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The Case for Training

By Michael Wurzman

“You don’t know what you don’t know”. I can’t begin to tell you how many times I heard that from my dad growing up. I was always challenged to think in those terms in conversations, so I could put in context my comments as well as better evaluate what I heard. As we face the immediate need to become REACH compliant, I real­ize how those words are critical to how we deal with our supply chains. For many the entire subject of REACH is new or possibly known only in snip­pets of what it re­ally requires. Few have actually studied the requirements and know what it means to be compliant, let alone explain it to their suppliers.

To become compliant we need in­formation from our supply chains, and must integrate it with what we do, so we can accurately as­sess and report our compliance as required by the regulations. To succeed, we need to collect accu­rate data, in a usable format, prepared in a consistent manner, so it can be easily evaluated and used. Having this oc­cur through one tier of a supply chain is tough, but we need it to happen all the way from the basic material suppliers to the OEMS, anywhere from 2 to 15 lev­els deep.

This only can happen with indus­try common content, delivery and tracking of training. Several key factors must be addressed to as­sure success through training.

First, training must be proactive. Training needs to occur before the data is collected, created or distrib­uted, so the individuals involved know what they are doing, and can do it right the first time. It is less costly to learn to do it right, than do it wrong and have to retrain then resubmit.

Secondly, training needs to be easily accessible, engaging, inex­pensive and measurable. Basic awareness of what we don’t know needs to be free and easily avail­able. Until we understand the risks of not getting trained it is hard to justify spending time learning. Training is most effective when it is engaging, entertaining and infor­mative. We learn best if our atten­tion is being held, an ever increas­ing challenge in our interactive me­dia world. Costs need to be kept to a minimum to eliminate financial barriers to training. We can’t afford to add costs to our supply chains without increased value.

Finally training must be measur­able. Both in terms of continual improvement of materials, but also so we can track training at all tier levels of our supply chains. If you can’t measure it, you can’t improve it.

Having a supply base trained be­fore supplying data, will im­prove initial data qual­ity, providing savings by eliminating the re­sources needed to train suppliers and by reducing the costs of rejecting and recol­lecting data. AEM has helped create a training process, with engaging materials, deliverable in a cost effective, efficient, and measurable way. Participating in this process will help us implement our REACH compliance programs quickly and cost effectively.

Article Library

  • 2017 IMDS and Chemical Reporting Summit
  • 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