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The “H” Factor

By Harvey Stone

“I’m too busy making products.”

My shareholders care about cash – not compliance.”

“We’ll get to it next quarter”

Over the years, I’ve heard many variations on the above themes in regard to compliance with RoHS, WEEE, ELV and other environmen­tal laws. Typically, the executive or manager uttering them is stating what he or she believes. But to­day, nearly seven years since the European Union enacted REACH, these statements reflect what I call the “H Factor,” where “H” stands for “human” and where “human” refers to our universal ability to make er­rors in judgment.

Given REACH’s risks for AEM members, it’s worth identifying three errors in judgment.

  1. Underestimating

It’s not difficult to grasp the state­ment: “REACH is 849 pages long, plus there are also hundreds of pages of guidance documents and is the world’s most comprehensive environmental regulation aimed at protecting human health and the environment.” Nevertheless, at a time when two substance registra­tion periods have already passed and EU nations have beefed up their enforcement strategies, it seems that too many OEMs are under-estimating both REACH’s financial risks and also the com­plexity of implementing a REACH compliance management process.

  1. Resisting

Nobody likes to be forced into a whirlwind of activity – especially when there is no perceived busi­ness value. That said, the old ex­pression “arguing against reality” applies. The reality is: REACH is here to stay. REACH-like laws are expected to spread to more than a hundred global jurisdictions. And compliance with REACH is part of today’s business paradigm. Fur­thermore, resisting REACH blocks out the very strong compliance val­ue proposition: garnering competi­tive advantage vs. slower-moving competitors; developing deeper levels of supplier partnerships; and having in place the full material dis­closure that will allow companies to comply with future requirements at a fraction of the time, cost and stress.

  1. Procrastinating

Some senior staff clearly grasp how big and complex REACH is. But, understandably consumed with running their businesses, they postpone freeing up the financial or human resources. Consequently, they run the non-compliance risk of products being blocked or recalled from the EU market.

Predicting the Future

Here’s a very safe prediction – no crystal ball needed. In the next five-to-ten years, some AEM members will lose customers and revenue because they under-estimated, resisted or procrastinated when it came to REACH compliance. Meanwhile, other AEM members will thrive in the new business land­scape because they implemented REACH-compliance processes early and thoroughly.

What’s the difference between those two categories of compa­nies? While there are many fac­tors, one of the most important is the speed with which AEM mem­bers train their staff and supply chain about REACH. In that regard, AEM’s REACH training process is a solution with the breadth and depth to offset the H-Factor.

So, don’t under-estimate the power of this very unique, very af­fordable and very transparent train­ing process. Don’t resist assign­ing resources for the training. And don’t procrastinate getting started.

Set in mo­tion a REACH-compliance process and value proposition.

Article Library

  • Article 33 obligations under REACH; The law of unintended consequences…or were they intentional?
  • Reducing REACH Risk Management
  • You Can't Go it Alone
  • The REACH Data Dilemma: Part 2
  • The REACH Data Dilemma: Part 1
  • The Case for Training
  • The Importer-of- Record and REACH Obligations
  • The “H” Factor