The landmark European Union regulation authorizing the creation of the European Chemicals Agency (ECHA) over 10 years ago ushered in regulations that have revolutionized the way chemicals are produced, tracked and distributed throughout the European Economic Area (EEA) and worldwide.
The regulation known as the Registration, Evaluation, Authorization and Restriction of Chemicals (REACH), is foundational to the ECHA mission of promoting chemicals legislation “for the benefit of human health and the environment, as well as for innovation and competitiveness.”
More Stringent REACH Obligations
REACH has been in force since 2007 but has gradually introduced greater substance registration obligations over time. In particular, the annual volume thresholds triggering substance volume registration obligations dropped from 1,000 tons annually in 2010 to 100 tons in 2013. In 2018 the annual threshold will drop to 1 ton. That is, every substance in any imported or manufactured product, whether a pure substance, or contained in mixtures or raw materials, must be reported and registered with ECHA once the annual one ton threshold is reached. The tracking, analyzing and reporting substance volumes is known as Substance Volume Tracking, or SVT.
What people are saying about SVT
As I travel throughout Europe and other regions, I continue to get feedback from our customers about what they are doing to address these evolving, more demanding SVT requirements. Here is what I’m hearing:
“Yes, it’s a hassle, but it’s worth it!” Product compliance and Product Stewardship professionals believe in the REACH mission. Although REACH compliance is sometimes organizationally tedious and costly, our clients believe that tracking of substance volume and the corresponding registrations is necessary to protect human health and the environment.
“We are getting by with current systems – for now.” Most enterprises are extracting composition information from their material database and volume data from their ERP into third party tools like Microsoft Excel and Microsoft Access. With this approach, enterprises generate volume reports as infrequently as once per year, sometimes as often as once per month.
“Although we are getting by, we have concerns.” Our research indicates that about 20% of chemical enterprises are not satisfied with their current SVT solutions. Current processes are often inefficient and many managers have concerns about accuracy.
“[Many] are worried about 2018.” With the reporting threshold dropping to 1 ton in June 2018, the frequency and complexity of substance reporting will increase. Enterprises will need to run volume reports monthly at a minimum, and they need up to date volume and substance data to ensure they are accurately tracking substance volume levels. Some are worried – about 20% of enterprises feel unprepared to meet these increased demands.
Not just an EU REACH issue
Other regulations require the accurate and timely monitoring and analysis of substance volumes. Examples include Korea REACH, SEVESO, Tier II reporting in the US and others. Accurate, efficient and timely SVT is becoming a universal requirement.
SVT: A universal requirement.
Enterprises in Europe and elsewhere are taking a hard look at optimizing their infrastructure and processes to address growing SVT demands. These strategies include organizational changes, as well as targeted investments that help enterprises drive towards a higher level of performance – what we at Sphera refer to as Operational Excellence.
Do you have your own thoughts on SVT or REACH compliance you would like to share with Sphera and your colleagues?
Do you want to learn more about what we at Sphera are doing to address the SVT needs of our customers? If so, feel free to contact us.