Sunday, February 20, 2011
Saturday, February 5, 2011
SAP EHS Reflections for Year 2011
Dear Friends,
I came to India for a week, I want to ensure I dont miss scribling down my thoughts on Whats in Store for SAP EHS in the Year 2011. The Year 2010 - was bit quick as far as EHS is concenred - "The Clock Really Ticked Too Fast", all the companies worked towards a commmon goal - to meet the 2010 - REACh deadline. During this period also there were some Property Tree enhancements released by SAP to support the eSDS creation and also a properietary tool from TechniData CLEO - SAP Bulk Notification Tool / Exper Rules for meeting CLP requirements - though these are not offical part of SAP release pack. SAP also released Component Extension 1.0 for SAP EHS Management - for Incident Management, SAP Carbon Impact SAP CI 5.0 version and SAP Product and REACh Compliance - enhanced version which includes Material Assessment, Business Partner, Supply Chain and Other key functionality enhancements.
There are some 3.1 Million Classification and Labelling notifications received by ECHA and around 24,675 registration dossiers are submitted. One notifceable thing is Companies made a significant effort in submitting the dossiers only few companies missed the deadlines, - showing whatver the current practices in Industry to prepare the dossiders / CLP notifications are effective to some extent for the Dossier preparation and Dossier Submission and Classification and Notification. But these very howegrown Software Solutions will give a good opportunity for EHS Consultants in the Year 2011. Majority of the companies would have realized that its too risky to bank upon the homegrown solutions and they need to migrate that to an enterprise platform - not only to streamline their processes but also to meet other Regulations similiar to REACh. So would see more of data conversion projects, new process optimization works.
This very exercise of preparation and submission of dossiers would have shown the companies how difficult it is to meet such regulatory requirements - would like to hire / outsource some of the processes outside the Industry to manage it for a long terms -
The other opportunity is the dissemination and storage of eSDS and email confirmation of the inforamtion is received for a long term solution, Other Opportunity would come from the Labelling perspective - Companies would be making significant work on the label creation
Companies would have also recognized that meeting the Operational Compaliance for tracking the REACh Volume movements - is also not easy given the current implementation scope - would see more in this sphere too - more of plant to plant utilization and portfolio management !
Exposure management is another reuqirement for a long term solution - not many Companies utilizied the curent SAP Solution for Exposure Management - given the tight schedule to achive them - would see some more Product Safety like works been taken up by companies.
Besides above the silver lining is - Companies are advised to retain their current REACh Project Team for some more time ! Given these and also new Regulations are being enforced in other Countries - I personally see a good scope for EHS for the Year 2011. So Here's the Chance - which Favors the Prepared Mind - Be Prepared !!!
Thanks
I came to India for a week, I want to ensure I dont miss scribling down my thoughts on Whats in Store for SAP EHS in the Year 2011. The Year 2010 - was bit quick as far as EHS is concenred - "The Clock Really Ticked Too Fast", all the companies worked towards a commmon goal - to meet the 2010 - REACh deadline. During this period also there were some Property Tree enhancements released by SAP to support the eSDS creation and also a properietary tool from TechniData CLEO - SAP Bulk Notification Tool / Exper Rules for meeting CLP requirements - though these are not offical part of SAP release pack. SAP also released Component Extension 1.0 for SAP EHS Management - for Incident Management, SAP Carbon Impact SAP CI 5.0 version and SAP Product and REACh Compliance - enhanced version which includes Material Assessment, Business Partner, Supply Chain and Other key functionality enhancements.
There are some 3.1 Million Classification and Labelling notifications received by ECHA and around 24,675 registration dossiers are submitted. One notifceable thing is Companies made a significant effort in submitting the dossiers only few companies missed the deadlines, - showing whatver the current practices in Industry to prepare the dossiders / CLP notifications are effective to some extent for the Dossier preparation and Dossier Submission and Classification and Notification. But these very howegrown Software Solutions will give a good opportunity for EHS Consultants in the Year 2011. Majority of the companies would have realized that its too risky to bank upon the homegrown solutions and they need to migrate that to an enterprise platform - not only to streamline their processes but also to meet other Regulations similiar to REACh. So would see more of data conversion projects, new process optimization works.
