SVT for TSCA 12 B regulation

[george_ainiveettil]

Hello All,

I am trying to set up SVT for TSCA 12 B regulation in our new system. I have seen there is standard set up provided by SAP and in the configuration the volume determination FM' s are missing. Do we need to add the FMs because as per my understanding TSCA 12 B is not for Volume check . There are 2 environmental parameters available, but we need to add the corrosponding phrase here right? Where exactly these phrases are used in property tree?

Also can anyone please tell me a little bit about the data set up. From SAP help i can see we have to maintain data in TSCA Lists,US( SAP_EHS_1023_053) property for regulation and legal entity and registration date etc . Also there is something as TSCA section and Concentration % , should we maintain any thing here? Now if i maintain the components in this property and assign composition with usage US is that sufficient? I have also seen that the property SAP_EHS_1023_057( Reg status) to be maintained . What data to be maintained here? Is there any other property or data which is required? Now i believe the fill table will get updated with components maintained in TSCA Lists,US with the components with concentration limits...Do we need to maintain anything in specify quantity limits configuration for TSCA 12 B?

Thanks and looking forward for the responses.

Regards

George

[george_ainiveettil]

Hi Christoph,

Thanks for your inputs. I have checked the configuration again and done some changes. Now the filling works with the composition maintained in TSCA lists. The data for components maintained in Reg status and when export orders are created its working. Regards-George

[christoph_bergemann]

Dear George

conclusion: question answered? if yes: Close the thread . Thanks

C.B.

[christoph_bergemann]

Dear George

your story is not clear,

1.) I have maintained the REAL SUB with some composition in the value assignment TSCA Lsits( US) => assuming you have an assigned material to REAL_SUB you have decided now, that property "TSCA Lsits( US)" is the "source" of the composition (to be used later in SVT process)... which "usage" do you use for the data record?

2.) . The usage for TSCA 12B maintained in configuration is used in the TSCA Lists( US) and registration status( company specific) properties. => here i do not 100% your explanation and what you are looking for etc.

3.) When i do filling, system is filling data from "Legal composition" composition rather than in TSCA Lists(US) property components. => it seems to be that your configuration is still wrong.. SVT allows to specify twoe properties to look for a "composition" ; it seems to be that you have here the "wrong" configuration and therefore the process consumes data from "legal composition"

4.) specify scenarios for TSCA 12B the validity area is mainatined as US( same in property also). => the story needs a "property", a "rating", a "validity area" etc... PLease check the OSS note for SVT set up... your story is not aligned to the important consulting OSS note for SVT.

C.B.

PS: please read the blog as well.. may be this might help you

https://blogs.sap.com/2014/06/13/substance-volume-tracking-using-sap-ehs-management/

[george_ainiveettil]

Hello Christoph,

Thanks for your inputs. I have maintained the REAL SUB with some composition in the value assignment TSCA Lsits( US) and also maintained the registration status of the components maintained here ( with TSCA 12 B regulation, legal entity ,export country and registered qty). The usage for TSCA 12B maintained in configuration is used in the TSCA Lists( US) and registration status( company specific) properties. When i do filling, system is filling data from "Legal composition" composition rather than in TSCA Lists(US) property components. I could not understand why the filling happens from legal composition as in Specify scenarios for TSCA 12B the validity area is mainatined as US( same in property also). Thanks-George

[george_ainiveettil]

Hi Christoph,

Thanks for your inputs and appreciate your reply. I understood the TSCA ,US lists are updated through rulesets. But when we do filling and tracking, what exactly the system will look into? I know in standard regulations for SVT we have qty checks and the traffic lights show up in CBRC20. But in TSCA12 B as far as i understood, we dont maintain any qty limits in configuration? So I am just trying understand the concept.

Regards

George

[christoph_bergemann]

Dear George

may be you are lost a little bit...

