GHS: Gobs in the details

Posted on August 13, 2012 by Chris Jellen

I recently attended a Environmental themed conference. Nearly 5000 professionals in Environmental, Health and Safety were there. I saw many things at the show, but nothing surprised me more than seeing standing room only — and a line out the door — for one event.

What was it? It was a talk on GHS, the Globally Harmonised System of Classification and labeling of chemicals. I mean — it was a general talk. Just a lay-of-the-land kind of talk.

Now, call me crazy, but I had to pull a high-level EHS association official aside and ask, “Really — are people really that confused about GHS? You add a couple of sections onto the MSDS and use slightly different pictograms. Why all the commotion?”

The official nodded slightly as if she understood the question. She said it was true that most companies may have a GHS solution built in with their current MSDS management system. But then she explained why there were lines out the door for general GHS information. So for those who — like me — are puzzled by the fuss over GHS, this one’s for you.

Understanding the new GHS. To help understand the fuss about the US Occupational Safety and Health Administration’s (OSHA) newly final Hazard Communication Standard (HCS), it’s important to realize that this rule is OSHA’s most comprehensive rulemaking in a decade. Of this I was reminded.

The updated HCS impact affects over five million businesses. These are manufacturers, and to some extent distributors, that use or store chemicals. Plus, the new HCS affects almost 100,000 chemical manufacturers, importers, and distributors.

Because the new rule is a major revision of the HCS, OSHA is requiring employers to train all employees on the new rules. Training is expected to impose the bulk of the cost burdens on US businesses.

Software for GHS won’t be much different from the current MSDS vault type programs companies use today. So training there should not be required, except for label making differences. Outsourced and SaaS solutions pose few training challenges — because these can be adjusted anytime, in real time. (SaaS is like the cloud — but believed to be more secure.)

But if you don’t outsource MSDS and GHS already — now is a good time to start. Rather than accrue costs while piece-mealing SDS responsibilities under REACH, OSHA and now, effectively, GHS — some companies have found value in investing in a centralized, comprehensive, outsourced solution.

Billions of dollars at stake. While the big-picture changes aren’t so scary, the details of it will get cumbersome. Largely the folks lining up at conferences to learn more are the consultants. They have to know everything, in theory. There’s a lot of money at stake.

The new GHS introduces a set of criteria for classifying human health and physical hazards while identifying OSHA-defined hazards. It requires that companies classify substances and/or products to ensure the appropriate classifications are assigned. Chemical data and labels will often need revision — perhaps significantly — to conform to new document requirements as they emerge.

Achieving and maintaining compliance will be a complex and time-consuming undertaking for many companies. I’ve heard OSHA officials use the word “billions” when discussing total costs. (As soon as I can lock down a quotable source, you’ll hear about it here.)

Who’s attending “about GHS” forums? Attending is anyone who has an eye on the money, basically. No, that’s not fair. Also attending are folks really trying to learn as much as they can. Groups and their motivations include:

Industry professionals seeking to understand / react to implications of the new HCS rule, so they can competently and strategically manage resources, budget, training, and compliance
Leading regulatory compliance experts and industry representatives who provide strategic advice to a broad spectrum of industry clients relative to regulatory standards, rule-making, and compliance.
Journalists trying to distill key insights and analysis of the OSHA HCS adopting GHS
Folks seeking discussions the multiple impacts, risk factors and estimated costs to be incurred by employers and manufacturers
Individuals looking to refine and discuss definitions for “substance,” “mixture,” and hazard “classification,” among other critically important new terms
Executives analysing strategic planning considerations and potential compliance/risk exposures

Audience by professional role? Well, look out, here comes everybody:

Environmental, Health, and Safety (EHS) Managers
Product Marketing/Safety/Packaging & Labeling Professionals
Human Resource Managers
Fire Services Professionals
International Marketing Professionals
Compliance and Training Staff
Environmental and Process Engineers
Engineering and Plant Services Professionals
Facility/Energy Planning Professionals
Environmental Compliance and Reporting Management
Monitoring/Environmental Resource Managers
Environmental Health and Safety Management
Production/Operations/Engineering/Environmental Management
Environmental Consultants and Attorneys
Environmental Risk Management Professionals
Environmental/Corporate Counsel SVP/VP/Director
SVP Finance/Engineering/Operations Management
Power Plant Chief/Supervisor/Managers
Physical Plant/Facility Management

If the question you ask yourself is, “Is this much ado about nothing?” then you’re probably all set. If you really do have questions about GHS solutions, sign up for a seminar or webinar soon, before it’s too late! I say that and am not even promoting such a thing. Just don’t get left out in the corridor like I did: people are hot on this trail right now and it’s standing room only.

