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Research among professionals to explore the readiness of the chemical industry for REACH
Chemical Industry REACH Research
July 2009
Reference Number: 5023
Prepared by:Jessica Hall, Reed Business Insight
On behalf of:Mark Radvanyi, Head of UK/ I Media and Analyst Relations, Accenture
Agenda
2
Background and Research Objectives
Methodology
Main Findings
• Respondent profile
• Company and REACH program characteristics
• Becoming REACH compliant
• Maintaining operational REACH compliance
Conclusion
Appendix
More about Reed Business Insight
3
Background
REACH is a new European Union regulation concerning the Registration, Evaluation, Authorisation and restriction of CHemicals. It came into force on 1st June 2007 and replaces a number of European Directives and Regulations with a single system
Research ObjectivesTo understand…
how different companies within the chemical industry have set-up their REACH programs
the progress, challenges and emerging solutions with regards to becoming compliant with all REACH requirements
the progress, challenges and emerging solutions with regards to staying operationally compliant with all REACH requirements
4
Methodology
• An online self-completion survey was emailed to the ICIS database of chemical industry professionals
• Potential respondents were encouraged to forward the survey to others in the company responsible for REACH
• A free prize draw to win an iPod Touch was offered to boost response
• Over 301 responses to the survey with 134 fully completed
• Results shown are based on those answering each question
• Fieldwork took place between 8th June and 26th June 2009
Respondent profile
6
Annual revenue of companies
Base: All respondents (126)
What is your company’s annual revenue?
7
Number of employees
Base: All respondents (128)
How many employees does your company have?
8
Type of chemical company
Base: All respondents (128)What type of chemical company do you represent?
Spontaneous mentions: Chemical converter, Advanced composites manufacturer, Mineral oils, Licensing and catalyst supply, Injection moulder, white goods production , commodity polymers trading
9
Job title
Base: All respondents (134)Which of the following job titles best reflects your position ?
Spontaneous mentions: Regional Procurement, Technical staff, Product manager, REACH Data Manager, Senior Research Scientist/REACH coordinator, Product Engineer, Assist. Quality Assurance manager
10
Organisation headquarters based in…
Base: All respondents (125)
Where are your organisation’s headquarters?
Company and REACH program characteristics
12
Just over a quarter of respondents work for companies deriving more than half their revenue from EU based clients
Base: All respondents (301)
Approximately what proportion of your company’s revenue derives from clients based in the EU region?
13
The majority of companies have pre-registered in excess of 1000 substances for REACH
Base: All respondents (251)
How many substances have you pre-registered for REACH?
14
Though not all anticipate registering all the substances pre-registered
Base: All respondents (88)
What percentage of your pre-registered substances do you anticipate that you will register? (Please type your answer below and if this is not 100% please give reasoning)
• 31% of respondents said they would register 100% of the substances they had pre-registered
Due to cost and work required, we will register the most important products for now
75% - We have decided to attempt to obtain certification from suppliers for substances sourced outside of EU
90 to 95% Some products are in a development status and will be registered only when we will obtain approvals from customers.
30% - the rest should be registered by our suppliers.
50%. We pre-registered chemicals that we thought had potential. But considering the costs involved, we will probably have to scale back.
85, due to high registration cost complexity
“
”
15
The approach to REACH is largely centralised
Base: All respondents (218)
As a company do you take a centralised or decentralised approach to the REACH challenge?
16
72% have a REACH team. Half work for companies where the REACH team includes representatives from safety, health & the environment
Base: All respondents (222)
If your company has established a designated REACH team, which functions are represented in this team?
17
Over a third have a formal steering committee for REACH. A third of these committees report to the CEO
Base: All respondents (233 / 81)
Is there a formal business-led steering committee for REACH? / What is the highest organisation level represented in the steering committee?
Spontaneous mentions: Plant manager, General manager, Purchasing Director
18
Lowest levels of REACH awareness are thought to be at board level
Base: All respondents (205)
How would you rate the level of awareness of REACH related issues at each of these levels in your company?
