Malcolm Pollard, CEO of Baytouch Ltd, discusses the need for robust management system processes to safeguard supply chain chemical compliance. He notes the increasing complexity of global regulations and challenges of managing supplier information and changes. ProductTraq, Baytouch's product regulatory data storage and management solution, aims to automate otherwise manual processes for collecting, validating, and updating supplier documentation to facilitate compliance. When implemented properly, such systematic approaches can help companies increase response rates, improve change management, and lower risks to support best practices and sustainability.

1. Safeguarding Supply Chain Chemical Compliance with
Robust Management System Processes
Malcolm Pollard – CEO, Baytouch Ltd
©Baytouch Ltd 2014

2. “Why do people hate the word 'chemicals'?”
With acknowledgement to Dr Mark Lorch and his Four
Thought piece on BBC Radio 4 on Wednesday 27 November
http://www.bbc.co.uk/news/magazine-25103941
Or download the Four Thought podcast
http://downloads.bbc.co.uk/podcasts/radio4/fourthought/f
ourthought_20131127-2100a.mp3 (UK only)
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3. Agenda

Baytouch

The regulatory affairs climate

Managing Supply Chain Chemical Compliance

Solutions
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4. About Baytouch

Based in East Lancashire with clients in the UK, EU and N
America

Cloud-based IT provider of regulatory management and
compliance solutions:


PSMmonitor: Workplace Safety - EHS and PSM in high hazard
chemical handling sites


ReachSuite: For company Lead Registrants and REACH Consortia
with SIEF Management / Communications, SIEF cost allocation
and sharing with online Letters of Access Contracts
ProductTraq: Product regulatory data storage and management
solution
Common thread is “robust”, information-rich change
management solutions
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©Baytouch Ltd 2014

5. Clients and Partners

Large, influential trade associations leading REACH
registrations


Lead registrant and chemical-using corporate clients


Kemira, IFF, Kimberly Clark, Shell, Eastman, Arkema
Consultancy Services and Expertise Partners


Lower Olefins, Higher Olefins, CONCAWE, European Aluminium,
Polyester Monomers, Petrol Additives, Grease Thickeners, etc.
Caleb Management Services, Ernst & Young (Netherlands),
Jongerius Consult, Penman Managed Services, WSP
Environmental
Cloud-based solutions with tens of thousands of users and
<2 hours unplanned downtime in the last 365 days
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©Baytouch Ltd 2014

6. Chemical Industry Trends

1970s

Bulk chemical manufacture predominates

Small number of large companies making everything
―

Centralised regulatory affairs resource
1980s



Speciality chemicals
Post-Bopal, Responsible Care and Process Safety Management start to take hold
1990s



Downsizing/rightsizing to adjust to the rise of the east
Quality Management / Assurance, Responsible Care et al become entrenched
2000s

MBOs/MBIs, divestments and the emergence of VC power

Industry fragmentation to VCs resulting in lots of small companies making “a few things”
―

Loss of technical resource
2010 onwards

Advent of REACH and global regulatory uptake – the decade of the Regulatory Affairs consultant..?
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©Baytouch Ltd 2014

7. Chemophobia!
Orange Juice
E300 – vitamin C by
any other name
• There is no such thing as “chemical-free”
• SO DEAL WITH IT!
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8. 8
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9. 9
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10. “… beginning in January 2015, it would require
suppliers to disclose ingredients online for items
sold at its stores,, and In January 2016, it would
begin to report publicly on what progress is being
made.”
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©Baytouch Ltd 2014

11. REACH Article 33 and Procurement
Standards as Drivers

“..Knowledge is in the hands of the supplier,
- power is in the hands of the customer.”

Customer drivers 
Reduce business risk

Minimise environmental impacts

Improve corporate image as a global citizen
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©Baytouch Ltd 2014

12. Regulatory Needs & Challenges

Objectives:


Compliance assurance


Speed to market
Risk management
Dependencies:


Supplier qualification: e.g. questionnaires


Management of all compliance declarations from suppliers
Coordination of all information to produce a declaration of compliance
for the finished product
Challenges:

Complexity of global requirements

Change management of requirements

Change management of declarations
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©Baytouch Ltd 2014

13. Processes are key!

Supply Chain Compliance Transparency

What Information required to validate product compliance

How does THIS translate to product compliance

How is it updated / maintained

Benchmarks, supplier trust rankings, KPIs, etc.

Processes to ensure all compliance information is
collected, validated, stored and current

Management of Change
Collect Supplier
Documents
Produce
Compliance
Documents
Review Certs /
Declarations
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Manage Change
©Baytouch Ltd 2014

14. Process status

Processes are frequently manual

Often within a small regulatory team

Supplier information formats inconsistent – manual
and/or electronic

Periodic updates are often required, which may not be
automatic!


“We bother them until we get what we want…”
Consolidated overview of compliance status sometimes
hard to discern – and metrics not easily acquired
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©Baytouch Ltd 2014

15. Process aspirations

Collect, store and update supplier information as well
as testing results would be a start

And flexible enough to collect supplier data in all sorts of
formats

Management of Change would keep the business in
step with requirements

Information shareable internally and with trusted
service providers

Compatibility with enterprise systems is desirable

De-skill as many processes as possible to free up high
value regulatory expertise
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©Baytouch Ltd 2014

16. Dedicated to the Regulatory Team
– or the hard-pressed individual!

As the list of chemicals of concern grows,


What will your REACH compliance statement actually mean?

Will you have sufficient information to support your Article
33 declarations?

How will you deal with the changes to the Candidate List?


How will you check that your business is on track?
What will you do if something goes wrong?
SVT – how will you efficiently and accurately capture
substance import volumes
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©Baytouch Ltd 2014

17. ReachSuite evolved into ProductTraq
ReachSuite
ProductTraq
Large scale Substance
Management across in-house
teams and Service Providers
Product Management portfolio –
substances, mixtures, polymers,
articles (in-house teams and
Service Providers)
Document store and Proprietary
Information for dossier compilation
Store and manage declarations,
SDS, supplier/SC communications
SIEF Portal - large scale
communications, surveys and
information exchanges to/from
SIEF members
Suppliers Portal - large scale
product formulation and
declaration requests to/from
suppliers
Action tracking, change
management and version control
Action tracking, change
management and version control
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©Baytouch Ltd 2014

18. ProductTraq sector functionality
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©Baytouch Ltd 2014

19. Bill of Substances

Chemicals by CAS, EC or EC name

Total substance volumes across all Products

Also accommodate articles, packaging and other
unclassified product volumes

Exclusions for OR-managed substances

Automated comparison against SVHC Candidate List,
SIN List or any other defined list and become proactive
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20. Formulations - supplier data entry
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21. IT Integration Options

“Open” interfaces for integration



Excel/CSV file import and export at a simplistic level
Web Services Description Language (WSDL) for more
comprehensive integration with ERP
Secure IT Platform

Secure Virtualised servers, SSL connections

Hashed and salted password encryption

Backups at ISP, at Baytouch

Cloud solutions since 2008

<2hrs unplanned downtime in last 365 days

100,000+ registered users supported
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©Baytouch Ltd 2014

22. Conclusions

Systematic approaches to request and receive supplier
information:

Increase response levels to information changes

Improve change management

Support best practices and demonstrate leadership in
chemical handling management

Institute Compliance dashboard leading to supplier
benchmarking

Lower risk which promotes corporate sustainability and a
positive image
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©Baytouch Ltd 2014

23. Questions
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