Cheers, and, as always, happy compliance.

EPA Penalties for Wrong Chemical Data Reporting

Posted on July 24, 2012 by Chris Jellen

The U.S. Environmental Protection Agency (EPA) has issued complaints seeking civil penalties against three companies for alleged violations of chemical reporting and record-keeping requirements. The requirements, under the Toxic Substances Control Act (TSCA), require companies to submit accurate data about the production and use of chemical substances manufactured or imported during a calendar year.

Chemical Data Reporting (CDR) penalties
These violations in particular involve failure to comply with EPA’s TSCA section 8 Inventory Update Reporting (IUR). The gist of the TSCA section 8 update is related to production volumes of chemicals, adjusted last November 2011. The larger IUR is well-explained here.

Under the TSCA penalty structure as it stands, penalties can be assessed up to $37,500 per day, per violation.

Formerly known simply as the IUR, the rule is now called the “TSCA Chemical Data Reporting Rule.” Of course, that’s been abbreviated, now it’s known just as CDR in most circles. As always, have your acronym machete handy when approaching EPA materials. Again, details can be found in section 8 of the larger TSCA.

CDR reporting deadlines and transgressions
The reporting deadline for the 2006 IUR rule ended in March of 2007 — EPA’s enforcement efforts have led to 43 civil enforcement actions and approximately $2.3 million dollars in civil penalties against companies that failed to report required chemical data information.

By the way: the reporting deadline for the CDR 2012 submission period is August 13, 2012.

The three most recent cases where EPA is complaining of a trangression are against Chemtura Corporation, Bethlehem Apparatus Company, and Haldor Topsoe, Inc., and resulted in penalties totaling $362,113.

The Chemtura Corporation – $55,901. The company corrected the violations, paid the penalty and a final order was issued by the Environmental Appeals Board (EAB) on June 25, 2012.

Bethlehem Apparatus Company – $103,433. The company corrected the violations and paid the penalty.

Haldor Topsoe, Inc. – $202,779. The company paid on July 2, 2012.

It will be interesting to see if enforcement continues, and whether it trends towards higher fines or not. Chemical data reporting is poised to become the next great challenge (and, arguably, competitive advantage) for American companies — which is why technology market watchers paid such attention to software for chemical ingredient disclosure earlier this year.

More information about TSCA reporting requirements and penalties is online, at the EPA website.

Conflict Mineral Regulation: Vote Slated for August

Posted on July 13, 2012 by Chris Jellen

The Securities and Exchange Commission (SEC) has announced an open meeting (see below) to vote on the final conflict minerals rule on August 22, 2012.

IPC says it will be making one last lobbying push to emphasize the importance of a phase in period, reasonable treatment of recycling, and other issues of concern. Additionally, they will continue to move forward with drafting of our due diligence guidance document, participation in the OECD guidance pilot implementation, and other tools to help our members.

Finally, assuming regulations are adopted on August 22, 2012, IPC will plan to hold educational seminars in California, Chicago, and Boston in late October or early November.

Other associations and lobbying groups are likely doing the same.

SECURITIES AND EXCHANGE COMMISSION Sunshine Act Meeting

The announcement:
“Notice is hereby given, pursuant to the provisions of the Government in the Sunshine Act, Pub. L. 94-409, that the Securities and Exchange Commission will hold an Open Meeting on Wednesday, Aug. 22, 2012, at 10 AM, in the Auditorium, Room L-002.

The subject matters of the Open Meeting will be:

Item 1: The Commission will consider whether to adopt rules regarding disclosure and reporting obligations with respect to the use of conflict minerals to implement the requirements of Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act
Item 2: The Commission will consider whether to adopt rules regarding disclosure and reporting obligations with respect to payments to governments made by resource extraction issuers to implement the requirements of Section 1504 of the Dodd-Frank Wall Street Reform and Consumer Protection Act
Item 3: The Commission will consider rules to eliminate the prohibition against general solicitation and general advertising in securities offerings conducted pursuant to Rule 506 of Regulation D under the Securities Act and Rule 144A under the Securities Act, as mandated by Section 201(a) of the Jumpstart Our Business Startups Act

At times, changes in Commission priorities require alterations in the scheduling of meeting items. Keep your eyes peeled and/or subscribe to this blog — or to IPC updates or the like.

