How to deal with legal/regulatory changes (using SAP EHS MANAGEMENT)?

[christoph_bergemann]

What are the business needs to use SAP EHS MANAGEMENT?

In most of the countries chemical companies must fulfill local or global regulation/legislation needs to e.g. produce chemicals and to sell them. SAP EHS MANAGEMENT can be used to fulfill those demands. Now with the starting of "Management of Change" (http://help.sap.com/managementofchange) approach the whole management of changes (either data or document content et.c) process might be integrated better in SAP but the use of SAP EHS Management itself is a matter of internal organisation of a company as well.

About SAP EHS Management

Document SAP EHS Management for Beginners gives (tries to give) an overview of the many SAP modules in SAP EHS Management. The below listed topics are mainly related to the modul called: SAP EHS Management as Part of SAP ERP. It does not cover the options and challenges in context to the other SAP solutions listed there. 

Challenges in the use of SAP EHS Management as Part of SAP ERP

What are the "basic needs" and why might SAP EHS Management help?

a.) in most of the regions you need to create a Safety Data Sheet and you must provide it to the customer who receives the corresponding material/chemistry=> this can be fulfilled clearly with SAP EHS Management

To create a SDS/MSDS according the legislation/regulation you need to consider

• you need data maintained (e.g. on REAL_SUB, LIST_SUB, PURE_SUB etc.) level. To do so you will need: 1.) phrases, identifiers, propertry tree content and other stuff (customizing must be done, phrases must be available etc.). And you need "legal content"
  2.) "Legal content" does mean: you need data maintained as OEL, labeling data etc. This data can be maintained by your own or you can buy legal content. The "legal content" will in most cases change once per year; so there is the need to make sure that you have corresponidng data in the system. This is not only related to LIST_SUB level but data on LS_UN_SUB level as well
  3.) to facilitate the preparation of "add on data" needed for SDS/MSDS you can use "rulesets" which are delivered as well by content providers
  4.) At the end you might have the need to update your corresponding WWI layout because of changes in the legislation

b.) in most of the regions you must make sure that you fulfill the transport regulations. Part of that (and sometimes "ignored" a little bit) is the topic of "packaging" as your are only to transport the chemical by using proper packaging => this can be fulfilled clearly with SAP EHS Management

 

• 1.) As mentioned above: some part of data maintenance can by simplified by use of "content providers"


• 2.) You can get data but e.g. updates on rulesets as well
  

 

BUT in context of DG topics the support is "limited" (e.g. mainly in context of the packaging part) 

c.) in many regions you must make sure that the chemical is stored properly (without risks to humans and the environment) => this can be fulfilled clearly with SAP EHS Management

 

Storage does mean here: store together; make sure that you can create e.g. SARA reports,  fire brigade lists, and similar stuff


 

d.) on the top there is the need sometimes to prepare "Standard Operating Procedures"  => this can be fulfilled clearly with SAP EHS Management

 

e.) and SAP EHS Management can be used as well in the process to get permission to build a new plant (e.g. Seveso etc.)

=> this can be supported/fulfilled clearly with SAP EHS Management

 

f.) and you can use SAP EHS Management in context of e.g. chemcial weapon convention and other "legal trade" regulations

 

=> this can be fulfilled clearly with SAP EHS Management

g.) There is the need to create "chemical inventories" (German: Gefahrstoffkataster) =

=> this can be fulfilled clearly with SAP EHS Management

 

h.) You need to take care e.g. regarding REACH, TSCA, CEPA topics (management of amount of substances to be registered)

=> this can be fulfilled clearly with SAP EHS Management

 

i.) there is the need to exchange data using e.g. XML in many contexts (either for industry purposes (IMDS) or for legal reasons (REACh)



=> this can be fulfilled clearly with SAP EHS Management

 

j.) there is the need to manage company internal changes in regards oc legislation. (e.g. now option of Management oF Change is delivered; some aspects are as well part of SAP Product and Reach Compliance Suite)

=> this can be fulfilled clearly with SAP EHS Management

 

k.) there is the need to handle the chemistry as such within company (e.g. now more related to "Component Extenstion for SAP EHS Management)


 

=> this can be fulfilled clearly with SAP EHS Management

etc.

