Framework for a chemical substance reporting system

Chemical regulations exist to control hazardous chemical substance use within society. As more chemical substances become more regulated, industry must adapt and develop mechanisms to analyze and report data on substances used on their own, in mixtures or within materials. A chemical substance reporting system is required to ensure compliance by identifying the chemical substances used within a product, which can then be compared against regulated chemical substance lists to identify potential business risks, as well as providing safety data to consumers. This paper contributes to material compliance reporting literature by identifying a research gap and presenting a framework model to enable chemical substance information to be collated (internal and external) to allow for accurate chemical substance reporting.

Chemical regulations exist to control and limit the use of hazardous chemicals; to protect the welfare of humans; the environmental and therefore society.
The traditional focus of engineering organizations (Skinner, 1978) departmentalizes data within functional areas using the data, thereby creating data silos, making chemical substance reporting difficult to implement.
The purpose of this paper is to examine the information paradox which has arisen and present a framework which will enable an organization to implement a base layer chemical substance reporting system.

II. METHODOLOGY
A three-step methodology approach was used based on (1) initial literature review of chemical regulations, automotive and electronic industry implementation approaches, business strategies, and data modelling; (2) previous experiences from working as a system design engineer within Engineering, IT and Aerospace and Defence (AD) industries, including drafting the initial IPC-1754 material data exchange standard for AD and Heavy Machinery (HM) industries; (3) expert interviews with AD companies.

A. Supply Chain Evolution
The term 'Article Transformation Cycle' describes the process of taking raw materials, processing substances and mixtures to produce finished articles. (Fig. 1) depicts the article transformation cycle.
A supply chain can be considered a collection of organizations / elements, selling / flowing articles and services, downstream and upstream across a supply chain. The traditional supply chain paradox focused on (1) maintaining quality deliverables; (2) reducing supply chain costs to maximize profit; (3) increasing customer satisfaction levels (Dias and Ierapetritou, 2017;Porter, 1980). Supply chains have evolved from producing simple but labour intensive articles to modern day highly complex modern articles which consist of globally accessible chemical substances, material and materials (Woinaroschy, 2016).

B. Impacts of Chemical Regulation Changes
Each new piece of chemical regulation presents industry with potentially new supply chain risk(s) (Fig. 2). Chemical regulations define lists of substances against which specific actions need to be undertaken, such as (1) notifications to regulators; (2) material declarations from the supply chain; (3) declarations to consumers; (4) safe use guidance, (5) request authorized use of a substance request; (6) even prohibited use of a substance, this information requires substance identification at the article level (

D. The Information Paradox -Traditional Internal Data
Supply Chain Information Flows Chemical substance reporting systems require connected design, engineering, supply chain, distribution systems which can handle data consistently being received / transmitted. A data supply chain is the information flow (internal or external), which requires clear and concise data flow analysis, which can then be readily absorbed by subsystems, against which appropriate risk reporting and risk treatment plans can then be applied. (Fig. 3) outlines a holistic overview of a chemical substance reporting system.
Based on expert interviews the following data supply chain flow was identified: Materials function: define the chemical substance(s); mixture(s) or material(s) to a specification (material / process based).  Figure 3. The chemical substance reporting system context model Engineering function: responsible for transforming raw materials / semi-components and semi-finished articles into finished articles. Stores function: receipt, dispatch articles, together with safe use guidance and customer declarations. Compliance function: (1) analyze data from internal systems and data provided by suppliers; (2) data compared to regulatory substance lists to derive obligations (customer declarations and regulatory notifications); (3) risk analysis of any articles at risk from chemical regulations; (4) generate customer material declarations. Health and Safety function: ensure safety of employees, users of articles and the environment. This sub-system relies on (1) data provided by materials function relating to substance(s), mixture(s) and material(s); (2) data provided by engineering function relating to substance(s), mixture(s) and material(s) used within manufacturing cycle; (3) all functions providing general safety information. Sales function: (1) liaise with customer; (2) distribute any customer declarations including any safe use guidance. This sub-system relies on (3) health and safety function provide any article related safety information; (4) compliance function to provide any material declaration data. Quality function: ensure quality is maintained across the organization. This sub-system works across other functional areas to ensure quality procedures are in place. Supply chain: supply (1) chemical substance(s); (2) mixture(s); (3) material(s); (4) semi-finished articles and; (5) finished article(s). Suppliers will supply articles to the stores function, providing supplier declarations which detail if any regulated substance(s) are contained within a supplied article(s). Chemical regulators: define chemical substances which require compliance reporting, notifications, and potential further restriction. Customers: end consumers of articles produced. Issues arise where variability in data consistency and quality causes incorrect analysis taking place.
Adopting a one chemical substance or mixture for one specification approach will result in improved configuration management enabling greater substance traceability. The negative aspect will be in the more frequent generation of new engineering drawings.
Maintaining data ambiguity by using many chemical substances to one specification (many to one), incurs cost inefficiencies of having to (1) checking all data from substance(s) to specification; (2) verifying actual substances used to enable determination of declarable and nondeclarable chemical substance(s).