This very exercise of preparation and submission of dossiers would have shown the companies how difficult it is to meet such regulatory requirements - would like to hire / outsource some of the processes outside the Industry to manage it for a long terms -
The other opportunity is the dissemination and storage of eSDS and email confirmation of the inforamtion is received for a long term solution, Other Opportunity would come from the Labelling perspective - Companies would be making significant work on the label creation
Companies would have also recognized that meeting the Operational Compaliance for tracking the REACh Volume movements - is also not easy given the current implementation scope - would see more in this sphere too - more of plant to plant utilization and portfolio management !
Exposure management is another reuqirement for a long term solution - not many Companies utilizied the curent SAP Solution for Exposure Management - given the tight schedule to achive them - would see some more Product Safety like works been taken up by companies.
Besides above the silver lining is - Companies are advised to retain their current REACh Project Team for some more time ! Given these and also new Regulations are being enforced in other Countries - I personally see a good scope for EHS for the Year 2011. So Here's the Chance - which Favors the Prepared Mind - Be Prepared !!!
Thanks
Friday, December 31, 2010
Happy New Year 2011
Dear Friends,
Wishing you Happy and Prosperous (Health, Wealth and Safe) New Year 2011.
Thanks
Wishing you Happy and Prosperous (Health, Wealth and Safe) New Year 2011.
Thanks
Monday, December 6, 2010
Some Break Now !!!
Dear All,
I am in Shanghai, China, and surprisingly I am not able to access the blog. It seems its not allowed. Sorry I may not contribute my thoughts as frequently as I used to / wish to !!!
Thanks
I am in Shanghai, China, and surprisingly I am not able to access the blog. It seems its not allowed. Sorry I may not contribute my thoughts as frequently as I used to / wish to !!!
Thanks
Friday, October 29, 2010
Draft Changes to SDS based on PEG Recommendations is now available @ REACh EU
Dear All,
Based on the initial feedback received from PEG, ECHA made some changes in the text of Safety Data Sheet released during Feb 2010. The major changes are basically relates to initial feedback on the structure and content of the document. Some Corrections to the legal text is also made to reduce the length of the text and to need for translations text. What it means to the business‘s is that they need to consider three different versions of the Annex II during different time periods. Up to 1st December 2010, Between December 2010 and June 2015 and from June 2015 and there could also be some changes needed for the safety data going forward like incorporation of Evaporation rate, Auto Ignition Temperature, Decomposition Temperature
ANNEX II - GUIDE TO THE COMPILATION OF SAFETY DATA SHEETS is valid through 1st June 2007 to 19th June 2010, (present Annex II published with REACH)
ANNEX II - REQUIREMENTS FOR THE COMPILATION OF SAFETY DATA SHEETS PART A, will be in force from 1st December 2010 to 1st June 2015. (Annex I of commission for substances until the end of 1st June 2015 and for mixtures labeled DPD.
L133/24 “ANNEX II 4 REQUIREMENTS FOR THE COMPILATION OF SAFETY DATA SHEETS PART A”, will come into force from June 2015 onwards. Annex II of 2010 for substances after 1st June 2015 and for Mixtures Labeled CLP
Full Text of legal Document and associated Excel Sheet showing, which are the recommendations which are implemented in this draft version are available @ ECHA website
Based on the initial feedback received from PEG, ECHA made some changes in the text of Safety Data Sheet released during Feb 2010. The major changes are basically relates to initial feedback on the structure and content of the document. Some Corrections to the legal text is also made to reduce the length of the text and to need for translations text. What it means to the business‘s is that they need to consider three different versions of the Annex II during different time periods. Up to 1st December 2010, Between December 2010 and June 2015 and from June 2015 and there could also be some changes needed for the safety data going forward like incorporation of Evaporation rate, Auto Ignition Temperature, Decomposition Temperature
ANNEX II - GUIDE TO THE COMPILATION OF SAFETY DATA SHEETS is valid through 1st June 2007 to 19th June 2010, (present Annex II published with REACH)
ANNEX II - REQUIREMENTS FOR THE COMPILATION OF SAFETY DATA SHEETS PART A, will be in force from 1st December 2010 to 1st June 2015. (Annex I of commission for substances until the end of 1st June 2015 and for mixtures labeled DPD.
