Actio Corporation

REACHtracker: snap-on SaaS software for REACh Regulation

In mid-January of 2010, the list of “substances of very high concern” or SVHCs under the REACH environmental regulation in Europe nearly doubled – the list is expected to quadruple by the end of the year. Actio REACHtracker™ software leads the market in providing enhanced substance-level materials information management for environmental regulatory compliance under REACH in a modern, complex, multi-tiered supply chain network. A key REACHtracker differentiator is how it handles multi-level (BOM to chemical) data management and data roll-up throughout a global supply chain.

REACH regulation effects American companies who sell products into the European Union, or who would like to. The landmark regulation was effective as of June 2007. It's widely believed that a form of REACH regulation will become global in the near future.

Actio Corp has been leading the market in REACH solutions since 2007. REACHtracker is a SaaS solution with a growing client list of international companies who sell into Europe. For details, see or the site. REACHtracker enables global manufacturing companies to manage data for REACH - using automated data-screening at the chemical substance level and automated communications with suppliers and customers, as with a drip program that allows suppliers to log in and enter or update certain data. All this data funnels into a secure central database where, by permissions only, users can extract and add up-to-date information in a relational database format.

Exposure scenarios under REACH: what is Indecent Exposure?

First, What are exposure scenarios, and why are they important under EU environmental law? Do you do unusual things with chemicals -- or products that you buy? Customers must inform suppliers of unusual things they might do with a product after they buy it. These are known as 'exposure scenarios.'

An exposure scenario is simply an alternative possible use. A company might make a product, but the way their customer uses it might be totally unexpected. And if the use is unexpected, the safety and hazard communications around the product may not apply.

For example: If a paint company produces exterior paint, it tests and approves the product for use outdoors. The product will come with certain health and safety warnings - which account for respiratory protection with plenty of ventilation. If, however, the customer uses the same paint for purposes other than external paint, the testing and approvals become irrelevant. If used in a closed confined space, for example, the paint fumes may be toxic and provide a serious inhalation hazard. If a large paint manufacturer sells exterior paint to a customer, and the customer then sells or uses the paint for a different use, say indoor paint, then the onus is on the customer to register that usage with REACH authorities.

The manufacturer can register possible exposure scenarios, if properly informed of them by customers.

Downstream Users of chemical substances
As a user of a chemical or substance (Downstream User) you should inform your suppliers about your use of it if you want the supplier to consider your use in relation to his REACH registration.

Before informing your supplier, you are advised to:

- check the use mappings prepared by your industry association
- check communication from your supplier about the uses he intends to cover
- assess the use and fulfill the related duties - such as registering - yourself

The advantage of communicating your use to your supplier is that your conditions of use are then more likely to be covered by your supplier’s Exposure Scenario, as the registrant of the substance will have to take account of your use in preparing the Chemical Safety Assessment.

You then can expect your use to be an identified use and have an Exposure Scenario covering your conditions of use, unless the registrant cannot support the use. If the registrant cannot support your use for reasons of protection of human health or the environment, both the
Downstream User and the European Chemicals Agency need to be notified. You need to provide your information in writing to your supplier on both the use and the conditions under which the substance is used. If you do not communicate your use and it is not covered by your supplier’s Exposure Scenarios, you will eventually need to prepare a Chemical Safety Assessment yourself once the substance has been registered.

Timing is everything
The final deadline for the pre-registration of certain chemical substances and high volume manufacturers and importers is on 30 November 2009. This deadline applies to companies within the first 6 months of manufacturing, importing or using* a phase-in substance that needs to be registered by 30 November 2010.