BUT KEEP IN MIND. REGULATIONS ARE CHANGING. NEW REGULATIONS CAN COME UP FAST ETC. Example: Korean Reach compliance

But taking all that into account  what does that mean on daily basis?

You as chemcial company must make sure that you manage the "change of data". E.g. many companies do use external providers to get updates in regards of e.g.:

1. phrases


2. rule sets


3. WWI layouts


4. legislation data

On the top SAP is now delivering a lot of additional services and there is clear trend of use of Cloud based solutions or to manage the data/documents using "services".


 Based on the permant changes in legislation SAP is reacting on that by e.g. delivering up to date property trees. But not all of the topics are covered and/or must be dealed with by using additional services from SAP:


Examples are:  sometimes you need new identifiers etc.

One can assume that at least once a year some minor update regarding all "technical" content is needed to still fulfill all legal requirements and clealry then ther eis the need to look for data and maintain them (and may be on top release WWI reports e.g. SDS). And this is only the technical part. The business upate process need to be triggered as well in a timely manner (e.g. REACh does have sometimes very short time limits which need be considered).

But now after you have imported the new data? What is the next step? Some companies create simply the new safety data sheet, some others try do identify: what does the new data mean? How many chemcial materials are effected etc.? How to deal with the set up of new WWI documents (new may be relevant version of safety data sheet)? Some companies use internal workflows (not using SAP system as IT system to support this process); less use the EHS workflow (as most of them might believe this might be to complex). Some use the automated SAP EHS mechanism to generate new Safety Data Sheets (but still need to handle in many cases the "Release" of the generated documents). But today this is not sufficient any more. You have to take care about content of label data and label reports as well etc. Correlate to that is the topic of "relabeling" need. At least tomake sure that you have the correct label available.

Therefore before you start a SAP EHS Management project you should be sure that you understood your external and internal needs, especially your internal organisation and you should have a plan established regarding roll out (by region? by SAP EHS module or other criterias).

But even if you have finished with the set up SAP EHS Management will not be stable because of the permanent legal changes and adaptions. And many companies have IS/IT governances taking care about the use of recent SAP software. Using the recent one provide chances to optimize processes. E.g. with SAP ERP ECC 6.0 EnhPack 7 more options are available in context of GLM. Therefore you have new options but  you need to decide how they can help you in your daily business and how to get this improvement in place from technical perspective (and clealry sometime regression test are needed a trainings etc.)

Depending on the region there you act you man need to consider e.g. the use of EHS Substance Volumne Tracking and (e.g. REACh, TSCA, CEPA context) the use of SAP Product and Reach Compliance Suite.

Now as there is a tend to use the "Component Extension of SAP EHS Management" you have may be a further software layer to take into account: what will happen and what need to be done if a regulatory change happens?

SAP EHS Management itself does contain a lot of suitable tools and technique to help companies. It is "only" a matter to decide which of the IT processes are useful, need to be optimized etc.

Without a good a stable process (set up of organisation etc.) to deal with legal/regulatory changesyou will not suceed taking care regarding the many challenges.

What can we expect of SAP in the next years regarding that?

Tools to help the Management of Change process will be established more and more and hopefully integrated more and more. The software it self will get "better" (based on enhancements using e.g. Business Functions). The use of "what if scenarios" might be more simpler as now. And regarding the trend to "analyze" the data (business quality etc.) we can expect hopefully that SAP will support the chemical companies as this is a "basic" need to analyze and check: how compliant are we? Can we do better? There is a lack "information"? What will happen if we exchange raw material A by B (e.g. does it have an effect on labeling; on status of registration). Does it hinder us to do more business? There do I use "hazardous substance? Can I avoid them? what does the use of this substance means for the employee? Which risks need to be considered for him/her and for the environment. How to reduce the risks? What about if I use many recipes for doing the same? How to handle eg. in this case "FDA" requirements.

A workload on the top is: the customer is always asking for more information on the products. Therefore the option to prepare inquiries etc. to retrieve the information might be a critical fact itself. Here you need to dig deeper as SAP EHS Management can help you (check e.g. http://help.sap.com/saphelp_erp60_sp/helpdata/en/a7/286cb50a6c11d28a220000e829fbbd/content.htm; context "TREX" search engine). SAP BW and similar approached can help as well.