19
Key findings
• Companies have typically pre-registered over 1,000 substances• However it is expected that some of these may not be registered• Two-thirds of companies take a primarily centralised approach to
overall REACH governance• 7 in 10 companies have an established REACH team • The REACH team is most likely to include representatives from safety,
health & environment, regulatory affairs and sales & marketing• Over a third have a formal steering committee • More than half of these committees report to the CEO or a board
member• Business unit led, function EVP/SVPs are perceived to have the
highest levels of REACH awareness and board level the lowest• However it appears that awareness could be improved at every level
Becoming REACH compliant
21
Companies have made most progress with pre-registering substances and building an inventory
Base: All respondents (191)
How would you rate the progress of your company with regard to:
22
Related costs are likely to be the biggest challenge faced in becoming compliant
Base: All respondents (164)
What are the biggest challenges you face in becoming REACH compliant: (Please mark the top 3 only)
Spontaneous mentions: Problems and bugs with REACH IT, Unclear/ different understanding of REACH regulations within the supply chain
Passing on costs to customers!
23
From verbatim comments, cost is a critical challenge especially for the smaller businesses. Many respondents do not know how they will overcome the challenges facing them
For your main challenge please elaborate and describe how you foresee managing and overcoming it.
Will likely drop some products
For small and medium sized chemical formulators exporting to the EU, REACH forms a significant cost management challenge. The more successful you are the higher the cost
We will have to make commercial decisions over whether to continue selling certain chemicals
A clear picture of total cost involved is missing. Therefore for some products we cannot decide to actually import & market in Europe, effectively having to change our business strategy.
I don't. The cost to register the business we have in Europe far exceeds the value of these sales. Once the final deadline arrives we will be forced to stop selling into Europe.
Our only chance to overcome this challenge is if sales exceed costs. Very close at this point. Otherwise, we withdraw from the market.
“
”
24
Time, communication and involvement with SIEFs/Consortia were also frequently mentioned as being difficult challenges
SIEF Formation and Consortia is a complete mess, cumbersome, expensive and totally unnecessary. The whole process is on the verge of collapse.
For your main challenge please elaborate and describe how you foresee managing and overcoming it.
Dependence on communication of data within supply chain. Possible solution: Involving other functions in managing the flow of information in the supply chain (Marketing and Sales)
It is the timeline that makes the cooperation within the SIEF a challenge.
We are afraid of how we can establish consortium to collect all necessary safety data and how we can share the related costs with each company.
Timeline set by EU: so many unknowns remain, that it is impossible to foresee the consequences. Moving production outside of Europe shall certainly be an option.
REACH puts additional pressure on critical internal resources for product safety and compliance. Many of those resources do not reside in the EU, so there are additional challenges in communication and managing work.
Communication through sales and purchase dept.
“
”
25
Email is the most likely method of communication with the supply chain
Base: All respondents (160)
Supply chain communication: How do you anticipate communicating within your supply chain?
Spontaneous mentions: Mail, Face-to-face presentation, REACH IT
26
Third party support will be used by over half. It is likely to be used for specialist tasks
Base: All respondents (163)
Do you anticipate using any third party support in the registration effort?
Of those who expect to use third party support, it will be used for:• Specialist tasks and specific expertise 44%• Program management and communication 7%• Address peak loads in administrative / repetitive tasks 6%
27
Nearly half of the SIEFs/consortia respondents participate in have identified participants and structure
Base: All respondents (118)
In general, how much progress has been made in the SIEFs/consortia in which you participate?
28
Some respondents are unsure which tasks will be supported using a REACH IT solution. Communication within supply chain is the most likely
Base: All respondents (118)
Which tasks will you support using a REACH IT solution?
29
Key findings
• 62% of companies have completed pre-registering substances• Just over a third have also completed a substance inventory and a further
25% have this process underway• Most other areas of preparation for REACH have not been started or are in
the early stages • Cost is likely to be the biggest challenge facing companies in becoming
REACH compliant• The implications of related costs are not fully known but include increased
prices and changes to business strategy• The timeline and communication within companies and with the
SIEFs/Consortia are also challenges for many• Communication within the supply chain is likely to be by email• Over half of companies expect to use some third party support in the
registration effort• Tasks to be supported with a REACH IT solution may not have been fully
decided but pragmatic IT solutions are expected to be used in most cases (see appendix)
Maintaining operational REACH compliance
31
Relatively few companies have completed activities for maintaining compliance but more than half have started
Base: All respondents (129)
What is the status of your activities related to maintaining operational REACH compliance in the future?
