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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.

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