The primary purpose of the proposed Chemical Safety Improvement Act (CSIA) of 2013 is to modernize the standards initiated through the Toxic Substances Control Act (TSCA), which was annexed 37 years ago. The bipartisan bill is intended to protect both public health and environmental concerns, as well as help to facilitate innovation through job growth within the chemical manufacturing industry.
The act is well-intentioned and potentially a great step forward for improving safety in chemical production. However, if manufacturers are unable to comply with the bill’s new regulations and standards, they will neither reap any of these benefits, nor will the act live up to its objective.
The only way to demonstrate compliance is through real-time, accurate data tracking and product traceability. CSIA requires the Environmental Protection Agency (EPA) to define the related information collection and reporting requirements. Specifically, it states that the EPA must establish the rules regarding what chemical processors must report on in relation to the new regulations. The act also states that the EPA must define the level of detail required, as well as the means by which this information should be reported. While those specifics are still to be defined, compliance to this new level of reporting can only be achieved by integrating these new regulations into business systems, most notably enterprise resource planning (ERP), supply chain management (SCM) and enterprise asset management (EAM) solutions.
Just as the old TSCA bill is now outdated, use of older technology can no longer deliver the level of visibility required by today’s government agencies. In order to keep pace with continuously increasing regulations, companies will need to take advantage of new technologies. These new tools can provide greater access to all necessary data and establish transparency into daily operations— enabling flexibility to make quick changes to production.
According to the new act, the Environmental Protection Agency (EPA) will perform safety evaluations on all chemicals, grading them as either “high” or “low” based on their potential risk to humans and the environment. This means chemical manufacturers will need to provide the EPA with easy access to data and records to complete these evaluations. Companies will also have to demonstrate the safety measures they are taking with high-risk chemicals, which can be tracked using a safety management application. When integrated with existing ERP or EAM solutions, safety management technology can help to establish step-by-step checklists for utilizing certain assets. These assets can range in form; one example would be a pump that moves potentially harmful chemicals. Organizations can then show these guidelines to the EPA to prove they are taking necessary precautions to protect both their employees and facility.
The EPA has essentially been tasked with securing the necessary health and safety information from chemical manufacturers. The organization has been instructed to first rely on existing information in order to prevent duplicate investigations. Companies that use an ERP to manage the necessary consolidated data for their chemicals and can readily export that information are able to demonstrate compliance.
The CSIA bill is also designed to help chemical manufacturers bring new products to market by protecting intellectual property and establishing clear parameters around launch requirements. Manufacturers can use these parameters to their advantage when quickly preparing for the debut of their latest innovation. That said, they can only do so if they offer visibility into the production and supply chain processes to prove that the new chemical meets safety guidelines. Because all new chemicals entering the market will now be screened against the bill’s established regulations, the EPA will also have the authority to prevent chemicals from being sold if deemed unsafe. Organizations should be prepared to deliver detailed insight into how their chemicals are made and transported, not just to clear new products for the market, but to keep existing ones on the market.
The EPA might also require that a company make changes, such as new labeling and packaging or altering steps in the production process. Today’s ERP systems are flexible enough to quickly accommodate this type of adjustment without requiring extensive downtime. Employing a configurable solution will help to reduce any stalls in production and better prepare companies for potential changes to the regulatory requirements. By making the necessary modifications quickly and efficiently, manufacturers can ensure that their chemicals will go to market as planned, helping to prevent any monetary loss due to launch delays.
The most critical thing for chemical manufacturers to remember is that if decision-makers cannot tell what is happening in the plant, down to the most detailed of daily operations, the EPA could flag the organization as out of compliance. Providing transparency into processes will allow the government agency to accurately assess potential risks as well as provide companies with greater confidence. A lack in transparency might also translate as a lack of safety precaution, potentially causing an organization to incur additional scrutiny from the government.
Today’s market offers chemical manufacturers an opportunity to benefit from technology solutions purpose-built for their industry. These applications provide the unique functionality necessary to deliver consolidated, real-time information and ensure connectivity between databases and users to promote visibility across day-to-day operations. This type of insight and traceability is exactly what manufacturers will need to effectively prepare for the impending changes to existing or future regulations.