global service providers guide 2015

A guide to global chemicals management and control services

Global Service Providers Guide 2015

sponsored by

Korea

China & Taiwan

Japan

South East Asia

South America

North America

Are you ready to entwine your strategies for regulations around the globe?

Dr. Knoell Consult GmbHDr. Michael CleuversManaging Director Industrial Chemicals & BiocidesTel. +49 214 [email protected]

www.knoell.com

There are a lot of challenges beyond REACH. Acting in a global business environment brings a lot of opportunities, but also new duties for the chemical industry. A key factor for global success besides the high quality of your innovative products - is to stay compliant with local laws and regulations. Are you su ciently informed and ready to cope with these challenges?

We have been an independentservice provider for the chemicaland pharmaceutical industriessince 1996, with currently over450 employees at sites withinthe EU, Asia and the USA.For further information visitwww.knoell.com or call us.

knoell operates a team of experts for global regulatory a airs which is continuously monitoring the quickly changing regulatory landscape.

Our service portfolio includes, but is not limited to: Strategic advice how to meet the regulatory requirements in

your target markets Global inventory status check Check of catalogues of hazardous substances and restricted substances Registration in China, Japan, Korea, Japan, Taiwan, USA, Canada,

Australia and other countries Global SDS service

az_chemical_watch_2015_rz_v03.indd 1 13.01.15 12:27

Fore

wor

d

Chemical Watch | Global Service Providers Guide 2015 Page 1

ForewordWelcome to the fifth annual Chemical Watch service providers guide and directory.

Combining in depth research with our annual survey results, this unique directory brings you a comprehensive view of the complex world of chemicals management and regulatory compliance. Gathering information from both service users and providers, it gives a 360 degree perspective of the market, ranging from consultancy and legal advice, to laboratory and IT, to strategic management; from California to Brussels, Beijing to Seoul.

This year the updated findings on our annual indicators show safe chemicals management within companies is coming under increased pressure from regulators and the market. Yet, our third year of reporting on salaries, career prospects and training, highlights some concerning trends regarding the demands placed on people working in the sector, as some companies cut back on human resources deployed in regulatory compliance.

In the complementary market analysis in this years guide, written once again by experienced chemicals market researcher Cynthia Challener, we look more closely at two new areas: the drivers and trends for software services to support chemicals management and compliance; and the emergence and acceptance of alternative methods to test chemical safety.

We also look at the factors that influence companies choice of service providers.

This years survey findings are based on almost 1,300 respondents from across the world.

We hope you find these insights useful for you as an individual and for your companys prospects

Mamta PatelEditorial Director

Global Chemical Notification REACH, TSCA, K-REACH, CEPA, China Order No. 7

Biocides, Pesticides, Antimicrobials,Nanomaterials

Hazard Communication, GHS Classificationand Labelling, SDS

Global Agent and Representative Services

Testing Strategy and Coordination Toxicology & Ecotoxicology Transport and Dangerous Goods Dossier Preparation and Expert Review Data Compensation

Beijing, China(86-10) 8453-4538

Manchester, U.K. +44 (0) 330 223 0610

Washington, D.C.+1 (202) 266-5020

www.actagroup.com

A scientific and regulatory consulting firm providing strategic, comprehensive support for global chemical registration, regulation, and sustained compliance.

Leslie S. MacDougall Director of Regulatory [email protected]

Ruth C. Downes-NorrissRegulatory [email protected]

Jane S. Vergnes, Ph.D., DABTDirector of Scientific [email protected]

Emma Louise JacksonRegulatory [email protected]

Gyngyi (Pearl) Nmeth, M.Sc.Regulatory [email protected]

J. Brian Xu, M.D., Ph.D., [email protected]

CONTACT OUR EU TEAM:

ACTA_ChemNWFullPg_2015:Layout 1 2/11/15 1:27 PM Page 1

Cont

ents


ContentsChemical service providers editorial .... 5Chemicals management grows in complexity .............................................. 5Solid outlook for chemicals management jobs market .................... 14IT critical to knowledge on chemicals . 23Regulatory acceptance key for alternatives to animal testing ............... 27Outlook for chemicals management and control service providers .............. 31Concluding remarks ............................ 44

Profiles .......................................423E Company ........................................ 48ACTA .................................................... 50APC ...................................................... 52Apeiron-Team NV ................................. 54ARCADIS .............................................. 56ARCHE ................................................. 58bibra toxicology advice & consulting .. 60Blue Frog Scientific Limited ................. 62BSL BIOSERVICE Scientific Laboratories GmbH ................................................... 64CEHTRA ............................................... 66Centro Reach ....................................... 68Charles River ........................................ 70Chemsafe ............................................. 72Chemservice ........................................ 74CHEMTREC.......................................... 76Chilworth a DEKRA Company .......... 78CIS Center ............................................ 80CiToxLAB .............................................. 82DHI ....................................................... 84Dr. Knoell Consult GmbH ..................... 86EBRC Consulting ................................. 88EcoOnline ............................................. 90ENVIRON ............................................. 92

EquiTox ................................................. 94ERM ...................................................... 96Exponent International Limited ............ 98Fieldfisher ........................................... 100FoBiG.................................................. 102GLTaC ................................................. 104International Cosmetics & Chemical Services Ltd ....................................... 106Intertek ............................................... 108iPoint-systems .................................... 110KFT Chemieservice ........................... 112National Chemical Emergency Centre (NCEC) ............................................... 114REACh ChemAdvice GmbH .............. 116REACH mastery ................................. 118ReachCentrum ................................... 120REACHLaw ......................................... 122Regulatory Services International Ltd 124Risk & Policy Analysts Ltd (RPA) ....... 126Royal HaskoningDHV ......................... 128SCC .................................................... 130SSS (Europe) AB ................................ 132TNO Triskelion .................................... 134ToxMinds ............................................ 136Trade Wind B.V. .................................. 138TSG .................................................... 140TV SD Industrie Service GmbH .... 142TV SD Process Safety ................... 144UMCO Umwelt Consult GmbH .......... 146WIL Research ..................................... 148

Niche Profiles ............................. 1513S-SafelyServingScience .................. 151Anthesis-Caleb ................................... 151BIG vzw .............................................. 151Boeije Consulting ............................... 151Bootman Chemical Safety ................. 152

CFCS .................................................. 152Chementors Ltd ................................. 152Chemical Regulatory Affairs Israel . 152Chymeia ApS ..................................... 153CONUSBAT ........................................ 153Danger and Safety srl ........................ 153Distefano Law Office .......................... 153DR MACH Chemical Compliance & Competence ...................................... 154eSpheres ............................................ 154Eurideas Linguistic Services ............. 154HDTS Chemicals Inc .......................... 154Infotox ................................................. 155Jongerius Consult BV......................... 155KREATiS ............................................. 155Linmark Consulting ............................ 155LKC Switzerland Ltd ........................... 156McKenna Long & Aldridge LLP ......... 156Peter Fisk Associates ......................... 156Prefusion LLP ..................................... 156Randis ChemWise (Shanghai) Co., Ltd ............................................... 157REACH Global Services .................... 157Reach Only Representative Ltd ......... 157REACHWise ....................................... 157ReFaC ................................................ 158Rovaltain Research Company ........... 158SCAS Europe ..................................... 158SciVera ............................................... 158Siam S.L. ............................................ 159Spring Trading Company, LLC ........... 159Tox Focus, LLC ................................... 159toXcel ................................................. 159Toxicon ............................................... 160ToxServices ........................................ 160WRc plc .............................................. 160

A-Z Listing ................................. 162

CW Research Ltd, trading as Chemical Watch, publishes news and intelligence to help companies achieve sound chemicals management that responds to the many non-regulatory drivers as well as meeting responsibilities under chemicals legislation worldwide, including regimes such as REACH, CLP, GHS and TSCA. We keep you abreast of policy and business trends across the EU, North America, Asia and the rest of the world. Because we are not tied to any trade associations, government or campaign group, we are able to offer objective news and analysis for all sectors.CW Research Ltd, 2 Nettles Lane, Shrewsbury SY3 8RJ, UK Tel: +44 (0)1743 818 101 Fax: +44 (0)1743 818 121 email: [email protected] www.chemicalwatch.com US office: +1 (202) 803 5869

Editorial Director Mamta Patel, [email protected] Editor Cynthia Challener, [email protected] and Information Editor Nick Hazlewood, [email protected] Managers Kerry Williamson, [email protected] Lotte Spencer, [email protected] Glen Marechal, [email protected] Sonja Davidson, [email protected] of Marketing Richard Butterworth, [email protected] Director Stuart Foxon, [email protected] Director Julian Rose, [email protected]

Distribution policy Copying of this document including electronic circulation is not permitted without consent of the publisher.Disclaimer While Chemical Watch takes every effort to ensure the accuracy of this guide, we cannot take responsibility for any adverse consequences arising from actions taken in response to our content and we recommend that readers take appropriate professional advice.Designed and typeset by Ministry of Design, Bath, UK www.ministryofdesign.co.ukPrinted by Trident Printing, London.Printed on 9 Lives 80 recycled stock.Front cover images Shutterstock, fotolia and Nick HazlewoodFirst published 2015 Copyright and Database Rights 2015 CW Research Ltd. All rights reserved

Strengthening your business globally.