As with regulations like REACh one can expect that you need "enough" time to make sure that you are prepared as in many cases you need to maintain more data and most of the data is not available and therefore you have to check there to find that etc. And even if the legislations is in place you need to take care about changes in your organization, in market etc. (e.g in context of REACh: you must take care regarding new "uses" to register, to make sure that you have registered any substance in the correct tonnage band; you need to take care regarding GHS etc. etc.).

But at the end: even if the software might be "stable" neither legislation/regulation is stable nor the data related to that (e.g OEL Limits).

Therefore to a certain extent we are talking about "automating" of processes. Is there really the need to have an expert in place to check content of safety data sheet, about dangerous goods relation topics etc.

We will see how SAP can support this in the future.

This is clearly a challenge but without taking care we need to make sure that we understand e.g. REACh: No data no market

And this seems to be a "international" trend now. Let us hope that SAP provide to us new further innovative solutions and will provide tools in place which can be used for efffective data management and the management of the change of data and e.g the change of content of documents. 

Please check as well these documents:

Determing Chemical Compliance with SAP HANA in Product Development

Achieving True Product Integrity

Featured Content for Chemicals

SAP HANA Chemicals Uses Cases

Best Practices for Chemicals - SAP Solution Manager

REACH Compliance Assessment

SAP REACH Compliance Solution Process Flow

How to Use SAP Best Practices for Chemicals During SAP Implementations

http://scn.sap.com/docs/DOC-1887

Bulk Transportation Scheduling for Chemicals Supply Chains

Bulk Transportation Execution for the Chemical Industry

Getting Started with Chemicals

Sustainability Strategies for High Performance in the Chemicals Industry

Get actual information about SAP for Chemicals

Are you capturing all information required? Can you prove and improve process compliance?

 

Take a look at SAP for Chemicals to get more input

BI Reporting

SAP is delivering a lot of BI reporting stuff in context of SAP EHS Management. E.g. check: 

SAP EHS Management - BI Content & BI Content Extensions - SAP Library

http://sapinsider.wispubs.com/Assets/Articles/2010/July/Go-Beyond-Compliance-With-SAP-EHS-Management...

http://help.sap.com/saphelp_ehsext30/helpdata/en/2c/5ac523a1244780b535f08340308828/content.htm

SAP EHS datasources and extractors list for BW (Environment, Health and Safety - )

 All these tools and techniques can support you dealing with legislation changes and these can be used on regular basis to get a report/status about compliance in your company. There is as well a trend to use Dashboards and similar stuff and we have more SAP mobile solutions in place.

Compliance Checks

Examples to execute compliance checks either in SAP EHS only or together with GTS are listed here:

 

Link	Type	Remark
Examples of Integration of SAP EHS Management into other SAP Solutions	SDN Document	To give an overview
http://help.sap.com/saphelp_gts80/helpdata/en/40/ef2d1b7a774addb6f988a0c499f409/content.htm	SAP Document	Integration EHS <=> GTS
EHS Integration points with GTS	SDN Document	Integration EHS <=> GTS
Dangerous Goods Information (EHS) in GTS	SDN Document	Integration EHS <=> GTS
SAP Product Compliance Managers Summit	SDN Document
Compliance Check (EHS-BD-CCK) - SAP Library	SAP Document
EHS Compliance checks	SDN Document
consolut - RMS_COMPL_CHECK - Set Up EH&amp;amp;S Compliance Check for Recipe Management	Other Document	Compliance Checks / Recipe

 

Appendix

Will be enlarged in the future


 

Links	Type	Remark
Extracting data related to 0EHS_PHRASE_TEXT Extractor. - Toolbox for IT Groups	Extractor
SAP EHS-PS datasources and extractors list for BW (Environment, Health and Safety - )	Extractor
consolut - DataSources for Data Extraction to BW (New) ( RELNEHS_APPL200_BWDATAS )	Extractor
Data Extraction to BW - Foundation for EHS Management (EHS-MGM-FND) - SAP Library
consolut - EHFND_BI_BADI_OLIST - BAdI: Determination of Objects to Extract
HCM Data - SAP Documentation
Incidents (Group Data) - SAP Documentation