32
Management of REACH data & documents and related costs are likely to be the biggest challenges faced
Base: All respondents (120)
What are the biggest challenges you see for ensuring operational compliance i.e. staying REACH compliant: (Please mark the top 3 only)
Spontaneous mentions: Motivation, All of the above
33
Many companies are yet to determine which tasks will be supported using a REACH IT solution
Base: All respondents (138)
Which tasks will you support using a REACH IT solution?
34
Key findings
• Most companies have started activities for maintaining REACH compliance but very few have completed these
• Around a quarter of companies have not started any activities for maintaining compliance
• Related costs are also a key challenge for maintaining compliance, as is the management of data and documents
• Over a quarter believe that the authoring, distribution and storage of SDSs will be supported with a REACH IT solution
• However companies are largely yet to decide which tasks will require support from an IT solution and which solutions will apply
Conclusion
36
Overall summary
• Preparation for REACH is underway with teams being established and pre-registration of substances largely complete
• However awareness of REACH related issues could be improved at most levels in companies
• In addition, many respondents have concerns over the challenges they face with becoming REACH compliant
• Few solutions to the main challenges (managing costs, achieving compliance within the timeframe given, communication) are currently established
• IT solutions will play a role in the tasks required for becoming and staying REACH compliant but many companies are yet to determine which solutions will apply
• It is likely that pragmatic IT solutions will be used in many cases
AppendixIT solutions respondents expect to use for tasks relating to REACH
38
Becoming Reach Compliant: Tasks respondents expect to be supported using a REACH IT solution
Base: All respondents (118)
Which tasks will you support using a REACH IT solution?
39
IT solutions: those who expect to support communication within supply chain with a REACH IT solution
Which of the following IT solutions will you be using for communication within supply chain?
IT solutions that will be used:
• Pragmatic IT solutions 77%• Changes to existing systems 35%• Off-the-shelf software product 16% (Respondents mentioned: SIEFReach, SAP REACH
Compliance, Axapta REACH add-in, IUCLID)• Others 7%
Base: All respondents (43)Caution: this question was only asked to a proportion of the sample so the base is low
40
IT solutions: those who expect to support the management of substance inventory and regulatory content with a REACH IT solution
Which of the following IT solutions will you be using for management of substance inventory and regulatory content?
IT solutions that will be used:
• Pragmatic IT solutions 69%• Changes to existing systems 49%• Off-the-shelf software product 13% (Respondents mentioned: AXAPTA)• Others 10% (Respondents mentioned: SAP EH&S, In house programs)
Base: All respondents (39)Caution: this question was only asked to a proportion of the sample so the base is low
41
IT solutions: those who expect to support collaboration within the industry with a REACH IT solution
Which of the following IT solutions will you be using for collaboration within the industry?
IT solutions that will be used:
• Pragmatic IT solutions 71%• Changes to existing systems 29%• Off-the-shelf software product 9% (Respondents mentioned: SIEFREACH, REACH LINK for SIEF IT, IUCLID 5.1.1) • Others 11% (Respondents mentioned: SIEF management software and Internet)
Base: All respondents (35)Caution: this question was only asked to a proportion of the sample so the base is low
42
IT solutions: those who expect to support management of records and documents with a REACH IT solution
Which of the following IT solutions will you be using for management of records and documents?
IT solutions that will be used:
• Pragmatic IT solutions 71%• Changes to existing systems 34%• Off-the-shelf software product 11% (Respondents mentioned: AXAPTA, IUCLID) • Others 20%: (Respondents mentioned: SAP EH&S, In house programs)
Base: All respondents (35)Caution: this question was only asked to a proportion of the sample so the base is low
43
IT solutions: those who expect to support interfacing with REACH tools with a REACH IT solution
Which of the following IT solutions will you be using for interfacing with REACH specific IT tools?