MARKET ACCESSMANAGEMENT CONSULTING

ADVOCACY

LEGAL SERVICES

REACH AUTHORIZATION

REACH REGISTRATION

LEAD REGISTRATION

BIOCIDES

GLOBAL REGULATIONS

PROCESS MANAGEMENT

OUTTASKING

REGULATORY MONITORINGFocusing on your core.

OUT-SOURCING

SUPPLY CHAIN MANAGEMENT

COMPLIANT SUPPLIERS

CONSULTANCYThriving through technology.

DIGITAL SOLUTIONS

WWW.REACHLAW.FI

C

M

Y

CM

MY

CY

CMY

K

REACHLAW_297x210_ver2.pdf 1 5.2.2015 14.42

Chem

ical

ser

vice

pro

vide

rs


Chemicals Management and Control

INTRODUCTIONIncreasing complexity is the key phrase in the chemicals management and control sector today. The number and types of regulations affecting the use, handling and transport of chemicals have multiplied within and across all regions of the world. European legislation continues to be a major driver of demand for both in-house and external chemical management and control services, including overarching substance regulations and legislation targeting specific product groups. In the US, a question still hangs over reform of the national chemicals management and control legislation, causing individual states to take action and pass their own regulations. As a result, a complex patchwork of compliance requirements is emerging across the US.

An increasing number of national regulations around the world, including some in Europe, are further complicating the situation for international companies. The fact that the Globally Harmonized System (GHS) of classification and labelling of chemicals is not consistently applied from country to country is also causing a headache for many.

The need for detailed information on chemicals in products is also placing pressure on brand owners, suppliers and testing labs. Communication of information throughout the supply chain is improving but still has a long way to go to be fully efficient and effective. Managing the data generated for compliance is another increasingly

complex and growing challenge, particularly for companies with many products that are sold into lots of different markets. Ensuring the security of all of that data is a further concern.

While some companies have invested in additional staff in response to the growing level of work, others are under budget constraints and have limited resources. As in previous years, small and medium-sized enterprises (SMEs) struggle the most, but even some larger companies are finding chemical management and control to be an increasingly daunting task. There is, in fact, real concern that many substances will be withdrawn from certain regulated markets due to the inability of suppliers to meet the various data requirements for registration and authorisation of their use.

A discussion of key trends in the chemical management and control market, and highlights of the results of the fifth annual Chemical Watch survey of the regulated community, including both service providers and in-house experts involved in chemical regulatory compliance, are presented below. In addition, we provide an annual summary of the current jobs market. Special sections on alternatives to animal testing and current trends in information technology are also included. We conclude with our annual discussion of user perceptions and general expectations for the chemicals management and control service provision market.

OVERVIEW

Chemicals management grows in complexity

Each year, the Chemical Watch survey seeks to identify the top regulatory and non-regulatory drivers of demand for chemicals management and control expertise, whether those services are provided by internal staff or external experts. Not surprisingly, as in all four previous years of the survey, REACH has been selected as the number one regulatory driver of the market, with 79% of respondents indicating it is the top choice [Figure 1]. The figure is slightly up from the number in 2013 (77%), but still down from the 89% peak in 2012, which coincided with the run up to the 2013 REACH deadline. Specific parts of REACH also scored high with survey participants: the REACH 2018 registration deadline; obligations for substances of very

high concern (SVHCs); and evaluation-related activities and dossier updates are important to 54%, 48% and 43% of survey respondents, respectively. The EU classification, labelling and packaging of substances and mixtures Regulation (CLP) and chemicals legislation in the US are as important as these individual REACH-related issues, with 55% and 48% of respondents, respectively, indicating they are key drivers of the market for chemical management and controls services. Other top issues identified by Chemical Watch survey respondents include legislation in China and South Korea, national implementation of GHS, and the EU biocidal products Regulation.

Strengthening your business globally.

MARKET ACCESSMANAGEMENT CONSULTING

ADVOCACY

LEGAL SERVICES

REACH AUTHORIZATION

REACH REGISTRATION

LEAD REGISTRATION

BIOCIDES

GLOBAL REGULATIONS

PROCESS MANAGEMENT

OUTTASKING

REGULATORY MONITORINGFocusing on your core.

OUT-SOURCING

SUPPLY CHAIN MANAGEMENT

COMPLIANT SUPPLIERS

CONSULTANCYThriving through technology.

DIGITAL SOLUTIONS

WWW.REACHLAW.FI

C

M

Y

CM

MY

CY

CMY

K

REACHLAW_297x210_ver2.pdf 1 5.2.2015 14.42

GET EXPERTS ON YOUR SIDE

You can do your business,we remove the regulatory roadblocks.

www.chemservicegroup.com [email protected]

Chem

ical

ser

vice

pro

vide

rs


Figure 1

LEADING REGULATORY DRIVERS FOR SURVEY PARTICIPANTS

79%

55%

54%

48%

48%

43%

36%

32%

32%

30%

28%

21%

21%

19%

19%

18%

18%

16%

16%

14%

14%

13%

13%

13%

13%

12%

11%

10%

9%

9%

8%

7%

7%

5%

4%

3%

0% 20% 40% 60% 80% 100%

REACH (any)

EU CLP regulation

EU REACH 2018 registration

EU REACH SVHC obligations

US (any)

EU REACH evaluation related activities/dossier updates

China regulationsNational GHS classification, labelling and inventory

notification regulationsUS HazCom 2012 (GHS) Standard

South Korea regulations

Biocidal product regulations

Food contact material regulations

US EPA Work Plan on Chemicals

US: California Safer Consumer Products Regulation

Nanomaterials risk assessment

Taiwan regulations

Packaging regulations

Japan regulations

Turkey regulations

Canada pending GHS in workplace legislation

Canada Chemicals Management Program

International Maritime Dangerous Goods (IMDG) Code

Cosmetics regulations

International Carriage of Dangerous Goods by Road (ADR)

Brazil regulations

Conflict minerals legislation

Agrochemical regulations

US CDR

Russia regulations

Malaysia regulations

Mexico regulations

Pharmaceutical regulations

Medical devices regulations

Argentina regulations

Israel regulations

Veterinary product regulations

% of participants

Regulatory requirements and the development of new regulations have a clear and direct relationship with the need for chemicals management and control expertise. However, there are several drivers that are not related to specific chemicals legislation that can have a significant influence on the development of chemical regulations,

and as such are important indirect drivers of the service provision market.

In the most recent Chemical Watch survey, respondents indicate that economic growth and customer pressure are almost equally important as the top non-regulatory drivers [Figure 2]. Next in importance are government policies and

Chem

ical

ser

vice

pro

vide

rs


the redistribution of regulatory compliance responsibility within organisations, although these two drivers are much less significant than the first two. It is interesting to note that for the second year running, the redistribution of regulatory compliance responsibilities within companies (30%) is thought by survey participants to be nearly as important as governmental activities (33%).

