With the REACH registration of high volume and hazardous chemicals now complete, many companies will now be turning their attention to the next phase of compliance which involves the production and delivery of Safety Data Sheets. Malcolm Carroll reports.
To comply with REACH, any company involved in importing and distributing oil to and within the EU will need to ensure the direct delivery of Safety Data Sheets (SDSs) and associated documentation to customers. They will also need to ensure SDSs are kept up to date, that customers can provide validation of their delivery, that they are using the most current SDSs throughout their organisation and that they have sufficient audit capabilities.
To achieve compliance in this area is a huge administrative challenge and could also prove incredibly costly. As SDSs are needed at every stage of the supply chain, this issue will impact thousands of companies.
New methods of delivering SDSs and associated documents will be required as traditional methods will prove unacceptable, expensive and they will not be robust enough to meet the REACH compliance requirements.
REACH compliance insists SDSs must be supplied directly to the customer so there are some obvious problems with current working practices in this areas. If we look at each of in turn, there are some very real challenges.
- Email does not guarantee or record proof of delivery without significant time, effort and cost and obviously does not physically replace old, out of date versions of an SDS.
- Post has the same problems as emails, adding further costs and time with stationary, postage and administration.
- Placing documents onto a website simply will not suffice as it provides no proactive delivery and is already rejected by REACH.
Nor will existing methods help with the intent of REACH, as customers will not be alerted to any changes in the SDSs, multiple recipients are not easily managed and there are no standards in terms of the media on which the SDS is held, making easy and consistent access difficult. All of this results in either significant additional costs for suppliers or the possibility of errors leading to non-compliance with the regulations.
So the issues facing companies are significant and there are many questions that companies now need to address. How do they fully comply with the legislation in respect of the delivery and receipt of SDSs? How do they maintain their operations and ensure only the use of current information, and provide consistency across all operational areas? How do they effectively audit, internally and externally, and prove the delivery, receipt and access of critical information by customers? And, how do they address possible legal action should it arise?
It has become clear recently that many companies now need to look at this aspect of REACH legislation. This year is starting to see a high number of revised SDSs entering the supply chain and keeping track of what has been sent to which customer and ensuring 'delivery' is bringing new challenges.
Companies are seeking ways to establish both a method of complying with legislation in communicating with their customers and an effective approach to their internal operations in respect of SDSs.
REACH Delivery is a new industry-wide SDS delivery service aimed at alleviating the headaches around REACH compliance concerning the delivery of SDSs and other documents. As a secure online service it facilitates the electronic delivery, receipt, control, update, audit and tracking of SDSs in line with the regulations.
REACH Delivery automates the entire delivery process, monitoring, tracking and reporting on all documents sent to customers. It retains a delivery status for documents sent, alerting users only when they need to follow up. Any document updates are automatically identified and the new SDSs replace any versions previously sent, alerting customers and staff to it.
Documents from all of a company's suppliers are all stored in an electronic database, allowing users a single consistent point of access for the latest version of a SDS. Any documents that a user chooses to store locally on his PC are also automatically kept up to date, so that it is possible to work online or offline.
REACH Delivery is free to use, with an optional 'pay as you send' area for users wanting to send documents externally, who will then pay a 'per document' fee. All that is required is a set-up and registration process, and then users can send securely the latest SDSs and other documents to their customer's desktops and receive proof of delivery. Recipients always use the service completely free of charge and users can also send documents free of charge internally to ensure that the latest SDSs are being used across an organisation.
The service operates on a 'many-to many' basis, allowing companies, no matter where they are located, to be able to manage and automate the sending and receiving of SDS, and other documents and messages, within a fully secure and audited environment. It is international and multi-lingual as well as being easy to use.
In addition to the fact that REACH affects companies throughout the world, similar legislation is now being considered in other countries, most significantly in the US. REACH Delivery has been designed to meet the requirements of new international legislation as and when it is required.
The system already functions on an international basis. Non-EU firms can use it to comply with REACH by securely delivering SDS to their customers in Europe. They can also use it outside of Europe and in their own countries, as it supports the delivery and receipt of SDS and any other documents worldwide, or to distribute SDSs free of charge throughout their company.
There is no doubt that REACH compliance is a hugely complex issue for companies around the world and but automating and guaranteeing the safe delivery of SDSs will ease the complexity and ensure one key element of compliance is addressed.
Malcolm Carroll, CEO, Reach Delivery, Hemel Hempstead, Hertfordshire, UK. www.reachdelivery.com.