The REACH Data Dilemma: Part 2
By Michael Wurzman
Being able to efficiently move data along supply chains, as addressed with CDX (Compliance Data Exchange), is only part of the solution. Having easily usable data is the critical second part. The old computer adage, “GIGO – Garbage in Garbage Out” applies here as well. We must train our supply chains to use a uniform and consistent data creating method at all levels, so it can be effectively analyzed for REACH compliance and other regulatory needs.
Let’s start by identifying key data objectives to facilitate REACH compliance and beyond.
First we need a common data structure to facilitate data exchange with in-house PLM, ERP, design and data analysis systems. We need a common data structure to facilitate data exchange with in house PLM, ERP, design and data analysis systems. The proposed structure will be extensible to address the coming regulatory needs. And it will take into account the proposed PLM future data requirements.
Second, for data analysis, the use of common rules for naming materials and components should be implemented, so we can do plausibility evaluations of data for quality issues. As an Industry, we can define these rules in a way that will work cross-industry. While not a major issue today, it will be one in the future when we are required to “enhance” our data set.
Third, the use of standard templates for materials, e.g. metal alloys where the product is defined in industry norms and standards, makes sense. It would simplify the data entry and allow material suppliers to attach the applicable norms and standards, as well as eventual greenhouse gas or other legislated reporting requirements from a smelter or steel mill level.
Fourth, another key concern is the use of actual substance content in material definitions. Use of substances classes will become a problem in the future. With REACH, individual substances can have restrictions placed on their use. We need to work from a unified list of substances based on the C.A.S. (Chemical Abstract Service) system. If we do so, generics will be controlled by the system for common items such as basic polymers without additives. This will standardize the data collected and allow for proper automated REACH compliance reporting.
Also, if we track and identify which data-entering persons have been trained, we will be better able to concentrate our educational efforts, which is the fundamental key to receiving good quality data.
We know moving forward there are additional standard descriptions for data elements that will be needed. Working as an Industry, we can create the databases needed to standardize reporting and provide the maximum ability to utilize data for compliance, sourcing risk reduction, product planning and long term cost reductions.
AEM is guiding us forward, and with our input will be able to provide the guidance to the data systems development needed to protect our interests, integrate compliance requirements, simplify our future reporting, and help us save money and reduce potential supply chain risk.