Figure 2

LEADING NON-REGULATORY DRIVERS FOR SURVEY PARTICIPANTS

46%

44%

33%

30%

25%

21%

21%

11%

10%

2%

0% 20% 40% 60%

Customer pressure

Economic growth

Governmental policies/spending

Redistribution of regulatory compliance responsibilitieswithin organisations

NGO pressure

Non-statutory voluntary corporate initiatives/CSR

Downsizing of inhouse chemical management andcontrol teams

Outsourcing of business support functions (by clientorganisations)

Increased commercialisation/better management ofservice provider business

Other

% of participants

What is clear is that companies chemicals management and control departments are inundated. Whether they have in-house staff, rely completely on outside experts, or use a combination of both, they are investing heavily in the area. For example, Axalta Coatings Systems tracks all of the major regulations, but particularly REACH in the EU, the Korean Act on the Registration and Evaluation of Chemicals (known as K-REACH), the Toxic Substances Control Act (TSCA) in the US, and the activities of Environment Canada, each of which can also serve as benchmarks for other national regulations. The company also monitors the CLP/GHS programme worldwide as it is adopted by countries and works with suppliers and customers to address conflict minerals reporting requirements, according to Janis L Nutini, director of global technology planning for product stewardship and regulatory affairs for Axalta. The biggest challenge is keeping up to date on evolving regulatory requirements and business impacts while managing the internal resources and determining what external resources may be required to augment expertise, she states. Dr Mayank Dave, head of quality

with the Indian chemical manufacturer Atul sums it up best: We must comply with all regulations, whether they are REACH-like or product-specific. It can be very difficult, because they all have different guidelines and requirements, but new or revised legislation keeps on coming and non-compliance is not an option.

REACH STILL ON TOPEuropes REACH regulation continues to be the main driver of demand for chemicals management and control services, both for internal compliance teams and external consulting and testing firms, but for many the work is evolving. In the initial years and up to 2013, most REACH-related projects were driven by dossier preparation and substance registration, whilst todays efforts increasingly involve follow-up work from the 2010 and 2013 dossiers, such as testing proposals and compliance check evaluations. In addition, the number of chemicals undergoing substance evaluation is increasing, the candidate list is continuously expanding, and assessment activities (for persistent, bioaccumulative and toxic (PBT) and endocrine disruption (ED) properties) require significant effort.

It is becoming very difficult for any company that has a reasonably large number of registered substances. Although the regulators, meaning European Chemicals Agency (Echa) and member states, seem to be involving industry, and registrants in particular, earlier in the process, it is a challenge to remain on top of all potential issues around chemicals, asserts a product stewardship and regulatory affairs manager from a speciality chemical company. REACH also continues to be a very large project for Celanese, another speciality chemicals manufacturer. Continuing registration work, volume tracking and reporting require significant technical expertise, as does tracking for deadlines and volume thresholds, says Philip J Brondsema, global product steward for the company. He adds that REACH implementation is the project with the largest staff, and is expected to remain so for several years to come.

Many companies have turned to service providers to assist with this ongoing work. For Forschungs und Beratungsinstitut Gefahrstoffe (Fobig), in 2014 its main consultancy services included preparing authorisation applications, updating existing registration dossiers, either due to the clients own initiatives or in response to Echa decisions, and support of companies with regard to substance evaluation for the Community Rolling Action Plan (Corap), according to Klaus Schneider, general manager of Fobig. He notes that the three areas require dedicated, sophisticated approaches to exposure assessment, including information on supply chains and exposure conditions, and in-depth hazard identification for specific endpoints, such as those addressed in Echa decisions or as part of substance evaluations.

This phase of REACH can be challenging both for the producers and users of chemicals and the compliance experts helping companies meet the regulatory requirements. Much of the current REACH work involves answering Echas questions from 2013 registration submissions and evaluations, which means responding to projects as they arrive, and often with limited time to do so. It is consequently difficult to plan under these circumstances, says Martin Richards, a principal consultant with Linmark Consulting.

Administrative activities related to REACH have also been in high demand. For KFT Chemieservice, managing

Chem

ical

ser

vice

pro

vide

rs

Page 10 Chemical Watch | Global Service Providers Guide 2015

joint registrations and addressing numerous questions concerning purchases of letters of access (LOA) as part of its management activities relating to substance information exchange fora (Siefs) have become daily activities for its major and medium-sized clients. The regulatory proposal by the European Commission to improve management and transparency of Siefs has polarised opinion between consultants, lead registrants and small and medium-sized enterprises, according to Rachel Green, technical manager of the Regulatory Facilitation Company (ReFaC). The former group fears increased workload for little return, whilst the latter group is demanding more transparent and equitable cost sharing based only on the data actually required, she observes. Dr Richards, for example, believes that the proposed Sief Regulation has the potential to create a huge amount of extra legal work with no benefit to anyone, apart from lawyers.

REACH authorisations, which have been a key issue in 2014, are expected to continue as a major source of work for service providers for the near term. We received many requests regarding the REACH authorisation process, because it is not well understood yet. It is not clear which uses are covered by a granted authorisation, such as whether the use is valid for the entire supply chain, and whether it covers research and development quantities over one tonne, says KFT managing partner Karl-Franz Torges. ReachCentrum believes that the European Commissions focus on simplifying the process for the granting of authorisations is an important, positive development.

Several industry experts indicate that the first successful authorisations in 2014 are some of the most important events of year. For an executive at a European-based speciality chemicals manufacturer, the granting of the first authorisation to Rolls-Royce for the use of diethyl hexyl phthalate (DEHP) was notable, because it highlighted a possibly unexpected impact of REACH on downstream users.He also finds the very recent decision to consider DEHP as an endocrine disrupting chemical (EDC) is striking, because it seems to completely change the picture for those applying for an authorisation for this substance.

The successful authorisations in 2014 are good news in a practical sense to Rick Stanton, director of SCAS Europe. Authorisation allows time for innovation or continued use when necessary for the specific cases where substitution of a substance of very high concern (SVHC) would be very difficult or impossible from a process or functional viewpoint, he explains.

Exposure scenarios continue to be an issue as well. In many cases, KFTs Dr Torges notes, suppliers are still not prepared or willing to deliver exposure scenarios for substances. In addition, those that do provide exposure scenarios as annexes to safety data sheets, often only provide them in English. The reconciliation of exposure scenarios developed under REACH with those required by individual countries is another important issue that service providers help address, according to Daniele Campi Martucci with Toxicon. It is not sufficient to support REACH-specific issues for clients. They also need help resolving the differences between those requirements and the requirements of Italian regulations, particularly with respect to exposure scenarios, which can be both complex and extensive, he says.

On top of the work related to the 2010 and 2013 registration deadlines, service providers have begun to receive a growing number of requests for assistance with the upcoming 2018 deadline for the registration of substances that are manufactured or imported in quantities

between 1-100tonne/year. We are increasingly involved as representatives of clients in 2018 substance consortia, and we see this business area growing, says Paul Thomas, senior ecotoxicologist and director of CEHTRA (Lyon Agency).

Many service providers are finding that the 2018 deadline is presenting a different set of challenges compared to the previous registration deadlines. For instance, it is necessary to determine the substances for which lead registration dossiers have already been submitted. For these obtaining an LOA will be sufficient for co-registrants (apart from the company-specific parts of their registration dossier), according to Peter Douben, director of REACHWise. He says that for substances yet to be registered, it will be imperative to start early. But, he adds that there is significant reluctance to do so. There is fear of the unknown, because a large number of the companies that must comply with this deadline have not yet been significantly involved in REACH registrations, leaving aside the pre-registration aspects, and therefore do not appreciate the processes involved, he explains. They also often do not appreciate the benefit of starting the process early on, but he warns that leaving matters until the last minute will pose challenges with respect to providing the required elements of the registration dossier.

As REACH implementation progresses, the demand for support services is also continuously increasing from non-EU companies. This work can be particularly challenging, according to Michael Cleuvers, managing director for industrial chemicals and biocides with Dr. Knoell Consult. Sometimes the lack of detailed information and guidance documents is causing problems, he comments.

GHS/CLP A HOT TOPICAs a growing number of countries adopt their versions of GHS, manufacturers and downstream users are faced with a need to comply with standards that deviate, sometimes in minor ways, from the harmonised approach. Most of our clients are very dissatisfied to learn that harmonisation does not mean complete harmonisation. says KFTs Dr Torges. He also notes that in some cases, the task is becoming more complicated because the differences in GHS implementation are only very small, for example different threshold values or no substance specific threshold values are applied. Paying attention to the differences is crucial, he says.