A phase-in substance needs to be registered by a manufacturer or importer by 30 November 2010 if it is:

• manufactured or imported in the European Union in certain quantities/year
• classified as carcinogenic, mutagenic or toxic to reproduction (category 1 or 2) and manufactured or imported in the EU, in certain quantities/year
• classified as very toxic to aquatic organisms which may cause long-term adverse effects in the aquatic environment (R50/53) and manufactured or imported in the EU in certain quantities/year

(*) using means producing articles, or importing for the first time an article, containing a phase-in substance that requires registration

If your product gets stopped at customs heading into the EU, detained, then turned around and deported to the tune of an embarrassing PR disaster starring your company -- you probably forgot to register something in your product or something from your supply chain with REACH.

For more information, try contacting the US-based REACH Experts for American Manufacturers at Actio Corp. Actio is the maker of REACHtracker™ and MaterialDisclosure™ software for environmental regulatory compliance.

Note: The process of gathering exposure scenarios as well as substances coming up through your supply chain can be automated going forward, and the investment does not have to break the bank. Automation can save time and money, while creating leaner processes.

2. Upstream, downstream in a supply chain flow - which is which?
The 'upstream/downstream user' terminology snags some people. Trick: imagine the manufacturing supply chain as a river. You make paint, seal it in a bucket, put it in the stream, and it floats along (downstream) to the next person or manufacturer. Anyone who uses something you make is 'downstream' from you. Anyone who sends you stuff you use is 'upstream' from you.

European Chemicals Agency (ECHA) opens web pages on Restrictions
On November 5, 2009 ECHA announced a new subsection concerning restrictions. The new web pages describe existing restrictions as well as the procedure for new restrictions. If a substance poses an unacceptable risk to health or to the environment, it can be restricted under the Restriction process described in Title VIII of the Reach Regulation. The Restriction will operate as a 'safety net' to manage risks that are not addressed by the other REACH processes. Proposals for Restrictions can be prepared by Member States or by ECHA on request of the European Commission.

This new Restriction subsection on ECHA’s site provides easy access to core information on restrictions to Member States Competent Authorities and stakeholders. It facilitates access to relevant guidance documents and to the submission format used by authorities when a Restriction proposal is being prepared. The subsection also explains the main actors and steps to be taken to arrive at a new or modified restriction. REACH foresees the restriction process will regulate both the manufacture and the placing on the market (or use) of certain substances if they pose an unacceptable risk to health or the environment. The restriction bills itself as a safety net to manage risks that are not addressed by the other REACH processes.

ECHA says: Any substance on its own, in a preparation or in an article may be subject to a restriction if it is demonstrated that risks need to be addressed on a Community-wide basis. A restriction dossier needs to justify that the proposed restriction is the most appropriate risk management measure to address these risks.

Get feedback on your company's situation, gratis
Not every company faced with REACH or other regulatory compliance needs a robust software module to manage it. Smaller companies, for instance, can often get by with a very organized spreadsheet repository. Ask a purveyor of REACH-related software to please survey your situation and provide a no-obligation evaluation.

Ruminations from blogger Chris Jellen
'The U.S. Environmental Protection Agency can't handle the truth,' says Chris Jellen, in his blog on Supply Chain Data Management. He means that at the EPA shouldn't shoulder the onus of monitoring the 80,000+ chemicals flying around the modern industrial landscape. Jellen cites leaders at the EPA, the Center for International Environmental Law in Washington DC, the American Chemistry Council and at Actio. Of particular interest is the EPA's recent call for chemical information management.

See the blog at:

REACHtracker is supply chain data management for REACH regulation

Progressive technology can evaluate your product data library and link raw materials to the finished goods. Knowing the ingredients empowers your organization. Learn how to break down ‘siloed’ enterprise data, so information can be securely shared, organized, and analyzed. Learn about Product Stewardship – from experts in the field – Actio Corp is a good example – and ask them questions! Solving REACH is easier and even desirable (from a CSR point of view) using the right tools. Find out how REACHtracker differs from older methods such as traditional document management either in a CMS or - oh no - pieces in a folder full of spreadsheets and emails. Ask about REACHtracker™ software, is a good place to start.

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