ECHA

Tracking your company’s obligations under chemical regulations can be quite complex. In the EU, it is important to know how your duties under REACH overlap with obligations under national laws. If your company has multiple roles in the supply chain, this can be even more complicated. We spoke to Arto Huuskonen and Victoria Larsson from Valmet, a global developer and supplier for the pulp, paper and energy industries, to find out more about the challenges their company faces in collecting reliable data.

Aligning REACH and the single market

The complex regulatory landscape can make it difficult for companies to understand how to follow national legislation and still comply with their obligations under REACH.

There are national duties for managing chemicals in many Member States that overlap with REACH requirements. And substances in articles are regulated by various EU regulations that can often set different concentration limits and even give different ways of calculating concentrations.

Arto Huuskonen. Image: Valmet.

“Let’s take food contact materials as an example. Substances are regulated under REACH across the EU, but there are also EU-wide regulations on plastics that affect plastic food contact materials. There are, however, no EU-wide regulations for food contact materials made of paper. Some Member States have created national legislation for these, but this differs in each Member State. It quickly becomes difficult to know which regulation to follow in all situations,” says Mr Arto Huuskonen, the health, safety and environment (HSE) manager for the automation business line at Valmet.

“There needs to be an alignment between the single market and REACH, so any national regulations overlapping with REACH should be removed to secure the single market’s functioning,” he says.

 

Working in a global context

Under REACH, Valmet has three roles. It is, first and foremost, a downstream user of chemicals with operations in more than 30 countries. But it also operates as an importer of key raw materials and as an article manufacturer supplying more than 100 000 components.

Mr Huuskonen argues that REACH has limited the availability of some specialty chemicals, and that this has led to some downstream users needing to take on the importer role.

“We use some chemicals with limited applications, such as those used for paper machine roll coverings. Because of the obligations that REACH places on importers, some manufacturers have stopped selling some niche chemicals to Europe. So, companies with global manufacturing chains like ours are left to choose between importing the chemicals themselves or changing the recipes. Both options have their own difficulties and costs,” Mr Huuskonen tells.

“Even if you are able to get some chemicals you need into Europe, you may still find that there are a lot of deficiencies in the safety data sheets,” he adds.

A development programme for suppliers

Valmet has around 10 000 suppliers in over 50 countries, delivering hundreds of thousands of components. “Sometimes, suppliers’ knowledge on what is required under REACH can be limited. So, to make collecting data feasible, we carefully scope the suppliers we use,” Mr Huuskonen tells.

The company assesses how likely it is that components sourced from its suppliers may contain substances of very high concern (SVHCs). The data is collected primarily to improve chemical safety assessment and customer communication, but also to identify possible substitution needs and opportunities. It also enables better compliance with regard to SVHC notification.

This information is used to gauge how much data needs to be collected and what kind of quality assurance needs to be run.

“Most of the components we buy contain metal parts, such as steel tubes and plates, which we consider to pose a lower risk than parts made of certain plastics. Each of our purchases is given a risk score and those suppliers associated with higher risk categories are selected for more in-depth data collection,” Mr Huuskonen adds.

Victoria Larsson. Image: Valmet.

To successfully navigate the evolving legislation in Europe and worldwide, a development programme has been set up for Valmet’s suppliers, to raise their awareness of what is required on a global level. “REACH-like chemical regulation is still a novel concept worldwide. Our traditional management focus has been to look at occupational health and safety regulations, with our attention on the concentrations that workers are exposed to,” says Ms Victoria Larsson, Valmet’s global HSE manager.

If the programme identifies a good practice in one unit, the company can also apply it globally. It has also helped Valmet to identify front-runner jurisdictions where regulation is more advanced than in some other countries. “We try to follow these regulations more closely so that we can stay up to date with the most strict and applicable requirements. Planning compliance according to the strictest regulations creates a good baseline for compliance globally,” Ms Larsson stresses.