Some clients are electing to generate general GHS (purple book) safety data sheets (SDSs) and classifications rather than country-specific documents. We are finding that it is necessary and difficult to make non-EU clients understand that CLP classification and EU-standard SDSs are not only independent of REACH registration but are required now, says ReFaCs Ms Green. REACHWises Dr Douben finds that he needs to keep reminding his clients that in nine months time matters will be streamlined as a result of GHS to a significant extent. This regulation simplifies supply chain communication and as a consequence they will receive fewer queries from their customers, he says. He also believes that implementation of the newest adaptations to technical progress (ATPs) and increased familiarity will help.

Companies that are choosing to comply with national GHS implementation are also struggling to determine how the language differs from the original European regulations, according to John M Robinson, project manager withGLTaC. In addition to our core translation services, we

Chem

ical

ser

vice

pro

vide

rs


have been receiving enquiries for help with understanding section headings, hazard statements and precautionary phrases, because they are not always equivalent, he says.

With so many GHS implementation deadlines on the horizon, it is not surprising that a noticeable increase in demand for SDS authoring services occurred in 2014. Both manufacturers and distributors of all sizes increasingly faced challenges related to globalisation in the marketplace and changing international regulatory initiatives. This situation directly affected their ability to efficiently and effectively produce and maintain the currency of SDSs, labels, and other hazard communication documents for their products, observes Clark van Scoder, vice president of authoring solutions and services for 3E Company.

For US companies in particular, there is concern over Canadas delay in implementing GHS because there is lack of clarity regarding both the interim and long-term cross acceptance of SDSs and labels with the US, according to Celaneses Dr Brondsema.

For all companies, Dr Torges believes that implementation of GHS and CLP for mixtures will drive significant demand for outside support, in particular for exposure scenarios for mixtures, over the next 18 months. He estimates that only 30% of KFTs clients have changed their classifications and SDSs for mixtures to meet the EU CLP requirements, and he is not sure that all companies will meet the 1 June 2015 deadline.

Finally, several service providers have had requests from clients regarding emergency number information for various countries, even within the EU. Many countries have implemented country-specific requirements for emergency number information that are very different from one another. In addition, the regulations are written in the local language and the people manning the help desks only speak the language of the country. Furthermore, in some countries the information must be provided physically, with an individual form for each mixture. A European solution is in development related to CLP, but it is not in place yet, notes Dr Torges. What is in fact needed is a global solution. We are working with a major US company to provide such a service, he adds.

PRODUCT-RELATED REGULATIONS GAINING TRACTIONIn addition to REACH and GHS, product-specific regulations are gaining in importance. In Europe, legislation covering the use of biocides, plant protection products, cosmetics and food contact materials and packaging are all demanding the attention of branded product manufacturers, their suppliers and regulatory experts. Similar regulations can be found in an increasing number of other countries. The growth of these product-specific regulations, at the same time as REACH and REACH-like regulations, continue to require significant attention. It is important for chemical management and control personnel to have both a broad view and regulation-specific knowledge, asserts REACHWises Dr Douben.

In particular, he points to updates and changes to product-specific regulations like the biocidal products Regulation in the EU, which creates challenges for everyone involved. It is important to be aware of the general rules but also some substance-specific ones which should not be overlooked, he notes. Registration of biocidal formulations in former Commonwealth of Independent States (CIS) countries, such as Russia, also

requires specialised and individual attention according to Dieter Drohmann, managing director of Chemservice, because these regulatory frameworks are generally not yet very specific.

The most important aspect of the BPR today, according to Leondina Della Pietra from ReachCentrum, is Article 95, concerning the list of suppliers of active substances. From 1 September 2015, a biocidal product cannot be placed on the EU market if the active substance or product supplier is not included in the list for the relevant product type. The companies listed have all committed to supporting their substances through EU review programme for existing biocidal products.

Ms Della Pietra also notes that Echas launch of the public activities coordination tool (PACT) in September 2014, which lists the substances for which a risk management option analysis (RMOA) is either under development or has been completed is an important development with respect to the BPR because several biocidal active substances are included.

It is also troubling to Dr Torges of KFT that many SMEs are not aware of the impacts of the BPR, or do not believe it will affect them and as a result have not taken appropriate action. Article importers and producers are not aware of the new labelling demands according to the Regulation, and many have not yet communicated with their suppliers in Asia. As a result, a large percentage of Asian companies will most likely not be on the Article 95 list of the biocidal products Regulation in September, he comments. KFT predicts that 80% of the smaller companies who supply biocidal products will be out of the market by 2016.

Toxicons Mr Martucci notes that his company has received increasing requests for assistance with compliance efforts related to the BPR and the EU cosmetic products Regulation. Because the BPR is so complex, Toxicon is in the process of evaluating which aspects of the regulation it will support. For clients in need of assistance with cosmetic product compliance, Toxicon is focusing on the generation of product information files (PIFs).

Numerous cosmetics and food product regulations emerging in 2014 are significantly impacting the regulatory landscape, according to Christina Widodo, director of regulatory research for 3E Company. There has been increased demand from our customers for data and services related to cosmetics and food regulatory compliance in Asia Pacific and Latin America. From a consumer products point of view, the challenge is that we not only need to understand the raw materials and ingredients used in the formulation of these products, but also how each of the products, for example lipsticks, sunscreens and toothpastes, is regulated, she observes. She also notes that less developed countries often present their own unique challenges as there can be a lack of clarity in their regulations.

To more fully support international clients in the cosmetics industry, some service providers have made a point of developing global knowledge on this growing aspect of the regulatory sector. Conusbat Internationalization Regulatory Service, for example, has established a global network of strategic regulatory partners in addition to providing core product stewardship services for EU cosmetics regulations. According to company president Steven L Hanft, having a global network of experts in cosmetic product regulations is increasingly important, because regulations should be looked upon as a challenge and not a hindrance towards entering a new market.

Stapelplein 70, box 104 B-9000 Ghent, Belgium Phone: +32 9 265 87 58WWW.ARCHE-CONSULTING.BE [email protected]

CLP/GHS

REACHRegistration

EnvironmentalComplianceHave you considered

our MECLAS tool? The smartest way tofulfil your classification obligations for complex

inorganic mixtures.

How can we assist you in getting yourproducts REACH

registered by 2018?

Are you sure your local business activities are in line with the latest

WFD and IPPCrequirements?

ARCHE is an accredited Material Health Assessor

helping you to direct your innovation and leadership towards a

positive footprint.

C2C

BIOCIDES-PPPHave you already

designed your game planto keep your biocides and plant protection products

compliant with the changing legislations?

Safeguard your

market access.

REACHAuthorisation

YOUR PREFERRED PARTNER

Chem

ical

ser

vice

pro

vide

rs


COUNTRY-SPECIFIC REGULATIONS ATTRACTING ATTENTIONIn addition to REACH, EU CLP and national implementations of REACH and product-specific regulations, producers and users of chemicals continue to be challenged with growing numbers of country-specific REACH-like and product-specific regulations, as mentioned above. With respect to country-specific regulations, K-REACH came into force at the beginning of 2015. This legislation is but one of many REACH-like regulations that are being promulgated in countries around the world, including Turkey, Taiwan and China. Many other governments are in the process of developing chemical control legislation, including others in Asia, as well as in India, Russia, and Central and South America, Africa, and the Middle East.

As a speciality chemical company, Johnson Matthey has found itself increasingly involved in ensuring that Asian suppliers of raw material are compliant with the prevailing legislation in their countries of operation. This task can be challenging because official translations of the regulations in these countries are not always available, according to Mark Raffray, Johnson Mattheys group product stewardship director. He adds that the issue is compounded because both official translations of the regulations and guidance authorised by the regulatory agencies are not always available in these countries often leading to doubts about precise interpretation of requirements. Lack of both guidance materials and the ability to directly communicate with the authorities further compounds the problem, says Chemservices Dr Drohmann. For instance, for K-REACH, the registration and reporting rules and guidance materials were not finalised when the Act came into effect on 1 January of this year.

