How safe are the chemicals in your supply chain?

Jill Kauffman Johnson

Jill Kauffman Johnson

We all knew that U.S. chemicals policy reform was coming… Europe made the first move, with its sweeping new laws governing the design, production and use of chemicals in products (primarily REACH), and now the US is following.

On April 15th  Sen. Frank Lautenberg (D-NJ) introduced the Safe Chemicals Act of 2010.  This legislation aims to reform the 1976 Toxic Substances Control Act (TSCA), by requiring companies to prove the chemicals it uses are safe, rather than presuming such substances are safe until proven dangerous.  California passed similar legislation in 2008.

What this new legislation means is that companies will need to start communicating and exchanging data up and down the supply chain, including providing chemical suppliers with information on how they are using their chemical products. There are several approaches that companies are taking to obtain and analyze this chemical information for both regulatory compliance and for use in business decision-making.

The first approach is for the chemical users to expand upon the chemical information software they already have, to provide more detailed information on chemical usage.  This puts the burden of chemical information management upon the customer to coordinate among the hundreds or thousands of chemical suppliers to provide usage data.

Another more proactive approach we’ve seen in industry is called chemical management services (CMS). The basic concept is that a customer engages a Tier 1 chemical provider to optimize their chemical supply chain and reduce chemical use, costs and environmental impact.  The Tier 1 chemical provider is compensated for providing chemical management services and for not selling chemical product, thereby financially aligning both parties to reduce chemical use and cost.  Currently implemented 12 industry sectors, including automotive, aerospace,  government, biotech and utilities, we’re finding that this CMS approach provides a robust infrastructure to better track chemical information.

As the new legislation makes its way through Congress, how are you beginning to prepare for TSCA reauthorization? Has the new legislation in California already changed the way you work? We’d love to hear from both manufacturers as well as chemical users.

Jill Kauffman Johnson is executive director of the Chemical Strategies Partnership (CSP), a San Francisco-based nonprofit dedicated to promoting chemical use and cost reduction through better supply chain management. CSP will share case studies of successful CMS programs and the latest on TSCA reform at its 13th Annual CMS Workshop: Supply Chain Sustainability in Practice on October 12 in Indianapolis,  kicking off the week at NAEM’s EHS Management Forum. For more information, please visit

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About Jill Kauffman-Johnson

Jill Kauffman-Johnson is Executive Director of the Chemical Strategies Partnership (CSP), a San Francisco-based nonprofit dedicated to promoting chemical use and cost reduction through better supply chain management.

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  1. Rihana

    June 24, 2010

    The potential for TSCA reform is quite exciting, but it should be done in a way that doesn’t sacrifice millions of animals (for toxicity testing) in the name of better protection for human health and the environment. The revised bill needs to mandate and create market incentives to use nonanimal methods and tests.

    I agree that we should use the latest science to assess chemicals. Instead of poisoning animals and attempting to apply that data to humans — which hasn’t worked out so far — we need to make sure a reformed TSCA relies on modern human cell and computer-based methods that provide more accurate data on how a chemical acts on cells and what the impact on human health may be.

  2. Stephen Evanoff

    June 24, 2010


    Thanks for raising an issue of increasing potential business risk (and opportunity) for coporations that operate across the globe. I offer the following observations from a corporate perspective.

    – Product compliance issues related to chemicals tend to be identified through the EHS function, as the regulations are promulgated by environmental agencies, and thus organizations initially perceive them as environmental issues.

    – While EHS can serve as the initial catalyst for action, the product design and procurement functions have the expertise and role in the organization to most effectively develop and lead execution of action plans.

    – Senior management generally does not yet fully-appreciate the level-of-effort and lead time required to adequately address these emerging regulations.

    – The most significant business risks associated wtih these requirements are related to supply-chain disruption, inability to enter markets due to inability to certify compliance, and costs associated with continued use of products being phased out of production due to bans on specific chemical components.

    Product compliance related to chemicals demands enterprise-wdie solutions and top management direction and support. Companies should consider establishing cross-functional teams with clear leadership to create strategy, develop actlon plans and implement solutions. The Product Design or Compliance functions are best suited for primary responsibility. Procurement and Manufacturing can play vital roles. EHS can serve as a communcation facilitator.

  3. K.M. Hurley

    June 25, 2010

    It’s true – regulatory compliance is becoming increasingly complex. An exciting time in manufacturing. As with any new era — and it is a new era — there will be adjustment pains; not all companies will be able to pivot in time.

    Emphasis now and forward is on supplier communication and chemical-level compliance. New paradigm!

    Companies benefit if they:
    • employ easy-to-use supplier communication tools
    • track chemicals, substances, and amounts then compare against up-to-data regulation data
    • insist on robust core technology that is centralized, database-driven and accepts raw material, regulatory and supplier information from many sources
    • work in cooperation, not in confrontation, with suppliers
    • automate, automate, automate

    Summary: It’s best to make the gathering and storage of granular ingredient information as standardized and automatic as possible. This saves everyone – up and down a supply chain – time and money.

  4. Michael Haro

    June 25, 2010

    We are currently switching to a CMS vendor and implementing POU system. Many software, data management and inventory challenges. Adding TSCA, Green Chemistry, REACH and GHS requirements yields the perfect storm.

  5. K P

    July 14, 2010

    UNEP are trying to adress the issue of the lack of an strategic approach to international chemical management:

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