L133/24 “ANNEX II 4 REQUIREMENTS FOR THE COMPILATION OF SAFETY DATA SHEETS PART A”, will come into force from June 2015 onwards. Annex II of 2010 for substances after 1st June 2015 and for Mixtures Labeled CLP
Full Text of legal Document and associated Excel Sheet showing, which are the recommendations which are implemented in this draft version are available @ ECHA website
Sunday, September 26, 2010
SAP EH&S Data Model - Use of Compositions
Dear Friends,
One of the significant aspects to the success of Safety Datasheet Generation / distribution projects is to use and adopt the eixsting data structures. Even for meeting regulatory requirements like to manage REACh Compliance, Volume Tracking or notification management it is necessary to use of right data model. Even, if EHS Data is needed for uploading to ECHA - CLP Notification Tool or REACh - IT, then information from Pure Substances is needed. For meeting these varied requirements there are a number of types of compositions which are available in SAP EHS. So if you are into a client project / needed to manage their data structure for meeting varied requirements, the first thing to notice is to study their existing data model and judiciously use them for meeting the to legislative needs. Remember the point that the priority would be not to disrupt existing business process and achieve the project objective.
The different types of compositions encountered in EHS include, Standard Composition, Exact Composition Based on Products (ECbP), Exact Components based on Components / Starting Material, Hazardous Composition, Legal Composition, REACH Use and Exposure Composition (U&E Comp), Impurities, Hazardous Ingredients (EU), DPDPlus and Pure Composition. Besides above standard types, based on client requirement there might be other flavours too. Here's the short overview of each of the component type.
1) Exact Components based on Products – Substances that are actually contained in the product after the production process has been completed and that can be detected by analysis. Can also consist of products which in turn consists of other components. This component type is generally used by different Expert Rules to calculated secondary data.
2) Standard Composition – Ingredients are substances, that are actually contained in the product after the production proces has been completed and that can be detected by analysis. These are generally taken from ECbP composition type and added together. Thes are calculated by Expert Rules – EHS Standard Comp Rule set.
3) Hazardous Ingredients - On the Composition tab page, specify the contents of the corresponding ingredients with lower limit, upper limit, and average value. In addition, specify the unit for the selected reference value.
4) Components with Occupational Exposure Limits - List of ingredients or ingredient groups (and their quantities) that are subject to an atmospheric limit value and must be specified with this limit value in the EU Safety Data Sheet in the current version), or in accordance with the Technical Regulations for Hazardous Substances.
5) Legal Composition – It’s an optional composition type excluding all impurities from Standard Composition for meeting legal requirements lik REACh. This together with recent release of Impurties –ideally should equal to Standard Composition.
6) REACH Use and Exposure Composition – Contains all substance, which are relevant for supply chain communication. Substances which are used in Compliance Workbench for triggering Supply chain communication.
Thanks
One of the significant aspects to the success of Safety Datasheet Generation / distribution projects is to use and adopt the eixsting data structures. Even for meeting regulatory requirements like to manage REACh Compliance, Volume Tracking or notification management it is necessary to use of right data model. Even, if EHS Data is needed for uploading to ECHA - CLP Notification Tool or REACh - IT, then information from Pure Substances is needed. For meeting these varied requirements there are a number of types of compositions which are available in SAP EHS. So if you are into a client project / needed to manage their data structure for meeting varied requirements, the first thing to notice is to study their existing data model and judiciously use them for meeting the to legislative needs. Remember the point that the priority would be not to disrupt existing business process and achieve the project objective.