'Zero harm, wherever we work'

One of Valmet’s aims is ‘Zero harm, wherever we work’. The company sets out minimum safety standards designed to meet the requirements of the main global HSE laws so that safety is always a priority, especially when working with hazardous substances.

“In a global company, it is important to have a common baseline for safety standards. Our starting point is, of course, to know which chemicals are used and what their potential hazards are across all our operations. For this, the substances need to be fully risk assessed before starting work so they can be correctly handled, stored and marked,” says Ms Larsson.

While the standards are adhered to in Valmet’s own workshops, there is also a need to think about the potential for exposure in their customers’ mills and plants.

“There are obviously different risks of chemical exposure in those environments, so we also try to cover these in our standards. It always comes back to doing a thorough risk assessment so that we know for sure that we have identified all the potential hazards,” Ms Larsson asserts.

Harmonising REACH interpretations

According to Mr Huuskonen, stabilising interpretations of REACH could lessen the confusion of companies, especially those operating in more than one Member State.

“More than a decade since REACH entered into force, national helpdesks still offer different advice even on how to define a chemical. A stable interpretation of REACH and harmonising the support provided by helpdesks and authorities at a national level would help companies,” says Mr Huuskonen and continues, “but it would also require clear legal texts with sufficient supporting documents and giving EU agencies a bigger mandate in their own fields of expertise. So ECHA, for example, should have a stronger role in managing chemicals within the EU, not only based on how REACH should be interpreted but also based on other related regulations”.

Less frequent changes to REACH

In Valmet’s view, stabilising REACH’s legal framework – so less frequent but more significant changes take place – could also benefit companies. Updates to the Candidate List, for example, happen every six months, which in their view is too often, as companies constantly have to cope with change.

“For companies supplying complex articles, it could take six months to even identify if the substance of concern is in their supply chain, let alone do anything about it. The frequency of updates means there is a constant need to chase data from suppliers, only to find that once it is obtained, it is probably already outdated,” Mr Huuskonen maintains.

“Suppliers feel that they get requests for information about substances of very high concern too often and they are therefore less willing to react. Less frequent updates could create a better outcome in terms of getting good data from manufacturers. It is, however, a careful balancing act. If a risk from a substance is identified, there shouldn’t be a two-year wait before something is done about it,” he adds.

Rationalising data

While both Mr Huuskonen and Ms Larsson think that there are useful tools under REACH to help companies manage the hazards of individual chemicals in the supply chain, they also feel that there is room for improvement. “When companies have to deal with several substances at the same time, with multiple roles in the supply chain and with manufacturing processes that are complex, the tools are deficient and the requirements become overly bureaucratic,” Mr Huuskonen says.

To address this, data flows should be simplified to take the complexity of manufacturing processes, supply chains and the final products into account. “To ease decision making, only data essential for ensuring safety and environmental protection should be readily accessible and flow throughout the supply chain. The rest should be stored to be used when needed, but not mandatorily communicated, as this only lessens the emphasis given to critical data,” he concludes.
 

Valmet is a global developer and supplier of technologies, automation and services for the pulp, paper and energy industries. The company’s solutions include complex machinery, equipment, automation electronics, wear and spare parts, and associated expert services. Under REACH, Valmet operates primarily as a downstream user of chemicals, but also as an importer and article manufacturer.

Valmet has research and development units operating across several continents that require a notable amount of chemicals either as raw materials or auxiliary substances. The raw materials contain various metals used in the company’s foundries, as well as monomer and polymers for manufacturing paper and tissue machine roll covers and fabrics.

http://valmet.com
 

Further information:

Communication in the supply chain

Valmet guidance on restricted materials in products

 

 

Interview by Paul Trouth

Published on: 15 February 2018

Top image: Valmet

If you liked this article, you may also like: IKEA: Putting consumer safety first, Newsletter 4/2016 Avoid a headache on 31 May 2018 – make sure your uses are covered, Newsletter 3/2016 Supply chain communication - help yourself, use the tools, Newsletter 1/2016