Differences between country-specific regulations also increase the complexity of compliance and often result in the need for more resources. Celanese is focusing on K-REACH, registration requirements and implementation tracking in Taiwan, and registration submissions in China, which are time consuming and, for some product categories, such as food contact materials, uncertain because the regulations are still being established. Compliance with country-specific regulations can also be difficult due to specific requirements for the use of domestic testing labs and specific testing species, such as is the case for China, according to Jos V Cantavella Cabedo, project manager with ChemSafe.

STATE REGULATIONS ARE A CHALLENGE IN THE USDuring 2014, significant progress on a bipartisan bill to modernise the major chemical control legislation in the US the Toxic Substances Control Act (TSCA) was lauded by many stakeholders. The Republican takeover of both houses of Congress boosts the chances of passage of a bill in 2015. However uncertainty over TSCA reform has resulted in many states developing their own legislation.

Leading the way is California with its Safer Consumer Products Regulations, which became effective in October 2013. In 2014, the state released its initial list of three priority products and the draft priority products work plan, which outlines the product categories that will be examined and possibly subject to regulation in 2015-2017. Separately, the states Office of Environmental Health Hazard Assessment (OEHHA) proposed new warning requirements under Proposition 65 in March of 2014. The proposals for

revised labelling content, certain composition disclosures and adoption of GHS labelling elements, received strong opposition from stakeholders. Further amendments are expected in 2015.

So-called green chemistry legislation was passed in several other states in 2014, including Maine, Vermont and Washington. Today, state regulatory activity ranges from banning specific substances in specific products to charging state agencies to develop lists of priority chemicals for which manufacturers and users must provide reports and make certain disclosures.

Concern from industry centres on the attention given to substances hazardous properties, without any consideration for the actual risk presented by use of chemicals in consumer products. These regulations also pose a significant challenge to any company marketing products that contain chemicals into the US, because for the most part each state acts independently. As a result companies need to develop state-by-state strategies for product manufacturing, compliance assurance, regulatory tracking and supply chain management, that also take into consideration any relevant national regulations.

DATA MANAGEMENTNot surprisingly, as the complexity of the global regulatory environment has increased, the need for management of the data involved in substance identification, volume tracking and all other aspects of chemical management and control has increased dramatically. Data management is a critical aspect of ensuring compliance with global regulations, states Johnson Mattheys Mr Raffray. The company has elected to manage this activity in-house and is directing increased resources to its effort.

There is also, according to Kami Blake, a solutions engineer with 3E Company, a widening of the gap between the information needed to meet compliance obligations and the data that is available from suppliers to satisfy regulatory requirements and customer requests for information. These demands seem to be imposed more frequently and have exponentially increased in size and scope in a very short period of time, and this trend will continue in 2015, she says. The key to success, she adds, is to focus on the desired outcomes and essential deliverables of all involved stakeholders across the supply chain. She says this can be achieved by: determining required data sources; launching data acquisition efforts; transforming data and compliance content into actionable business intelligence; integrating intelligence with customer-specific materials and products; and aligning information with compliance requirements, such as client questionnaires, disclosures, certifications and agency-required reports.

Getting the information is the real challenge. Ms Blake acknowledges that sourcing is a significant undertaking, dependent upon knowledgeable resources with the capacity and capability to effectively manage the effort. In addition, the work is not finished once the data and documents are obtained. Validation, enrichment, and contextualisation are the next steps in analysing and repackaging the information in order to fulfil a host of compliance obligations. To add to the workload, Ms Blake notes that compliance requirements can change rapidly, often with little warning. Most information collected to support supply chain material compliance efforts must be re-certified at least annually. As a result, the ripple effect of a data requirement revision can have significant upstream and downstream impacts.Stapelplein 70, box 104 B-9000 Ghent, Belgium Phone: +32 9 265 87 58

WWW.ARCHE-CONSULTING.BE [email protected]

CLP/GHS

REACHRegistration

EnvironmentalComplianceHave you considered

our MECLAS tool? The smartest way tofulfil your classification obligations for complex

inorganic mixtures.

How can we assist you in getting yourproducts REACH

registered by 2018?

Are you sure your local business activities are in line with the latest

WFD and IPPCrequirements?

ARCHE is an accredited Material Health Assessor

helping you to direct your innovation and leadership towards a

positive footprint.

C2C

BIOCIDES-PPPHave you already

designed your game planto keep your biocides and plant protection products

compliant with the changing legislations?

Safeguard your

market access.

REACHAuthorisation

YOUR PREFERRED PARTNER

Care

ers

and

sala

ry s

urve

y


Chemservices Dr Drohmann adds that mixtures present an additional challenge, because many substances, and hence suppliers, can be involved for each mixture, and the confidentially claims of the actors in the supply chain come into play. Not only is the organisation of data important; secure management of data is crucial, and trustee services may be the only effective solution when formulation and other proprietary information must be shared for various reporting purposes, he says.

HOW ARE SERVICE PROVIDERS HELPING?With such a complex regulatory landscape, it is not surprising that different service providers offer support on different types of regulations, different regions of the world, or in some cases different client sets. Toxicon, for example, focuses on clients in Italy and helps them with general regulatory interpretation and compliance support, development of testing and registration strategies, as well as providing legal support for the purchase of LOAs under REACH, toxicological evaluations for substances and mixtures, and data gap analyses.

KFT Chemieservice, on the other hand, has been increasingly providing general consultancy services for all areas and regions, whilst clients turn to Dr. Knoell Consult for regulatory and scientific support, plus study management and general strategic advice. In addition to project management, ReachCentrum has experienced growing demand for its data and financial management, legal support, Sief communications and authorisation and evaluation support services. Outsourcing to testing laboratories remains high, as well, and Dr Thomas of CEHTRA believes that pressure is building in this area, with the most popular labs already fully booked for months ahead. His companys KREATiS subsidiary, which provides high accuracy quantitative structureactivity relationship (HA-Qsar) analysis services, is benefiting as companies look for alternatives that can replace lab testing. Separately, in response to growing demand from consumer product importers, some of which have had bad experiences with enforcement decisions, KFT Chemieservice is establishing

a separate department to help companies determine the marketability of consumer products in the EU.

Of course, the use of external service providers varies widely from company to company as well. Axalta Coating Systems relies on its internal regulatory staff for the most part, but uses qualified testing laboratories for toxicology testing to support registrations and outside counsel when global regulatory interpretations are needed, according to Ms Nutini. Celanese takes a similar approach, with the majority of regulatory compliance work done in-house even though there is increasing complexity and volume of routine product regulatory work, according to Dr Brondsema. The company does contract out legal services for unusual registrations and occasionally for communications with regulatory agencies. Toxicity and ecotoxicity studies are also routinely contracted out, although each study done is designed to meet as many countries requirements as possible.

In addition to testing support, data management and analysis are also the key areas for which a European speciality chemical manufacturer uses service providers. Testing demand is high, particularly for higher tier testing, for example the extended one-generation reproductive toxicity study (Eorgts), developmental toxicity, environmental fate and bioaccumulation. At the same time, data management with respect to dossier preparation and maintenance also remains important, as does the need for expert interpretation and evaluation of the data and results. All of these activities are increasingly handled by outside expert consultants, notes a company representative. Atul, an Indian chemical manufacturer, also looks to service providers to meet data management and analysis and testing requirements, and uses those firms that have experience with the regulations in each country in which it operates, according to Atuls Mr Dave. For Johnson Matthey, consultants have been used to provide support for new chemical substance notifications in China, where the company has recently acquired manufacturing sites. In addition, as required by Chinese regulations, local contract research organisations are used to perform certain mandated toxicity tests.

CAREERS AND SALARY SURVEY

Solid outlook for chemicals management jobs market

Further, albeit slow, economic recovery in much of the world, combined with an increasing chemical regulatory burden, continued to keep the jobs market for chemicals management and control professionals fairly healthy in 2014.

With this fifth edition of the Chemical Watch survey of professionals involved in the chemical management and control sector, we are able to report our third round of results regarding salaries and career prospects. As in years past, many people from a wide variety of organisations and holding a wide range of positions elected to participate in the Chemical Watch salary survey. We thank all of them for sharing this information, without which we would not be able to provide any useful data on salaries, pay rises, and bonus levels in the global chemical management and control community. The results are summarised below and

where appropriate compared to those obtained for the 2013 survey.

Of the survey participants, 31.1% are project or team managers, 29.0% are specialists or technicians, 22.6% are senior managers, and 10.7% are directors or associate partners. Juniors, trainees and government officers each accounted for approximately 3% of the respondents.