The different types of compositions encountered in EHS include, Standard Composition, Exact Composition Based on Products (ECbP), Exact Components based on Components / Starting Material, Hazardous Composition, Legal Composition, REACH Use and Exposure Composition (U&E Comp), Impurities, Hazardous Ingredients (EU), DPDPlus and Pure Composition. Besides above standard types, based on client requirement there might be other flavours too. Here's the short overview of each of the component type.
1) Exact Components based on Products – Substances that are actually contained in the product after the production process has been completed and that can be detected by analysis. Can also consist of products which in turn consists of other components. This component type is generally used by different Expert Rules to calculated secondary data.
2) Standard Composition – Ingredients are substances, that are actually contained in the product after the production proces has been completed and that can be detected by analysis. These are generally taken from ECbP composition type and added together. Thes are calculated by Expert Rules – EHS Standard Comp Rule set.
3) Hazardous Ingredients - On the Composition tab page, specify the contents of the corresponding ingredients with lower limit, upper limit, and average value. In addition, specify the unit for the selected reference value.
4) Components with Occupational Exposure Limits - List of ingredients or ingredient groups (and their quantities) that are subject to an atmospheric limit value and must be specified with this limit value in the EU Safety Data Sheet in the current version), or in accordance with the Technical Regulations for Hazardous Substances.
5) Legal Composition – It’s an optional composition type excluding all impurities from Standard Composition for meeting legal requirements lik REACh. This together with recent release of Impurties –ideally should equal to Standard Composition.
6) REACH Use and Exposure Composition – Contains all substance, which are relevant for supply chain communication. Substances which are used in Compliance Workbench for triggering Supply chain communication.
Thanks
Friday, September 10, 2010
Practical Examples of Exposure Scenarios
Dear Friends,
ECHA has long released the Exposure Scenario Format and also a modified version to incorporate Contributing scenarios based on revised understanding. Exposure Scenarios are the set of information on operational conditions and risk management measures to be communicated to the users. Generally exposure scenario consists of description of conditions suitable to ensure control of risk related to the uses of a substance during the entire life-cycle. Environment, Workers and consumers are included covering one or more exposure uses. Data required for Exposure Scenario include Substance Properties, amounts, emission factors, onsite measures, personal respiration protection, frequency and duration of exposure, frequency and duration of use etc, depending whether it is Environmental Exposure, Workers or Consumer Exposure Scenario.
However one of the challenges in using exposure format is the availability some practical examples of exposure scenarios. Last week ECHA released sample exposure scenarios constituting three substances. These scenarios are specific to Semi Conductor Industry. The lesson's learned therein like how to manage site specific conditions versus Site independent data and how air emission management could generate risk to water compartment are very much helpful to understanding the complexity of the process.The data available therein is very good source to validate SAP EH&S Data models for Exposure Scenarios and also checking suitability of WWI Templates.
Note: Practical Examples of exposure Scenarios can be downloaded from ECHA Site http://echa.europa.eu/news/press_en.asp#press20100906
Thanks
ECHA has long released the Exposure Scenario Format and also a modified version to incorporate Contributing scenarios based on revised understanding. Exposure Scenarios are the set of information on operational conditions and risk management measures to be communicated to the users. Generally exposure scenario consists of description of conditions suitable to ensure control of risk related to the uses of a substance during the entire life-cycle. Environment, Workers and consumers are included covering one or more exposure uses. Data required for Exposure Scenario include Substance Properties, amounts, emission factors, onsite measures, personal respiration protection, frequency and duration of exposure, frequency and duration of use etc, depending whether it is Environmental Exposure, Workers or Consumer Exposure Scenario.
However one of the challenges in using exposure format is the availability some practical examples of exposure scenarios. Last week ECHA released sample exposure scenarios constituting three substances. These scenarios are specific to Semi Conductor Industry. The lesson's learned therein like how to manage site specific conditions versus Site independent data and how air emission management could generate risk to water compartment are very much helpful to understanding the complexity of the process.The data available therein is very good source to validate SAP EH&S Data models for Exposure Scenarios and also checking suitability of WWI Templates.
Note: Practical Examples of exposure Scenarios can be downloaded from ECHA Site http://echa.europa.eu/news/press_en.asp#press20100906
Thanks
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