India’s Environmental Policy for Chemicals

Posted on June 6, 2012 by Chris Jellen

Last April we wrote about India’s new manufacturing policy. They needed one then, and some say still do. Manufacturing in the land of cumin and curry has stalled. But don’t be fooled into thinking that means manufacturing is not happening at all in India — it means growth has stalled, not production.

Some wonder, rhetorically, how could Indian manufacturing have kept growing…?

Answer: by finding new markets.

Maybe you saw the news (India GDP news May 31, 2012) that India’s GDP growth slowed to 5.3% in Q1. This represents a three-year low for the nation. However, let’s not count India out just yet. Not even close. The nation, like many of its neighbors, is pausing, looking for new markets to pour its tremendous energy into.

One of those markets looks like it might be the chemicals industry.

Let’s take a look at the chemical industry (and related policy) in India.

India industrial sector growth: chemicals. In India, the chemical industry is said to be one of the oldest in the nation. It’s essential to any nation’s economic development that is based on manufacturing. In years past, India has had to import and almost-embarrassing amount of raw materials, including chemicals. Still, the Indian chemical sector is growing, estimated now to be worth about $108 billion.

Asia itself is a rising star in chemical sales. For example, over the last 10 years, Asia’s share of global chemical sales has increased by ~14%. Currently, the Indian chemical industry accounts for approximately 7% of India’s GDP. The share of industry in national exports hovers near 11%. Despite its large size and significant GDP profile, India’s chemicals industry represents only about 3% of global chemicals.

The Indian chemical industry is one of the most diversified sectors touching thousands of commercial products. As the raw materials engine in a booming manufacturing ship, the chemical industry is central to industrial and the agricultural development. The chemical industry provides essential building blocks for multiple downstream industries, such as textile, paper, paint, soap, detergent, pharmaceutical, varnish, etc. In India, the chemical sector is known to be largely based on feed stock derivatives from cracking of naphtha in oil refineries providing the building blocks, such as benzene, toluene, xylene, cresols, etc.

India environmental policy: chemical policy like REACH? India’s Ministry of Chemicals and Fertilizers has declared the need to invigorate the chemicals aspect of its environmental policy. Holding out for REACH-like* legislation might be a stretch in the near future (someday maybe). But the Ministry is talking in the direction of the safer use of chemicals. “For the protection of human health and the environment, and in order to reduce the current number of chemical-related laws,” authorities are saying.

*REACH is a European regulation, a pioneer initiative in the world on that deals with the registration, evaluation, authorisation and restriction of chemical substances, which entered into effect on June 1, 2007 in the European Union.

However, in India, the Department of Chemicals and Petrochemicals did begin a consultation process of the draft national chemicals policy in April of this year (2012). The resulting document includes a wide range of objectives and proposals.

Included in the documentation is the stated need to consolidate the “multiple legislations in India governing the chemicals industry that fall under the purview of different ministries.”

Also, according to the draft, India lacks legislation that addresses the following:

the registration of substances
preparation of a national inventory
restrictions on hazardous substances
banning of certain substances
detailed classification and labeling criteria
transport classification

The draft policy also calls for the creation of a “National Chemical Centre” (NCC). They would perform functions such as:

draft legislation
monitor its implementation
monitor international trade practices
identify opportunities for innovation and technology

The NCC would have a role in disseminating information about hazardous chemicals and create and maintain a chemicals inventory, which would include data on production, consumption and toxicological properties.

A second new body which the document states should also be set up under the guidance of the department is a “Chemical Standard Development Organisation”, or CSDO. They would “drive consensus regarding national requirements, including safety norms.”

Sound like REACH? Yes — ish — in theory. In reality though it’s light years away, in miles, sure, but mostly in time.