Interestingly, despite the growth of global regulations and the continued recovery of the global economy, more respondents indicated this year that the size of their regulatory team decreased in the last 12 months than did last year (14.5% compared to 12.2%). On the other hand, a similar number indicated that they saw and expect no change (52.5% and 58.6%, respectively, this year, Figure 3, compared to 53.9% and 57.4% last year).

Figure 3

STAFFING TRENDS

32.9% 32.4%

52.5% 58.6%

14.5% 9.0%

Last 12 months Next 12 months0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

Decreasing Static Increasing

In addition, fewer Chemical Watch survey respondents (35.2%) believe that job prospects are good within their own country compared to a year ago (40.9%), although fewer believe they are poorer (8.4% in 2014 versus 10.1% in 2013) [Figure 4]. Whilst the numbers are more positive when survey participants consider global opportunities, they still do not see things as positively as they did a year ago; 52.2% see global job prospects as being good today compared to 57.2% a year ago.

Figure 4

JOB PROSPECTS

35.2%

52.2%

56.4%

44.2%

8.4% 3.6%

In your country Globally0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

Poor Stable Good

With respect to career progression, survey respondents also see greater opportunities across the wider jobs market than they did within their own companies, but the numbers are again lower than a year ago. Specifically, 59.3% and 31.2% see good prospects in the overall market and with their current employer [Figure 5] compared to 63.2% and 35.2% last year, respectively. Furthermore, a higher number in 2014 (28.5% versus 24.7% last year) believe that their opportunities for advancement are poor if they do not move

ToxServices excels at providing world-wide toxicology, regulatory, and sustainability-based consulting services.

Targeted Science Solutions

ToxServices specializes in the areas of Alternative As-sessments, Product Safety Evaluations, Environmental and Sustainability Assessments, and Toxicology and Chemical Hazard and Risk Assessments.

We help clients comply with applicable international, federal, state, and local environmental health and safety regulations, and provide clients with strategic technical support assistance and Risk Assessments.

Key areas of ToxServices expertise comprise: Cradle to Cradle CertifiedTM

GreenScreen

Health Product DeclarationTM (HPD) U.S. EPA Design for the Environment (DfE) CleanGredients

Alternatives Assessments Full Materials DisclosureTM (FMD) Study Design, Coordination, and Data Analysis Regulatory Compliance and Expert Witness Support

1367 Connecticut Avenue, N.W., Suite 300, Washington D.C. 20036(202) 429-8787 | [email protected] | www.toxservices.com

Care

ers

and

sala

ry s

urve

y


elsewhere. These results suggest that a greater number of the professionals in the chemical management and control sector that are participating in the job market today are hoping to improve their positions.

Figure 5

CAREER PROGRESSION OPPORTUNITIES

31.2%

59.3%

40.3%

33.7%

28.5%

7.0%

In your company Wider jobs market0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

NeitherPoor Good

Despite these downward trends in expectations for job prospects and progression, 65.3% of Chemical Watch survey participants felt as secure in their jobs in 2014 as they did the previous year [Figure 6]. Interestingly, however, slightly fewer felt that jobs across all roles were more secure than their own roles (19.9% versus 23.5%, respectively).

Figure 6

JOB SECURITY COMPARED WITH 12 MONTHS AGO

23.5% 19.9%

65.3% 67.5%

11.3% 12.6%

In own role Across all roles0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

Less secure Similarly secure More secure

Meanwhile, the level of job satisfaction dropped slightly in 2014 to 55.9% from 59.9% in 2013 [Figure 7]. This change was accompanied by an increase in the number of respondents that took a neutral position (31.5%, up from 27.5%), with no change in the number of participants that are dissatisfied with their jobs (12.6%). The reduced level of satisfaction may be due to an increased workload as many companies in the US and EU are finding it difficult to hire people with mid-level experience that can start contributing from day one. Those few companies that are willing to invest in the training of younger candidates, however, seem to have a greater chance of attracting high-quality workers.

Figure 7

JOB SATISFACTION

Satisfied55.9%

Neither satisfied nor dissatisfied

31.5%

Dissatisfied12.6%

Looking at the average salaries by job title [Figure 8, overleaf], little variation was observed in 2014, as was the case for 2013. Average salaries ranged from 45,200 to 49,000. Due to a strengthened pound and dollar against the Euro, all of the average salaries were noticeably higher when looked at in Euros than a year ago (38,900 to 46,300). However, at constant exchange rates this years average is slight down (from 47,100 to 46,300).

Chilworth Technology Ltd. Southampton Science Park, Southampton. SO16 7NS +44 (0)23 8076 0722 - [email protected] - www.chilworth.co.uk

The Global Experts in Process Safety ExcellenceYour Safety - Our Insight>>

- Organizational Process Safety Programs- Process Safety Management & Engineering- Process Hazard Analysis (HAZOP)- Functional safety (SIF, SIS, SIL)- Emergency Relief Systems- Incident Investigation, Expert Witness & Litigation Support- Compliance (ATEX/DSEAR, Seveso, OSHA, NFPA, COMAH) - Dust, Vapour & Gas Explosion Hazard Assessment & Control

- Flammability/Combustibility Properties of Gas, Vapour, Dust - Chemical Reaction Hazards (isothermal & adiabatic calorimetry)- Thermal Instability & Fire Properties- Electrostatic Chargeability, Resistivity, Discharge Incendivity- Energetics Materials & Explosives Testing incl. Large Scale Facilities- Regulatory Testing (UN, CLP, REACH, OSHA, ADR, DOT, EPA, BPD)

- Covering All Aspects of Process Safety- Tailored to your Business and Organizational Levels- Multiple Languages & Delivery Mechanisms- Instructor Led Content

Laboratory TestingConsulting

Instruments

- Electrostatic, Explosions and Thermal Stability Equipment- Charge Decay Analysis - Field Meters- Lightning Warning Systems

Competence Development Programs

ARCADIS is an international company providing consultancy, design, engineering and management services in infrastructure, water, environment and buildings. We are assisting companies worldwide in the field of product stewardship during the whole life cycle.

Creating balance

development of compliance strategies; compliance audits; employee training.

portfolio management and SIEF communication;

eSDS authoring and compliance check; study monitoring; general and financial consortium

management; data and cost sharing.

STRATEGIC ADVICE

MANAGEMENT SUPPORT

TECHNICAL SUPPORT hazard, exposure and risk assessment

of chemicals; development of chemical safety

reports for registration dossiers; preparation of dossiers for restriction or

authorisation under REACH, including socio-economic analysis;

classification of chemicals and waste according to GHS/CLP;

preparation of RMO analysis; preparation of exemption dossiers.

More information?http://www.arcadis.com/Global_Product_Stewardship.aspx or contact: [email protected]

Care

ers

and

sala

ry s

urve

y


Figure 8

AVERAGE SALARY BY JOB TITLE

48.2

45.2

49.0

47.4

46.4

47.7

45.6

45.6

46.3

0 10 20 30 40 50 60

Business management/development

Consultant

EHS management

Other

Product safety/stewardship

Regulator

Regulatory aairs management

Toxicologist/chemist/scientist

Average salary

Euros 000s

There is, however, more variation in average salaries when considering the type of organisation [Figure 9]. Survey respondents working in the engineering, automotive and aerospace industries earned the highest average salary by far (57,700). Participants with positions in the chemical and life science industries (46,900) and for service providers (45,800) earned the second highest average salaries. Consumer product companies, trade associations and other manufacturing industries paid average salaries of 42,700 to 43,500. Those respondents working for government agencies earned the least of all survey participants (40,600).

There is not much difference in average salaries when considering company size, although they did trend higher with the number of employees. Participants at companies with over 250 employees earned an average of 47,100, whilst those at medium-sized organisations with 50-250 employees earned an average of 45,300, and those at firms with less than 50 employees earned an average of 43,000. Notably, however, the average salaries for each company size are slightly lower at constant exchange rates than they were in 2013.