F. Chemical Substance Reporting Paradox
Chemical regulations: state chemical substance(s) that need to be traced and reported above a threshold (ECHA candidate list, 2017; ECHA authorisations list, 2017; ECHA restrictions list, 2017) Engineering definitions: state specification(s) which require substance(s), mixture(s) or material(s). Supply chain: (1) complex supply chain tiers; (2) spanning multiple nations / regions; (3) cost constraints; (4) competition restrictions; (5) security restrictions (defence); (6) intellectual property issues. The lowest supply chain tier has the most accurate data within the article transformation cycle, as the article is transformed multiple factors (1-6) can constrain the flow of information. In the context of complex articles, if you ask a supplier to complete a supplier declaration, the response will invariably be 'we produced as per your specification' which then needs additional discussion with a supplier to confirm the precise chemical substances which were used, and why they need to be reported. Thus, envelops a level of angst -additional effort required, which may not have been originally defined in contractual terms / costs. The chemical substance reporting paradox results in the supply chain reporting struggling to be processed beyond the mid-chain tiers, unless a standardized chemical substance reporting approach is adopted with a standard list of data elements, declarable substances, and template document (XML / Web based) for transmitting requests and receiving data supply data.
The chemical substance reporting framework model presented in the following sub-sections covers: Creation of master chemical substance list, to monitor substances, mixtures and materials on hand. Creation of data elements to be used within the framework. Creation of a supply chain chemical substance reporting questionnaire. Map out supply chain data flows. Agree supply chain chemical substance reporting. Execute supply chain chemical substance reporting requests -push or pull. Receive data back. Evaluate data received back. Evaluate the supply chain chemical substance reporting process and adjust as necessary.

2) Define a master chemical substance list
Review all applicable chemical substance lists (regions where articles are produced and consumed). Create a generic 'Master Chemical Substance List', against which the organization would then take applicable actions ( Fig. 6; Fig.  7).

3) Define data elements and formats
Review internal data supply chain flows of information, derive a common set of data elements ( Fig. 8; Fig. 9; Fig. 10).
Data formats should be simple to use and capable of parsing data. The simplest format to transmit and receive data in is a spreadsheet parsing data in a simple structure. The more advanced formats would be via an XML form.
The master chemical inventory list will act as the reference list against which data from internal supply chain can be queried and analyze any potential business risk(s).

4) Develop a supply chain chemical substance reporting questionnnaire
Define a set of data elements need to be captured as part of a chemical substance reporting supply chain survey (Fig.  11). Existing data exchange standard templates may be used (IPC, 2017; IEC, 2017) may be utilized instead of developing a supply chain questionnaire, the values in (Fig.  11), align to those existing data exchange standards. 5) Understand data flows within a supply chain Assume articles are defined by specifications which define substances which remain on the finished articles (material specifications) and substances which are used in the process of producing the article (process specification) (Fig. 12    Information flows from the lowest tiers (raw chemical suppliers / refiners / formulators / mixers) are the most detailed as it generally pertains to the Materials Safety Data Sheet and Safety Data Sheet data, in which chemical substances/ exposure / handling / labelling data is presented to users.
Define ownership: Which department / function / team will be responsible for the transmission and receipt of the data from the supply chain? What training will be given to the supply chain? How will the training be communicated? How will the data be receipted back, which data formats are acceptable? How will end user queries be handled?