Resources besides those referenced above, as links:
International Labor Assn for Sustainable Development ILASD
Subscription / fee based: Chemical Watch

Intel Inside: The Supply Side of CSR

Posted on May 23, 2012 by Chris Jellen

At a Product Stewardship summit last week, Wood Turner from Stonyfield Farms sat on a panel. He spoke about Stonyfield CSR tips and tricks.

Turner mentioned that his company links employee compensation with environmental reporting.

Turner said that linking salary with environmental performance engages all employees. And that it makes sense for Stonyfield. After all, he said, Stonyfield is a company built on concepts of sustainability, responsibility and progressive environmental initiatives.

Well, it turns out that Intel— not set upon the greenest foundation of all time— has a similar compensation program. They also have a relatively sophisticated substance tracking system for raw materials. Things like tungsten, tantalum and tin aren’t going to fly under the radar in their supply chain.

World’s largest semiconductor chip maker gets green
Intel’s summary of 2011 Corporate Responsibility published this week. In it, Intel says that since 2008 it has linked a portion of every employee’s variable compensation — from front-line employees to CEO — to the achievement of environmental sustainability metrics.

Intel, the world’s largest semiconductor chip maker, says it believes linking pay to green, as it were, helps the whole workforce focus on achieving environmental objectives.

Notably, Intel’s 2011 Corporate Responsibility report also links corporate responsibility performance and the creation of business value.

“At Intel, corporate responsibility is a crucial component to the overall growth of our business,” said Michael Jacobson, Intel’s director of corporate responsibility.

And, to our interest, the report also hones in on increased supplier assessments.

Intel inside: the supply side
In the lengthy Corporate Responsibility report, Intel says it is committed to operating with transparency. This, it says, provides accountability and encourages two-way dialogue with employees and other stakeholders.

“Acting on stakeholder input,” says the company, “we also expanded our disclosure on our policies, approach, and management systems related to human rights in our operations, our supply chain, and the use of our products. Assessments and audits of suppliers help the company identify compliance gaps and develop system solutions and improvements.

Conflict minerals approach
In 2011, Intel says it completed or reviewed the results from 49 third-party audits of supplier facilities in nine countries, a five-fold increase over 2010. In 2011, they also continued to address concerns about minerals derived from unsavory mines, whose profits may be fueling human rights atrocities in the eastern region of the Democratic Republic of the Congo.

As of the end of 2011, we had mapped 92% of the tantalum, tin, tungsten, and gold supply lines supporting our core business, and had visited 48 smelters in nine countries. Impressive? Kind of. If it’s not too greenwashed it’s really good work.

For the lurid details, see: http://www.intel.com/content/www/us/en/corporate-responsibility/corporate-responsibility-report-overview.html

EPA’s New Rule Requires Electronic Reporting

Posted on April 18, 2012 by Chris Jellen

Time to buff up your stuff — meaning your data archives and processes. The U.S. Environmental Protection Agency (EPA) has announced a proposed rule to require electronic reporting for certain information submitted to the agency under the Toxic Substances Control Act (TSCA). Now’s the time to get data management under control so reports aren’t being fired off from your internal ops over to EPA willy-nilly.

You’ll recall last year when a similar rule was launched. EPA set up a page for that rule called Requirements for Submitting Electronic Pre-manufacture Notices (PMNs).

Today’s proposed rule would require electronic reporting rather than paper-based reporting for various TSCA actions including submission of information relating to chemical testing, health and safety studies, and other information. When final, EPA will only accept data, reports, and other information submitted through EPA’s Central Data Exchange, a centralized portal that enables streamlined, electronic submission of data via the Internet.

EPA will be soliciting comments on this proposed rule for 60 days.

Fact is, though, digital reporting is the way of the future.

For more information on the proposed rule: http://www.epa.gov/oppt/chemtest/

For more information on OPPT’s increasing transparency efforts: http://www.epa.gov/oppt/existingchemicals/pubs/transparency.html

Greece: Global Supply Chain Economy is as Strong as Its Weakest Link

Posted on February 21, 2012 by Chris Jellen

Eurozone finance ministers agreed on a bailout strategy for debt-riddled Greece. The American markets opened high in the US, with the Dow Jones industrial average at a nearly four-year high, just 20 points away from 13,000. This is exciting, as the Dow Jones has not reached 13,000 since May 2008.