Figure 9

AVERAGE SALARY BY ORGANISATION TYPE

46.9

42.7

57.7

40.6

42.6

43.4

45.8

43.5

0 10 20 30 40 50 60 70

Chemicals, life sciences and similar

Consumer products, cosmetics and similar

Engineering, automotive, aerospace and similar

Government & agencies

Other

Other manufacturing

Service provider, including consultants, laboratories, lawyers etc

Trade association or professional body

Euros 000s

Once again, company location has a significant impact on earning potential according to the results of the Chemical Watch survey [Figure 10]. Respondents in Europe earned the highest average pay by far (54,800), whilst those in North America and the rest of the world earned on average just under two thirds that amount (35,000 and 36,300, respectively), and less than the average annual salary of 46,300.

Figure 10

AVERAGE SALARY BY JOB REGION

54.8

35.0

36.3

46.3

0 10 20 30 40 50 60

Europe

North America

Rest of world

Average

Euros 000s

ARCADIS is an international company providing consultancy, design, engineering and management services in infrastructure, water, environment and buildings. We are assisting companies worldwide in the field of product stewardship during the whole life cycle.

Creating balance

development of compliance strategies; compliance audits; employee training.

portfolio management and SIEF communication;

eSDS authoring and compliance check; study monitoring; general and financial consortium

management; data and cost sharing.

STRATEGIC ADVICE

MANAGEMENT SUPPORT

TECHNICAL SUPPORT hazard, exposure and risk assessment

of chemicals; development of chemical safety

reports for registration dossiers; preparation of dossiers for restriction or

authorisation under REACH, including socio-economic analysis;

classification of chemicals and waste according to GHS/CLP;

preparation of RMO analysis; preparation of exemption dossiers.

More information?http://www.arcadis.com/Global_Product_Stewardship.aspx or contact: [email protected]

KFT TheCHEMICAL COMPLIANCECompany

Care

ers

and

sala

ry s

urve

y


Not surprisingly, salaries varied with respondent age [Figure 11]. Survey participants ranging in age from 46 to 50 earned the most on average (54,100), which is down slightly on the 54,800 earned in this bracket last year, at constant exchange rates. Another difference from 2013 is the shift in the lowest earning age bracket from the oldest respondents to the youngest. In addition, those survey respondents just entering the workforce earned an average salary of 26,300, which is down from an average of 33,900 in 2013 (at constant exchange rates).

Figure 11

AVERAGE SALARY BY AGE

26.3

35.7

47.2

49.7

48.8

54.1

47.4

41.5

42.9

30.9

0 10 20 30 40 50 60

21-25

26-30

31-35

36-40

41-45

46-50

51-55

56-60

61-65

>65

Euros 000s

For survey respondents who did not receive a promotion at their last pay review, the average pay rise is 2.0% (slightly down on the 2.2% the previous year) and ranged from 1.5% in Europe to 2.4% in North America and 3.38% in the rest of the world (down significantly from 5.1% a year ago) [Figure 12]. On a positive note, approximately two thirds of Chemical Watch survey respondents earned an average bonus of 11.0% in 2014, which is slightly up from 10.8% in 2013. Participants in Europe and North America earned bonuses close to the average (~10% and 11%, respectively), while those located in other parts of the world report receiving much higher average bonuses of around 16%.

Figure 12

AVERAGE PAY RISE

1.5

2.4

3.8

2.0

2.0

3.3

4.9

2.8

4.7

8.4

6.8

6.2

0 2 4 6 8 10

Europe

North America

Rest of world

Average

%

Excluding promotions

Including promotions

Only promotions

The relatively stable and positive metrics uncovered in the Chemical Watch survey support the notion of a healthy jobs market in the chemical management and control sector. The role of regulatory affairs continues to grow in prominence and regulatory budgets continue to rise to meet the challenges of increasingly complex regulations, says John Sherratt, regulatory affairs business manager for European-based recruitment firm VRS Regulatory. He adds that deadlines for regulatory change can create surges in demand for chemical management recruits that in the past were frequently filled by using interim solutions or consultancies, but in many cases companies today believe the growing demands are a step change rather than a blip, and are thus looking to increase permanent head counts within their regulatory functions.

In addition to the growing number of regulations being promulgated around the globe, the improvement in the global economy has played a significant part in driving the upsurge in demand for toxicologists and people with regulatory affairs and product stewardship expertise, according to Terry Leyden, president of the Leyden Group, a Colorado-based professional recruiting and executive search firm focused on toxicology, product safety and regulatory affairs. Mr Sherratt agrees that some of the demand is created by renewed investment by companies looking to enter new markets, many of which now have their own regulatory compliance requirements.

The sector is facing a significant challenge in terms of the number of qualified and skilled personnel, which may have long-term consequences. Demand continues to outstrip the supply of qualified chemical management professionals, particularly in countries with improving economies. UK personnel with integrated knowledge of REACH, CLP, transport, and biocides regulations are difficult to find, which can be an issue for small

KFT TheCHEMICAL COMPLIANCECompany

Care

ers

and

sala

ry s

urve

y


consultancies operating across the full spectrum of EU regulatory requirements, according to ReFaCs Ms Green. European companies in general, according to Dr Torges of KFT Chemieservice, are looking for experienced specialists, but they are few and far between.

In India, there is a shortage of reasonably-experienced application and analytical scientists and general health, safety and environmental (HSE) professionals, according to Atuls Mr Dave. Skilled staff are also in short supply in Asia, according to Dr Brondsema from Celanese. The chemical industry is relatively young, and chemical management regulations are quite new. As a result there are fewer senior people in the chemical industry, less expertise for those in chemical management, and fewer people in the general chemical industry from which to recruit.

It is a huge challenge that is driven by market demographics, states Mr Leyden. Whilst there are a lot of people with many years of experience, companies are looking for people with sufficient experience to go straight to work without any need for training, but not so much that they fall into a substantially higher pay scale.

The lack of experienced people can be attributed to the fact that chemical management is not a typical career choice for new graduates and frequently not identified as an alternative for mid-career professionals. As a result there is a limited pool of potential candidates for the increasing number of positions, according to Dr Brondsema.

The need for experienced people is driven by the fact that the requirements associated with chemicals legislation are becoming more complex, according to Chemservices Dr Drohmann. He notes that technical staff must be expert in not only the regulations, but also their interpretation and the planning of required testing. The current cadence of chemical regulation compliance deadlines is an inhibitor in terms of training early career staff hence the tendency to seek more experienced individuals who can be immediately effective on project work, and who also do not require diversion of valuable staff time for training purposes, observes Johnson Mattheys Mr Raffray. He does note, however, that this approach reflects a myopic perspective given the need to develop the next generation of professionals.

Another part of the problem is that companies have never presented positions in regulatory affairs or product stewardship as positions from which careers can be built, says Mr Leyden. As a result, at least in the US, there are few graduates fresh out of school that are intending to go into the field. Toxicology, however, is an exception to this situation, according to Dr Brondsema. The role of toxicologists in industrial chemical management is well established and is a routine career path for both new graduates and mid-career professionals, he says.

In the UK, Mr Sherratt notes that there are a lot of graduates on the job market, but few have the solid academic qualifications and the right attitude, but those that do have a choice of positions. Karen Machol Piraino, global director of talent acquisition at Axalta Coating Systems agrees that in the US there is increased competition for the top new graduates that are looking for regulatory affairs positions because companies have started to re-engage their college recruitment programmes.Students are receiving multiple offers, and the starting salaries have been increasing. To attract these bright, young people, it is critical to understand what drives their generation and how careers in a company or industry align with those drivers, she observes.

ReFaC, on the other hand, has not had a problem finding new graduates with suitable education and motivation for entry-level positions, but Ms Green notes

that there is a shortage of suitable external training in these areas, and therefore the majority of training is performed in-house. KFT has a similar view. We have had excellent experiences with new graduates. They are young, motivated and looking for challenges, says Dr Torges. His company also offers extensive in-house training and sends employees to special training courses once or twice a year. As a consulting firm that offers training, he finds that one of the best ways to help new employees learn is to involve them in the development of new training programmes. They receive excellent training this way because they have to look very deep into the content and the processes, he explains. Training of new graduates can be a big effort that requires significant time and resources that many smaller firms do not have, however, notes Dr Drohmann.