Base: All respondents (35)Caution: this question was only asked to a proportion of the sample so the base is low
IT solutions that will be used:
• Pragmatic IT solutions 81%• Changes to existing systems 31%• Off-the-shelf software product 3% (Respondents mentioned: IUCLID) • Others 13% (Respondents mentioned: SAP EH&S, in house)
44
IT solutions: those who expect to support exposure scenario development with a REACH IT solution
Which of the following IT solutions will you be using for exposure scenario development?
Base: All respondents (21)
IT solutions that will be used:
• Pragmatic IT solutions 52%• Changes to existing systems 38%• Off-the-shelf software product 19%• Others 10%:
Caution: this question was only asked to a proportion of the sample so the base is low
45
IT solutions: those who expect to support workflow management for registrations with a REACH IT solution
Which of the following IT solutions will you be using for workflow management for registrations?
Base: All respondents (19)
IT solutions that will be used:
• Pragmatic IT solutions 63%• Changes to existing systems 47%• Off-the-shelf software product 16%• Others 21%:
Caution: this question was only asked to a proportion of the sample so the base is low
46
Maintaining operational compliance: Tasks respondents expect to support using a REACH IT solution
Base: All respondents (138)
Which tasks will you support using a REACH IT solution?
47
IT solutions: those who expect to use REACH IT for authoring and distribution of REACH compliant SDSs
Base: All respondents (36)
Which of the following IT solutions will you be using for the authoring and distribution of REACH compliant SDSs?
IT solutions that will be used:
• Pragmatic IT solutions 61%• Changes to existing systems 47%• Off-the-shelf software product 8% (Respondents mentioned: Shepherd) • Others 6%:
Caution: this question was only asked to a proportion of the sample so the base is low
48
Base: All respondents (35)
Which of the following IT solutions will you be using for the storage of SDSs (suppliers and internal) and their accessibility by your companies workers?
IT solutions that will be used:
• Pragmatic IT solutions 60%• Changes to existing systems 54%• Off-the-shelf software product 11% (Respondents mentioned: SAP EH&S) • Others 6%:
Caution: this question was only asked to a proportion of the sample so the base is low
IT solutions: those who expect to use REACH IT for the storage of SDSs
49
IT solutions: those who expect to use REACH IT for substance volume tracking
Base: All respondents (24)
Which of the following IT solutions will you be using for substance volume tracking?
IT solutions that will be used:
• Pragmatic IT solutions 54%• Changes to existing systems 75%• Off-the-shelf software product 8% (Respondents mentioned: SAP EH&S) • Others 4%:
Caution: this question was only asked to a proportion of the sample so the base is low
50
Which of the following IT solutions will you be using for operational compliance of purchasing processes?
IT solutions that will be used:
• Pragmatic IT solutions 58%• Changes to existing systems 63%• Off-the-shelf software product 16%• Others 5%:
Base: All respondents (19)Caution: this question was only asked to a proportion of the sample so the base is low
IT solutions: those who expect to use REACH IT for the operational compliance of purchasing processes
51
Which of the following IT solutions will you be using for operational compliance of purchasing processes?
Base: All respondents (18)
IT solutions that will be used:
• Pragmatic IT solutions 44%• Changes to existing systems 72%• Off-the-shelf software product 17%• Others 6%:
IT solutions: those who expect to use REACH IT for operational compliance of marketing and sales processes
Caution: this question was only asked to a proportion of the sample so the base is low
More about Reed Business Insight
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Meet the project team
Diane Lewis, Head of Research. After graduating in Statistics from Bath University, Diane gained her first business-to-business research experience at BUPA. She now has 15+ years experience in research & is a full member of the Market Research Society. Diane is responsible for directing a high performance Research team and works across the whole portfolio of business markets, specialising in Property, IT, Road Transport & Travel . Tel: +44 (0208) 652 8065, email: [email protected]
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Jessica Hall, Senior Research Executive. Jessica has gained several years of research experience since graduating from the University of Nottingham with a degree in English. She previously worked for Research International and TNS where she provided ad hoc and continuous research solutions for global clients. Her experience includes projects in innovation, brand and ad tracking, customer satisfaction and market strategy. Tel: +44 (0208) 652 3429, email: [email protected]
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