous system’ (consider phase-formulators and other covers your use and – classification if substances and mixtures out of substance)professional users) if not - check obligation unmodified to prepare CSRDistributor (incl. Not required Not required Required Required Required Mainly ’early warningretailer) but check if registered but take over supplier’s For dangerous system’ (consider phase- classification substances and mixtures out of substance)Article producer / Not required Not required Not required Not required Required REACH Article 33importer / supplier but check exception for but check exception for but check exception for communication²; SVHC articles with substances imported articles with articles with substances notification as of subject to REACH Art.7 substances subject to subject to REACH Art.7 1.6.2011; consider REACH Art.7 and explosive articles phase-out of substance ¹ Existing (‘phase-in’) substances ≥1,000 tonnes, R 50/53 ≥100 tonnes and CMR cat.1 or 2 ≥ 1 tonne per year ² If supplied downstream in EEA
  • 19. Main tasks as an importer/ manufacturerRegistration (substances on their own or in mixtures): Hasyour non-EU supplier appointed an OR,Compliance with restrictionsCLP by 1.12.2010 for substancesC&L notification (unless supplier-OR has registered usingCLP) first deadline: 3 January 2011REACH-compliant SDS update required to include CLPclassification & labeling starting 1.12.2010Outlook: Authorisation, substance will be permanentlyunder inspection, creates a strong pressure to substitute
  • 20. Main tasks as distributorCheck if your supplier is going to registerCompliance with restrictionsREACH-compliant SDS
  • 21. Main tasks as article producer/importer/supplierCheck if your supplier is going to registerMain issue: Article 33 have a system in place totrack SVHC and communicate downstreamCompliance with restrictionsCheck registration and notification obligation acc.to REACH Article 7
  • 22. Key concerns – grouping of issues Supply chain management concerns 1. Availability of chemicals after 2010 (sourcing) 1. Substances not covered currently by REACH work,? 2. Certain Uses not covered according to ECHA Use Discriptor System 3. Current (real) status of REACH work, outcome 2010 2. Other new regulations, obligations for supply chain (delivery side) 3. Structural changes in the market (both sourcing and delivery) 4. Need of internal process updates (both sourcing and delivery) Technical concerns in supply chain 1. CLP and REACH: how implement at same time ? 2. Need of updating IT support ?
  • 23. Structural changes in the market ? Solution ? You must survive regulations… or ???
  • 24. EU importer – registration necessaryAnnouncement from Shell:
  • 25. Topics to be covered Introductions Current status of REACH The role of supply chain in REACH and key responsibilities Alternative strategies Future of REACH and impact on supply chain Conclusions & summary
  • 26. Availability of chemicals ?Impacts ? What will happen with substances, which will not be registered on time ? No manufacture ? No import ? Enforcement ? By local authorities ? Different approaches ? ”Unequal markets ” ?
  • 27. REACH is about StrategyPreregistration Phase in status important Future development substances Future importer status Operations : future production decisionRegistration Which consortia to join? Do you want to have a leader position? Do you need to take a leader position?Rethinking your supply chain Buying EU vs non EU Discontinuing products Reformulation products Excluding applications
  • 28. Imported substances from non-EUcountries - Background Many importers have made pre-registrations for substances they import from non-EU countries Note: Many EU manufacturers act also as importers when they buy raw materials for their own manufacture To register or not ? Business decision based on several issues Cost, benefit for your business, independence
  • 29. Imported substances from non-EUcountries - alternatives If you register, in most case you will be ”Regular Registrant Especially if you are ”true” importer REACHLaw Registration Services available If you don’t register you need to know if your suppliers are REACH-compliant REACHLaw Supply Chain Audit Services
  • 30. Topics to be covered Introductions Current status of REACH The role of supply chain in REACH and key responsibilities Alternative strategies Future of REACH and impact on supply chain Conclusions & summary
  • 31. Substance Volume Tracking
  • 32. Need of changes in internal processes On sourcing side: ”Compliance certificate” Agreements: On delivery side: Information in supply chain Agreements ….
  • 33. Substance Inventory Managment System SIMSIdentification & monitoringSubstance volume tracking upstream &downstreamInternal use mappingSupply chain communicationCreation of notification documents
  • 34. Substance Inventory Managment SystemSIMS (only IT can manage it)
  • 35. Substance Inventory Managment System SIMSInterface between ERP & EH&SElectronic eSDS systemInterface with IUCLID5..
  • 36. REACH SVHC in articles management indentification & downstream communicationRequirements for substances in ArticlesSVHC in Article screeningSVHC Communication in the supply chainSVHC Candidate list proposals
  • 37. Substance first re-classified as hazardousand then identified as SVHC – What is thepotential impact on your EU customer? Cosmetic Ozone depleting EOL vehicles Products substances REACH Directive Young people at Directive Regulation (EC) Regulation 2000/53/EC work Directive 76/768/EEC No 2037/2000 1907/2006 1994/33/EC Chemicals Seveso II Hazardous Agents Directive Detergents Directive waste Directive 1998/24/ECCLP Regulation Directive 96/82/EC Exposure to 91/689/EC 1272/2008/EC 648/2004 carcinogens and Ecolabel Award mutagens at work IPPC Directive Biocidal scheme 2004/37/EC 2008/1/ECWaste Framework Products 1980/2000 DSD / DPD Directive Directive Export / import Directive VOCD 2006/12/EC & 98/8/EC Biological Regulation 67/548/EEC & Directives 2008/98/EC agents at work 689/2008 1999/45/EC 1999/13/EC Directive & 2004/42/EC Aerosol 2000/54/EC Health and Dispensers WEEE Directive RoHS Directive Pregnant and Safety signs at Directive 2002/96/EC 2002/95/EC breastfeeding work Directive 75/324/EEC women at work Water 1992/58/EC 1992/58/EEC Framework BatteriesGeneral Product Directive Directive Plant protection Ambient airSafety Directive 2000/60/EC 91/157/EEC Products Directive 2001/95/EC Protection of Directive 1996/62/EC mothers 91/414/EEC Ecolabel EU indicative Directive Regulation occupational 92/85/EEC PPE Directive 66/2010 exposure limit 89/686/EEC values Directive 2000/39/EC
  • 38. Other new regulations ?How to utilize REACH work and experiences REACH goes global !!! Turkey Japan Others
  • 39. Other new regulations ? Solution: Global Regulatory Monitoring Amendments to REACH and CLP Regulation REACHLaw will report the latest amendments to the REACH and CLP regulation with an explanation and of the possible business effect if any. SVHC monitoring service Authorization and Restriction processes Enforcement of REACH REACHLaw will report on the REACH Implementation projects initiated by the Forum and provide information on Forum meetings, resolutions and actions taken.
  • 40. Topics to be covered Introductions Current status of REACH The role of supply chain in REACH and key responsibilities Alternative strategies Future of REACH and impact on supply chain Conclusions & summary
  • 41. REACH (and CLP) go global – using registrationto meet other regulatory requirements We have not seen the real impact of REACH yet ! New regulations coming, affect…. .......
  • 42. Top key concerns – Conclusions Supply chain management concerns 1. Availability of chemicals after 2010 (sourcing) 2. Other new regulations, obligations for supply chain (delivery side) 3. Structural changes in the market (both sourcing and delivery) 4. Need of internal process updates (both sourcing and delivery) Technical concerns in supply chain 1. CLP and REACH: how implement at same time ? 2. Need of updating IT tools ?
  • 43. Questions ? Thank You !

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