Even for companies that do not generally hire graduates direct from university, but start people with at least a Masters degree, must do training to some extent, according to Dr Thomas, at CEHTRA (Lyon Agency). We generally hire people with a Masters 2 degree, which means they have worked for two years after receiving their degree in France. Even these people have a limited understanding of regulatory toxicology, unless they have worked on a REACH-related subject as part of an internship. Thus, there is a significant mentoring effort required, even for these hires, he says.

Internships are viewed by some companies as a way to assess graduates and search for potential new staff. However, according to Chemservices Dr Drohmann, for small companies with higher workloads and fewer employees, it is difficult to take on the additional burden of managing interns. Thus, internships are more likely to be offered in bigger companies. Axalta, for example, offers internships across all functional areas, including regulatory affairs and product stewardship. Our internship programme is multi-faceted and is intended to help the college student obtain a broad understanding of the business world and how it is applied in Axalta, says Ms Piraino.

Companies that wish to attract professionals with mid-level experience are offering higher salaries and total rates of pay. Some offer more flexible working conditions as a quality of life incentive, such as working from home, but in general, according to Mr Sherratt, working at a permanent office is still highly valued by most companies. Travel to conferences and seminars and continued training are other benefits that help to attract the right types of candidates.

Many, however, do not have any luck finding people with the level of experience that they want, according to Mr Leyden. Often these companies end up transferring someone from another part of the company to the regulatory affairs department. Because such individuals are familiar with the companys products and culture, less training is required to get them up to speed. Others, and particularly small and medium-size enterprises (SMEs), are in the biggest predicament, according to Dr Thomas, because they cannot afford to increase non-production staffing levels, but at the same time they are rather nervous about signing big contracts with consultancies.

Many companies seem to be maintaining an internal core team for chemicals management with a trend towards more outsourcing, according to Dr Cleuvers from Dr. Knoell Consult. Outsourcing is particularly attractive for certain types of regulatory work, such as the writing of safety data sheets, that do not need to be done on site and do not require that the person doing the job has extensive training in the companys business processes and manufacturing procedures. It therefore makes sense to hire the work out to

IT S

olut

ions


qualified people, many of whom are overseas, and often in India, according to Mr Leyden.

The shortage of talented and experienced people will become an even bigger issue in the US in the not too distant future when many regulatory affairs and product stewardship specialists are due to retire. Companies will lose a major portion of their experience and know-how within a short period of time. Mr Leyden believes companies should be preparing today. There is too much short-term thinking, rather than interest in investing for the long term. Companies really should be looking for bright people with chemistry, chemical engineering, and toxicology degrees and training them, he asserts.

In the meantime, companies looking to fill chemical management positions generally advertise on: their own websites; on industry specific job boards, sites like Chemical Watch with jobs information targeting the chemical management and control sector; and media websites, such as the websites of trade magazines and large job sites such as careerbuilder.com and monster.com. The use of specialist recruitment firms with proven track records is also popular when companies are looking to fill technical positions. Very little advertising takes place in print publications any more. Some companies also work closely with universities and their associated alumni organisations, trade industry associations and social media, particularly LinkedIn.

IT SOLUTIONS

IT critical to knowledge on chemicals

As outlined in the overview of the chemical management and control sector, chemical regulations will continue to increase around the world at a rapid pace. This growth is driving the recognition that chemical management must be considered as a core business process, according to Brian Stafford, vice president of EHS for Biovia-Dassault Systmes (previously Accelrys). Savvy businesses that are seeking to streamline operations will be implementing software solutions that will enable better work flows throughout the organisation and reduce bottlenecks and risk, he asserts. In addition, whilst the desire will remain for specialised solutions that address specific business needs, the day of isolated data silos is over. Data of all types will need to be accessible and integrated digitally to enable businesses to become and remain competitive.

Information technology (IT) solutions are in fact fundamental to the success of any chemical management and control programme, and because there are many different tasks associated with chemical management, there are several different types of solutions available to facilitate the completion of those tasks. It is important, therefore, to understand what tasks need to be accomplished to ensure the appropriate system is selected, according to Vincent Hauville, director of product management at Enablon. The main tasks include: compliance with classification and labelling systems, such as GHS, CLP and the like; onsite hazardous materials management, for example substance registration and tracking chemicals by hazard class, to meet the reporting requirements of regulations such as TSCA; and compliance with REACH and REACH-like regulations that are tied to volumes manufactured and imported.

Because of different demands, companies tend to use different software solutions for research and production facilities.

For research facilities, the first requirement, relating to classification and labelling, can be met using a barcode-based inventory management system that enables centralised chemical tracking. Such systems can be located on site or used as a software-as-a-service (Saas) (on-demand or cloud-based) system. They provide real time chemical container data from receipt to disposal for all chemicals on site, detailing quantity and storage location. Biovias Cispro program is designed to ensure that the

second requirement, regulatory reporting, is also met; a feature the company claims is unique. Cispro compiles the data required for global environmental and right-to-know regulations while other chemical management tasks are being performed. This enables accurate reports to be generated when required, according to Biovias Mr Stafford. Some of the reporting requirements, such as average total quantity per day per chemical, would be difficult to meet without digital tracking of chemical use data. It is also important to note that for multinational companies, the use of the same chemical inventory management system for all sites across the globe is the most efficient approach, he says.

To meet the chemical management tasks required by REACH, however, the above-described chemical inventory management systems are inappropriate, because they are designed to track laboratory use and not the shipment of materials. For compliance with REACH and similar regulations, product formulation data and chemical container data generated by operation planning, manufacturing and logistics systems are needed for efficient global supply chain management, according to Biovia.

In general, effective software systems can help companies secure rapid growth in new regions and markets and accelerate the speed of innovation with integrated processes that drive rapid time to market while ensuring product safety and stewardship throughout the entire product lifecycle, according to Marko Lange, solution manager at SAP.

Many companies today wish to have business intelligence solutions relating to chemicals management. These can include software functionalities such as dashboards and customisable views of various metrics that can be used for administrative, or operational or functional purposes, such as risk assessments or chemical quantities by hazard, says Jerome Marinkovic, chief marketing officer with Chemwatch (Australia). He also notes that chemical approvals with customisable work-flows are very important, because each approval involves several aspects, such as financial, environmental, and safety and health.

More specifically, according to Enablons Mr Hauville, software systems can help companies address many different key business needs, including:

IT S

olut

ions


IT S

olut

ions


O ensuring compliance with product and chemicals regulations around the world, calculating volumes of chemical substances throughout an enterprise, and throughout entire product lines, in order to comply with regulatory reporting obligations;

O determining the compliance status and marketability of products in different countries;

O determining the physical and chemical characteristics and classifications of materials procured from suppliers;

O providing timely and convenient access to safety data sheets and critical health and safety information on chemicals; and

O authoring safety data sheets in a way that saves time and costs, and reduces risks of inaccuracies and non-compliance.Many organisations still manage these various tasks

manually, spending considerable time and effort tracking chemical data and double-checking the data for accuracy, according to Biovias Mr Stafford. There are IT platforms available today that accommodate a variety of different systems for managing chemicals throughout the product development and distribution life cycle. Digital solutions can streamline and expedite these tasks considerably whilst also ensuring real time, accurate data and reports, he adds.

Mr Hauville from Enablon observes that these various needs are addressed by:

O providing access to SDS data on materials and regulatory content on substances;

O analysing the full composition of products, calculating volumes of chemicals at various levels, for example enterprise, business unit, country, individual plant, and screening chemicals using regulatory lists;

O calculating substance volumes through the use of inventory data on materials and products, and through roll-up of quantities using composition information;

O obtaining updated SDSs from suppliers; O storing SDSs electronically; and O automating the SDS creation process.

SaaS systems, or cloud-based solutions, represent the latest evolution of chemical management software. Whilst on-premise software still dominates, most software providers also offer an SaaS option. The increasing use of SaaS solutions is one of four main trends occurring in chemicals management and control software development, says Philippe Tesler, CEO of Enablon North America. The other three include: the convergence of chemical management functionalities under a single solution or platform; increased integration of chemicals management software with the software controlling other business processes; and the growing use of mobile devices.

Over the past several years, IT and business process complexity has grown significantly and has reached a critical limit, asserts SAPs Mr Lange. We see many companies now standardising and harmonising on a single platform, unless a best-of-breed application delivers very compelling business benefits which can overcome the cost savings derived from simplification, he says.

global service providers guide 2015

Documents