Insiders say the bailout of Greece will resolve the country’s immediate financing needs. But the program, like most if not all bailouts, seems unlikely to revive the nation’s shattered economy in the longer term. That will have to come from some serious internal structuring. The doubt is whether Greece’s internal systems are capable of that sort of overhaul. Let’s hope so. Now is a time when we’re reminded that the global supply chain and its attendant economy is only as strong as its weakest link.

Our markets are your markets, and your markets are our markets, and we are all together. Goo goo ga joo.

Greece is the walrus

The bailout deal will cut Greece’s debt to 120.5% of gross domestic product by 2020. That’s a fraction above their original target of 120%, after negotiators for private bondholders accepted bigger losses to help plug the funding gap.

Agreement on the $170 billion rescue package, subject to strict conditions, will help draw a line under months of uncertainty that has shaken the currency bloc, and avert an imminent Greek bankruptcy, Euractiv reported.

“We have reached a far-reaching agreement on Greece’s new programme and private-sector involvement that would lead to a significant debt reduction for Greece and pave the way towards an unprecedented amount of new official financing … to secure Greece’s future in the euro area,” Luxembourg’s Jean-Claude Juncker, who chairs the Eurogroup of finance ministers, told a news conference.

Making it in the old country

As for manufacturing and Greece, for businesses in the heavy equipment, vehicle/auto and aerospace industries (or users of their components), Greece is not an insignificant supply chain source. Below please find a list of manufacturing companies in Greece whose names may well appear on your purchasing orders. Or on your suppliers’ purchasing orders. When you’re planning a winter vacation, Greece seems much farther away than you’d like. But in a global economy, Greece really isn’t all that far away at all.

To show that Greece is significant, not just in the world of finance but in the realm of the global manufacturing supply chain, we respectfully submit the following. Here is a partial list of higher profile manufacturers in Greece:

1.   AEKKEA-RAAB
2.   EADS 3 Sigma
3.   Hellenic Aeronautical Technologies
4.   Hellenic Aerospace Industry
5.   State Aircraft Factory (Greece)
6.   BIOMAN (lifting devices)
7.   Kouppas (machinery)
8.   EADS 3 Sigma
9.   EAS (weapons)
10.   Econ group (Greece)
11.   Elviemek (defense)
12.   Hellenic Aerospace Industry
13.   Hellenic Arms Industry
14.   OMI Ordtech Military Industries
15.   Pyrkal (defense)
16.   Dimadis-Kanakis (engine)
17.   Malkotsis (engine)
18.   Chropei (firearms)
19.   EAS (weapons)
20.   Basileiades (vehicle)
21.   Hellenic Shipyards Co.(vehicle)

Extended list of vehicle supply sources in Greece:

1.   Agricola (vehicle)
2.   AK Hellas (vehicle)
3.   Alta (vehicles)
4.   Atlas (light trucks)
5.   Attica (automobiles)
6.   AutoDiana (vehicle)
7.   Autokinitoviomihania Ellados (vehicle)
8.   Automeccanica (vehicle)
9.   Balkania (vehicle)
10.   Biamax (vehicle)
11.   BIOMAN (lifting devices)
12.   Biotechnia Ellinikon Trikyklon (vehicle)
13.   C.AR (automobiles)
14.   Diana (agricultural machinery)
15.   DIM (automobiles)
16.   Dinap (trucks)
17.   EBIAM (vehicle)
18.   ELBO (vehicle)
19.   Emporiki Autokiniton (vehicle)
20.   Hercules (vehicles)
21.   MAVA-Renault (vehicle)
22.   MEBEA (vehicle)
23.   Motoemil (vehicle)
24.   MotorCar (trucks)
25.   Namco (automobiles)
26.   Neorion (vehicle)
27.   Pan-Car (vehicle)
28.   Pantelemidis (vehicle)
29.   Petropoulos (vehicle)
30.   Pitsos (vehicle)
31.   Record (agricultural vehicles)
32.   Ros (vehicles)
33.   SAM (vehicles)
34.   Saracakis (vehicle)
35.   Scavas (vehicle)
36.   Sfakianakis (vehicle)
37.   Styl Kar (vehicle)
38.   Tangalakis-Temax (vehicle)

EPA’s New PVC Standards

Posted on February 17, 2012 by Chris Jellen

The U.S. Environmental Protection Agency (EPA) is on the move, issuing strong final standards requiring facilities that produce polyvinyl chloride and copolymers (PVC) to reduce harmful air emissions.

