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Chemical Regulation and SMEs - thoughts on the Chemicals Northwest "REACH: A time to plan" Symposium

Mon, 14 Jul 2014

I was fortunate to find the time to attend a Chemicals North West symposium in early June, jointly organised with the Royal Society of Chemistry – REACH: A time to plan – which is an area of interest to me and should be for all chemical handling businesses. 

I’m immersed in trying to determine the far-reaching consequences for businesses of failure to fully appreciate and suitably adjust their business model for the long-term demands of REACH and an era of regulation – in Europe and elsewhere. And having built a business and two products on the back of REACH, we at Baytouch are constantly researching ways to mitigate the organizational stresses and pain in our IT solutions.

The speaker line-up offered direct insight from regulatory affairs personnel, well-known consultancy practitioners and the regulatory bodies themselves, that are grappling with the growing burden of regulatory paperwork. But it was the first-hand and practical experience from the SME community that I found most insightful, not least because it confirmed the acute need – particularly within the SME community – for precisely the supply chain management solution that Baytouch has built in ProductTraq. It also demonstrated just how seriously SMEs take their license to operate; after all, these are the businesses least likely to be able to afford the fines or other sanctions that would go alongside failure to comply but there is no exemption because of size..

The SME community presenters were represented by Trevor Rhodes, Michael Goodwin and Graham Bayliss, from real-life SME businesses with real-life experiences.

Trevor, from Harman Technology Limited, spoke openly and eloquently about the unanticipated and considerable impact REACH has had on their business processes and resources – and their expectations that it will continue to do so.  It’s not something they would have chosen to do as they have many decades of responsible chemical management under their belts, supplying photographic materials to the professional sector and schools and colleges. It has brought next to no benefit to their bottom line but they accept it as a necessity to trade.

Michael, from John Hogg Technical Solutions, handles Regulatory Affairs for the company on a full-time basis. He told us about the commercial considerations and manufacturing decisions that have stemmed from REACH. The long-term impact on the way the business operates has clearly been wide-ranging.

Finally, Graham from ReAgent Chemical Services Limited stressed that, although ReAgent is classed as a downstream user and not a manufacturer, they are not removed from duties under REACH. Being able to transfer accurate information up and down the supply chain and keep safety data sheets up–to-date is crucial to effectively controlling and mitigating risk in their business. It has affected how they source materials as well as how they handle data, labelling and communications. 

On the whole, Graham has found information sources about products and components to be rife with inconsistencies, inaccuracies and occasionally there is no data at all. This is a huge headache for any business trying to exemplify best practice and provide full and accurate information to their customers. He estimates that it will take up to 10 years to achieve consistent information transfer standards across the industry, something we are trying to leverage in ProductTraq’s design.

 My own vision is that ProductTraq can play a market-leading role in delivering this consistency much sooner than that.

What is your experience of REACH? What issues or benefits do you foresee for chemicals handling businesses over the coming years? Let’s have a conversation. Tweet me @MalcolmPollard or connect on LinkedIn.