But let us try it step by step:

"But in TSCA12 B as far as i understood, we dont maintain any qty limits in configuration?" => this is as well my understanding of the legal requirement

" I understood the TSCA ,US lists are updated through rulesets." => not sure about your feedback: by using "rulesets" and data you can "add" data (secondary data) on level REAL_SUB; but this is a "nice to have" and not a "must do do"; so you could maintain TSCA 12B data without usingany ruleset (this might be time consuming.. buit as long as you know the "legislation"... no problem)

"But when we do filling and tracking, what exactly the system will look into?" => here I am not sure what you would like to get; you need to seperate the "fill" and the "tracking" part. SAP has an "idea" in mind what you "could" do for TSCA / TSCA 12B; but it is your turn to decide: what approach you would like to use. And TSCA 12 B is a "complex" regulation (from a certain point of view)

Tracking: here the answer would be "more" simple: you need documents (e.g. SAP MM... etc.); then by configuration etc. SVT decides: Ok: i need to track something... then SVT "drills" down and write the the data in some tables which are then used in CBRC20; normally you would at least need data in CCRCT_EHS_COMP for the tracking part ; this is all very customer specific set up, so no real help possible; for SVT you need "only" to decide which scenario to look at; for TSCA 12B at least "EXP"; therefore you need to schedule the relevant jobs etc.

As i have tried to explain: the set up for TSCA 12 B depends on your decision; you can only track without block; you can track with block etc. You could used "Notification Check" as well... We are not using SVT in relation to TSCA 12B; but it is clearly possible from my point of view.

From tracking perspective: you are not interested in the "amount"; you need "only" to know: does the "component" have some "TSCA 12B" relevance and if so which one (here TSCA 12B is complex !) an dthen based on the "relevance" you need to decide the "follow up" decisions

We have only the SAP documentation in place; no documentation exists (according to my knowledge)

C.B.

[christoph_bergemann]

Dear George

TSCA 12 B set up is discussed here very rarely. Let us first start with the regulation part and then looking on SVT part.

For regulation: https://www.epa.gov/tsca-import-export-requirements/chemicals-subject-tsca-section-12b-export-notifi...

The main legislation message is:

"All of the chemical substances appearing on this list are subject to the Toxic Substances Control Act (TSCA) section 12(b) export notification requirements delineated at 40 CFR part 707, subpart D"

So let us start step by step:

1.) We have a "regulatory list TSCA 12B

1a.) the legal demand focus in "Export" process only !

2.) Data which we need should be maintained in LIST_SUB/PURE_SUB level

3.) Data is normally received by using "content" but you can maintain by your own the needed data

4.) We need a "composition" (so that we know which component of REAL_SUB need a "control" using e.g. SVT)

If you read the legislaiton part: in principly: you need not to "track"

As soon as the company acting is "exporting" something (according to TSCA 12B) you must start "actions"

In most cases: such demands would be realized using the "Notification check"; but "SVT" is a "work around"

Let us assume the process: you use SAP SD. You start with a company / plant in US; you deliver the material to "outside" of US (you need to check the "definition" of US imn the regulation !! e.g. many US regulations are not only valid in "US" but e.g in "Virgin Island" as well). This you need to control; but only if there is a component which is "relevant" (TSCA 12 B listed)

There are many options how you can get what you need.

According to the "regulation" and according to my knowlegde: there is no "company specific" story in place. So SAP_EHS_1023_057 (Reg status) is "out of scope" (from my point of view).

The use of SAP_EHS_1023_053 is much more feasible.

I am sorry to say; according to my experience the specific set up (the specific blue print / final solution) for "TSCA 12 B" is very "customer" specific and there is according to my knowledge no general Blue Print available (Best Practise)

C.B.

PS: rare example of discussion of TSCA 12 B: https://answers.sap.com/questions/9016275/tsca-12b-scenario-in-volume-tracking.html

https://answers.sap.com/questions/12555946/notstat-p-vs-notstat-s.html

https://answers.sap.com/questions/11744833/country-based-blocking-system-svt.html

https://answers.sap.com/questions/156826/what-would-be-the-specify-scenario-configuration-f.html

PPS; it is important to understand the "legislation" and the two env. parameters:

E.g. one of them: SVT_TSCA_PHR_ANNUAL

Check https://www.sapdatasheet.org/abap/cus0/cbrc_quan_tsca.html

https://help.sap.com/viewer/8a399f5444164440ac4f426e847ec901/6.17.17/en-US/d6cdc253d0a4b54ce10000000...

Here you find this information:

For the support of quantity-independent regulations, also note the documentation for the IMG activities Set Up Notification Check und Set Up Monitoring for TSCA 12B in Customizing for substance volume tracking.

So as i have tried to explain above: for TSCA 12 B there is no need exsting to "control" volume limits

Last but not least; if you are interested in TSCA 12 D (D !) I believe we have only one thread: https://answers.sap.com/questions/10469018/warning-messageregulation-tsca-8d-no-substance-is.html