Now, a year ago in April (2011) it seems we had this same news about EPA and PVCs. In fact, EPA had a 74-day public comment period and held two public hearings on the proposal before issuing this final rule. So, this is the final phase of EPA’s draft-policy process, so either speak now or forever hold your peace.

EPA says that the final standards — announced yesterday, February 14, 2012 — will reduce emissions of air toxics, such as dioxin and vinyl chloride. Facilities will have the flexibility to choose the most practical and cost-effective control technology or technique to reduce the emissions. Facilities will be required to monitor emissions at certain points in the PVC production process to ensure these standards are met. Multimedia enforcement is expected.

Currently, there are 17 PVC production facilities throughout the United States, with a majority of these facilities located in Louisiana and Texas. All existing and any new PVC production facilities are covered by the final rule.

PVC production facilities manufacture PVC resins that are used to make a large number of commercial and industrial products at other manufacturing facilities. These products include latex paints, coatings, adhesives, clear plastics, rigid plastics, and flooring.

Polyvinyl chloride, commonly abbreviated PVC, is the third most widely produced plastic, after polyethylene and polypropylene. It’s durable, cheap, and easily worked. PVC production is expected to exceed 40 million tonnes by 2016. It can be made softer and more flexible by the addition of plasticizers, the most widely used being phthalates. In this form, it is used in clothing and upholstery, electrical cable insulation, inflatable products and many applications in which it replaces rubber.

Read more in the Advocate: http://theadvocate.com/home/2065296-125/epa-issues-pvc-pollution-rules.html

WEEE Recast Gets Electric

Posted on January 23, 2012 by Chris Jellen

In Brussels, on Jan. 19, Environment Commissioner Janez Potocnik said he was pleased with the overwhelming support given by the European Parliament to an updated Directive on waste electrical and electronic equipment (WEEE). A majority of MEPs voted in favor of a deal.

Lots of excitement for this measure; you could say the atmosphere is electric.

WEEE — when executed — sets preconditions for professional recycling of valuable raw materials like:

gold
silver
copper
other rare metals contained in used TVs, laptops and mobile phones.

Currently only one third of electrical and electronic waste in the European Union is reported by EU Member States to be separately collected and appropriately treated.

Citing “challenging times” and “rising prices for raw materials,” Potocnik made a good point that resource efficiency is where environmental benefits and innovative growth opportunities for European industry come together.

“The waste stream with the greatest relevance in this respect is electrical and electronic waste,” he said. “Today, the European Parliament has given a great boost to this policy, raising the binding collection levels to 85% by 2019.”

WEEE work. The new Directive will force exporters to test and provide documents on the nature of their shipments when the shipments run the risk of being waste. Illegal shipments of WEEE disguised as legal shipments of used equipment, in order to circumvent EU waste treatment rules, are a serious problem in the EU. The new WEEE Directive will also give EU Member States the tools to fight illegal export of waste more effectively.

The so-called WEEE recast also calls for harmonisation of national registration and reporting requirements under the Directive. In collaboration with Member States, the Commission will endeavor to adopt a harmonised format to be used for the supply of information in registers for producers of electrical and electronic equipment.

Administrative burdens are consequently expected to decrease by around EUR 66 million per year. For Americans and WEEE, not much has been said yet. There’s a wait-and-see air about it, but respectfully so.

WEEE all the way home? The vote means that co-legislators agree on a common text. This will need to be formally adopted by the Council of Ministers in coming weeks. Here’s what’s being asked:

Member States will be required to collect 45% of electrical and electronic equipment put on their markets by 2016, and then achieve 65% by 2019, or may opt alternatively for a target of 85% of waste generated. Some Member States will be able to derogate from these targets where justified by lack of necessary infrastructure or low levels of EEE consumption.

The existing binding EU collection target is 4 kg of WEEE per capita, representing about 2 million tons per year, out of around 10 million tonnes of WEEE generated per year in the EU. By 2020, it is estimated that the volume of WEEE will increase to 12 million tons. The new target, endorsed by Parliament, an ambitious 85% of WEEE generated would ensure that around 10 million tons, or roughly 20kg per capita, would be separately collected in 2020.

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