6) Agree supply chain chemical substance reporting
Establish an early supplier engagement process. Ensure suppliers have contract coverage which states the need for chemical substance reporting as part of a 'business as usual' process. Ensure training developed for the supply chain informs them about their legal obligations to report chemical substance presence, above designated threshold levels, regardless of a part being defined by your organization or the external supplier. Establish supply awareness of any chemical substance reporting templates as soon as possible to identify issues prior (via a simple pilot) to being rolled out to your entire supply chain. 7) Execute supply chain chemical supporting reporting requestspush or pull?
A push chemical substance reporting system exists where the lowest supply chain tiers flows information to downstream users within a supply chain (Fig. 13). Push chemical substance reporting systems work best in industries where the articles are regulated and highly defined. Safe Use Guidance -Labelling / material handling information.

Retailers
Chemical Substance Reporting -Declaration of chemical substances within an article against a regulatory or declarable substance list.
Engineering Article Definition -Engineering drawings, material and process specifications.
Compliance Reporting -Conflict mineral reporting / conformity statements. Figure 13. Article transformation cycle: push chemical substance reporting system Complex articles need to be considered as those with high potential data ambiguity. They will require a pull type chemical reporting system, where the highest tiers are initiating the chemical substance reporting information requests to the lowest tiers (upstream) who will then flow the information back (downstream) (Takhar and Liyanage, 2017)

8) Receive data back
Chemical substance reporting questionnaires start to flow back, ensure the data is receipted and stored in a defined location for processing. From a defined location, the data should be collected (automated or manual) and then ingested into a target system. The target system will then process the data. Processed files should then be moved to a processed folder to be used in the event of a system failure.

9) Evaluate data received back
Supplier response rates: record as a set of metrics the dates, names of suppliers who have (pull requests) transmitted completed chemical reporting questionnaires back to the organization. Flag data quality issues: either check all the responses or perform a spot check analysis on a sample set. Flag issues back to respondents where issues have arisen. Perform regulatory impact analysis: run reporting which compares data and highlights chemical substances which potentially require (1) threshold declarations to customers / regulators; (2) require authorizations for continued usage; (3) have been flagged as restricted for specific use condition. Perform business continuity analysis: substances flagged as requiring action (because of performing regulatory impact analysis), identify where these substances are used within the organization or across the supply chain. Develop an action plan: plan the actions which need to be undertaken such as declarations; authorizations; looking for alternative substances; performing last time purchases.

10) Evaluate the supply chain chemical substance reporting process and adjust as necessary
Chemical substance reporting template: use feedback from your supply chain and make any necessary adjustments.
Master chemical substance list: this will require regular updates as more and more chemicals become regulated, adjust the list regularly. Data elements and formats: use feedback from your supply chain and adjust as required.
System reporting: adjust reporting as required.
Additional declarations: where a supplier has flagged the use of a substance of concern, an additional declaration may be required as to understand actions supplier strategy regarding looking for alternative substances.

1) Business function support of the framework model
The chemical substance reporting data model (Fig. 14), the design of this model should allow for analysis and reporting against REACH, RoHS and other regulatory chemical substance reporting.
The data model will also additionally feed into EU Classification, Labelling and Packaging (CLP) (EU CLP, 2017), EU Biocidal Properties Reporting (BPR) (EU BPR, 2012; EU BPR, 2014) and EU Conflict Mineral Reporting (CMR) (EU CMR, 2017) reporting. The outputs could additionally be used to feed into Life Cycle Assessment (LCA) as a secondary data set.
2) Where could the chemical substance data be stored?
The core aim of the chemical substance reporting data model depicts the data elements needed to perform chemical substance reporting as well as the required data elements from an organizations data supply chain.
The chemical substance reporting data model can be implemented in a few different IT systems and platforms ( Table I).
The data model can be applied as either a (1) stand-alone system or; (2) applicable functional data elements added to sub-systems, with data exported to a central reporting solution or; (3) a central reporting solution queries the functional sub-systems.    (Zschieschang, 2014) and decision based modelling (Dumas, Schmidt, Alexandera, 2016)