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You Can't Go it Alone

By Michael Wurzman

“You can’t go it alone” is an adage that becomes ever more true as we address the data issues of REACH compliance.  Success in achieving compliance requires us to overcome the supply chain data reporting objections that are blocking our compliance efforts.  Let’s take a closer look.

 

Suppliers continually say that everyone is trying to get the data collected in a different way. And, to make imatters worse, their customers tell them: “if you want the order, you must supply the data and enter it manually into our portal at your own expense”.  It’s no surprise, then, that a very common supplier complaint is; “If I sell a part to three companies, I need to enter it three times. This is crazy, it’s a waste of time and money. There has to be a better way.” 

 

There is a better way. But as always, it is much easier said than done. Let’s take a look at some of the activities we need to undertake to make the better solution happen. The first activity is determining a common data structure for everyone to use.  The majority of our OEMs already have PLM or other systems to help control and manage their BOMS and drawings.  But only agreeing on a common structure can meet a wide variety of needs from different companies - not to mention the needs of suppliers who must use the data across various industries. 

 

The second activity is developing a common training, so all companies understand the data requirements; how to collect real data; how to enter the data they are required to share; and how to use the common exchange tool so the data is usable and actionable by their customers.  This is a very large and difficult task to do right.  If not done as a joint effort, it’s easy to multiply the costs of duplicative training efforts along the supply chains. 

 

To achieve and coordinate these activities, we need an industry-wide collaborative effort - one that addresses not only the needs of the OEMs , but of all companies shipping product into the EU that need REACH compliance. Furthermore, this type of collaborative effort must be done transparently in order to meet federal anti-trust guidelines and to ensure that all companies, regardless of size, have the ability to participate and provide constructive support to achieve our common goals. 

That why we all need to participate in the AEM Market Access Pathways program. It allows us to jointly develop data structures, exchange tools, participate in training and facilitate the collaborative efforts we need to make compliance a realistic goal.  Working together, we can help our suppliers to “do it once, do it right and do it now”, thereby making compliance a 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