Steps to REACH Compliance

In a previous blog, I observed that the requirements of the European Union regulation known as Registration, Evaluation, Authorization and Restriction on Chemical substances (REACH) are complex but noted that it represents a step in the right direction for the manufacturing industry as well as the global environment. (See: REACH Is Not Overreaching.) Since REACH is essentially here to stay, I will present in this blog steps companies can take to ensure compliance.

Today, products nearly universally compete only on the properties I mentioned last week. What we compete on gets researched, optimized, improved, and cost-reduced; what we do not compete on does not. There is enormous inertia to researching, optimizing, improving, and cost-reducing environmental and human health performance properties, not only at the individual company level but also at the fundamental industrial infrastructure level.

How many product environmental engineers and product environmental cost accountants are being graduated by top universities every year? How many positions are opening up for these people in manufacturing companies? How many manufacturers are actually measuring and competing against each other on environmental performance properties? Nearly none in all cases.

Because there has never -- until recently -- been a requirement to address environmental performance in products, there is virtually no capability within manufacturers or academia to do so. This is why dealing with these regulations is so difficult: There are few experts, standards, and methodologies developed to do so.

This is why, as more and more information is released about chemicals due to REACH and other copycat regulations, and your customers and NGOs and governments start taking more and more action based on their review of that information, you need to prepare. Academic institutions are starting to, but mostly at a very basic level: "Green chemistry" courses are being taught to chemists. This is a long way from producing the expertise needed in the article manufacturing world.

On a practical note, Douglas Alexander asks in a recent post: "How do we even begin to resolve the multitude of REACH implementation and management problems?" (See: The REACH Conundrum.) More and more chemical substances will be removed from commerce. It is up to you to make sure that you know which chemical substances are used in your products, and which of them are at risk now and in the future. Fiduciary responsibility to customers and shareholders demands that corporate risk assessment cover environmental regulatory requirements to the extent they are revenue and liability risks. Taking a reactive approach and being surprised by each and every new addition to the SVHC list is, therefore, not a "best-practice"!

In that light, here’s a set of steps to consider:

1. Collect full material disclosure from your suppliers. Simple declarations and certificates are useless. If your suppliers insist on continuing to provide this level of information in light of the changing marketplace, make sure you understand why they’re doing it and whether you can move to a different supplier that will give you what you need.
2. From this information, produce a list of the chemicals that are used in your product.
3. Prioritize the chemicals in terms of toxicity, potential for exposure, amount, and potential for future regulation.
4. Understand why those chemicals are used.
5. Understand what it would take to replace these chemicals in your product.
6. Assess any marketing or competitive value this could have for your company.
7. Make a plan for what to replace, how, and why.
8. Get it funded and move ahead.

I’ll be the first to agree that this is easier said than done. But the train’s left the station, and it’s gathering steam. Unless you prepare to jump on you’ll either miss it entirely or perhaps get run over.