IT WASN’T THAT LONG AGO that most chemical companies had a handful of people who appeared to be blessed with an infinite knowledge about substances.
If you wanted to manage hazardous materials along the full life cycle—from raw material acquisition to production to distribution of products around the world—they were the go-to folks who knew how to ensure companies stayed in compliance. If you needed to know about the regulations for using Acetone in South Korea, for example, you could turn to an in-house expert and get the information you needed. If you had concerns about a product that was designed to specification for China, running foul of interpretations by authorities in another part of the country, then there was an obvious door to knock on.
Like walking rulebooks, these individuals just seemed to have all the answers. If they were particularly experienced, they could even guide their teams through the extensive cultural differences that lie behind detailed regulatory requirements and interpret them correctly.
But times change. Age creeps up on us all—as does technological development and macroeconomic pressures. Many businesses in the chemical-producing and manufacturing value chain—including the downstream and chemicals sectors—are at the point where their valued experts, namely the baby boomers with years of experience, are retiring and leaving younger cohorts without the same degree of sagacity and experience.
A MORE SYSTEMATIC APPROACH
The experience retiring workers take with them is not to be dismissed. Global regulations have exploded in both volume and complexity over the past few decades—a trend that began around the time many of these imminent retirees were just starting out. They had the luxury of learning each regulation as it came up, adding to their knowledge incrementally.
Now, a newcomer faces what seems like an impenetrable thicket of tangled rules and regulations. By necessity, expertise becomes more spread out, and the company loses that totemic resource: the person who knows the regulations and business inside out.
But that level of expertise is not to be overestimated either. Knowledge doesn’t get old, but the application of that heritage knowledge changes. Some Japanese regulations have been in force since the 1990s but may now be affected by overarching chemical control laws. What’s more, as any number of businesses will point out, overdependence on one individual or a small team of specialists, and their collective knowledge, is a risky proposition. Supporting systems, documentation and processes are all required.
This is what many firms have been implementing for the past 10 years or so. The looming loss of specialists need not, therefore, be as terrifying as it first appears.
PRODUCT STEWARDSHIP SOLUTIONS
As dependence on individual knowledge has declined, reliance on technology has increased. As careers have progressed, so have ways of accessing vital data and making it available to those who need it—a transformation that continues to evolve through continuing advances in technology. Even the past five years have seen a dramatic change in the way we gather, collate, assess and report vital data.
In addition, what junior colleagues lack in worldly experience, they often more than make up for in technological savvy. They have the opportunity to catch up fast by finding the answers to specific questions as they arise. Automated, instantly accessible Product Stewardship software is an effective solution to the departing of human expertise. Particularly as the industry comes to terms with the idea that Product Stewardship covers significantly more than just hazard communication, and links together disparate functions including manufacturing, marketing and legal.
It is a little more complicated than that. Product Stewardship is complex. If you don’t ask the right question, you won’t get the information you need. So, you still have to understand what countries you’re doing business with and what regulations apply to your products.
That in turn has implications for the systems themselves, which must be designed to support less-experienced colleagues and prompt them to search for the necessary information. The systems must integrate seamlessly with key enterprise systems like Enterprise Resource Planning and Product Life cycle Management so that no one’s time is spent simply shuffling data from one spot to another. Additionally, they must apply information in the way that a new user cohort needs and expects, for example, taking a single substance and discovering in a single search how it is regulated around the world.
What’s more, people become more educated by virtue of more information being available to them. Keeping up with the growing sophistication of users is an essential component of any system. Consider that net native millennials and Generation Zers who will comprise 75% of the workforce by 2025, and that need for smart, intuitive systems becomes more critical.
TRANSLATING ENVIRONMENTAL HEALTH, SAFETY & SUSTAINABILITY
But this is more than just a case study on the changing relationship between people and tech. This is all taking place against a backdrop in which global trade and transport of industrial products is becoming more closely monitored while new trading patterns are emerging but ill-defined. What’s more, EHS legislation is becoming simultaneously stricter and more complex—but not necessarily more clearly defined.
Take the requirements for the Safety Data Sheets and Label as an example. A country will translate verbatim the UN GHS Purple Book leaving phrases like “Some competent authorities may require ‘this’ for the SDS and/or ‘that’ for the label,” but there is no clear requirement in the regulation. Another example is occupational exposure limits (OELs). Say a country sets its OEL for selenium compounds, but do they include selenium, the element, in that? Or is it exclusively related to its compounds? Sometimes, the country will refer you to the competent authority to decide without pointing out who that competent authority is or how to contact them. To make it more challenging, the competent authority for one issue may not be the same competent authority for another one.
These challenges that sound relatively minor on paper become significant headaches when translated into vessel freight that cannot be unloaded until all the labels and product safety documentation is examined and confirmed. Any mistakes and port fees soon rack up as ships are stuck in dock unable to unload while potentially lowering the value of the trade in progress. More than that, it will almost certainly lead to future delays as port authorities take note of, and apply watch notices to, importers with a history of poor paperwork.
TAKING BACK CONTROL
There is a direct connection between effective Product Stewardship and just-in-time manufacturing, frictionless trade and seamless supply chains, which are all demands of the modern global economy. As geopolitics continue to upend previous assumptions about global trade and introduce major notes of uncertainty over which businesses have limited control, it is critical to minimize disruptions by aligning regulatory expertise and software systems to streamline business processes.
Mary Rudolph is now retired. She worked on international Environment, Health, Safety & Sustainability projects for more than 25 years, including technical and business implementations of authoring services.