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The Substance Volume Tracking (SVT) is a sub module of SAP EH&S, to automate the substance quantities calculation according to regulatory requirements.


The SVT bases its calculation on:
  • Materials stock movements in the different SAP modules
  • EHS specifications to which are attached materials on one side and substances to track on the other
  • Scenarios: importation, production, sale, exportation… The scenarios are standard programs adaptable from SVT to identify the materials and quantities to track.
The SVT allows to :
  • Automatically calculate pure substances volumes per legal entity, site, scenario, specification PRCO…
  • Archive the Tracking results in BW to ease the reporting to the authorities.
  • Create warning threshold when the tonnage bands are approached or reached.
  • Create warning event when we export a substance for the first time in a country (example).

Contents

Europe

REACH tracking

Objectives

Track the tonnage of substances that have been imported or manufactured in the REACH zone, by legal entity, in order to prepare updates or new registration and notification dossiers.

Some products or substances fall under specific measures:
  • Water, as solvent, is exempted from tracking in a mixture
  • For an hydrated substance, It is either the hydrated pure substance or the anhydrous part that is tracked according to the Enterprise decision for registration.
  • Biocides listed in Directive 98/8/EC are exempted from tracking, the other ones will be taken into account.
  • The pure substances having an impurity or stabilizer role must be assimilated to the main components of a composition at pro rata of the percentages.
  • The polymeric substances must be declared through their monomers/ other reactants constituting them, using the production ratios and excluding the monomers/ other reactants having a chemical ratios under 2%.
Thus calculation rules, according to the specific measures, were elaborated in order to obtain the relevant substances for the tracking in the “Standard REACH list”.


SAP EHS
  • Specific compositions:
    • REACH list: intermediary composition
    • standard REACH list: mandatory to allow the REACH tracking. This may be manually maintained or populated by the REACH Rules
  • Rules:
    • REACH list calculation
    • Standard REACH list calculation
    • Now combined in "REACH rules"
  • Other PRCO classes to fulfill:
    • Production ratio: to maintain the split of a polymeric substance into its polymers
    • Monomers: to maintain all the monomers used in the manufacturing of the polymer, even below 2% (optional)
System where the reporting is done
  • SAP BW: EU REACH (Core Workbook)

> Refer to the training item: SVT Europe - REACh (broken link)

EU - Audit REACh Traceability IS Tools (ARTIST)

This report complements the SVT report because it provides the full details of the REACH status entered in the PURE_SUB or raw material PROD_COM in SAP EHS. It provides a complete plant or GBU view of the REACH status of substances, ready to use for internal or external audit.

Note that it is only available for WP1 plants at the moment (Rhodia legacy).

>> Refer to the following presentations: (broken links)

Turkey

We are waiting for the publication of the final "REACH Turkey" regulation before updating the SVT report.


North America

USA


1) TSCA 12b or pre export notification
The regulation:
  • For substances or mixtures subject to TSCA Section 5(f), 6, or 7 actions, the exporter must submit a notice to EPA of the first export within each calendar year of export per subject chemical per country of import.
  • For substances or mixtures subject to TSCA Section 4, 5(a)(2), 5(b) or 5(e) actions, the exporter must submit a notice to EPA only for the first export to a particular country; notice of export to a particular country is not required if an exporter previously submitted to EPA a notice of export to that country prior to January 6, 2007.
  • There is no threshold limit for the quantity of the material exported, so even samples are concerned.
  • However it is only applicable if the substance listed is present at >=1% or >=0.1% depending on the substance
What we implemented, concretely speaking:
  • We know if substances are listed or not thanks to the regulatory data we retrieve from SAP ERC* in the Listed Substances
  • Then when the Product Steward runs the rule Notification Status, it populates an output in the class TSCA Lists (US)
  • When there is a relevant delivery scheduled in the logistics system for the material, an automatic warning email is sent to the person in charge of the reporting to the Authorities. A relevant delivery is determined according to the regulation above.
  • Technically the tracking takes place in BW, which allows also access to audit tools.
Refer to the dedicated training item for more explanations and screenshots. (broken link)

2) TSCA Chemical Data Reporting or CDR

The regulation:
  • The regulation requires manufacturers (including importers) to report information on the chemical substances they produce domestically or import into the United States during the principal reporting year. For now the reporting cycle is 4 years.
  • The purpose of CDR is to collect recent information on the manufacture (including importation); processing; and industrial, commercial, and consumer uses of certain chemical substances currently on the TSCA Inventory.
  • Reporting thresholds are used to determine when CDR reporting is required for a subject chemical substance at a manufacturing (including importing) site.
    • The reporting threshold is typically 25,000 lb during the "principal year"
    • Beginning with the 2016 submission period, the reporting threshold will be reduced to 2,500 lb for those chemical substances that are:
      • The subject of a rule proposed or promulgated under TSCA section 5(a)(2), 5(b)(4), or 6,
      • The subject of an order issued under TSCA section 5(e) or 5(f), or
      • The subject of relief that has been granted under a civil action under TSCA section 5 or 7.
    • At 100,000lb/year at a single site, more information are needed in the report
  • The CFR includes a wide variety of elements:
    • Report production volume for each of the years since the last principal reporting year
    • Volume of chemical substance used on-site. EPA is requiring that submitters report the volume of a manufactured (including imported) chemical substance
    • Indicate whether imported chemical substances are physically at the reporting site
    • Report volume exported
    • Identify whether a chemical substance is to be recycled, remanufactured, reprocessed, or reused.
    • Concentration ranges
    • Industrial processing and use information reporting
    • Consumer and commercial use reporting
    • Number of commercial workers reasonably likely to be exposed.
    • etc
  • Numerous substances are in fact exempt from tracking:
    • for hydrates, only the anhydrous substance is reportable
    • by products and co products because they are not manufactured for commercial purpose
    • some polymers
    • isolated intermediates
    • impurities
    • water
What we implemented, concretely speaking:

Because of the complexity of the reporting and the variability of the criteria from one reporting cycle to the other, the scope of tracking is deliberately very wide and local regulatory expertise is then required to filter out the data.
The reporting is in BW, where the compositions of products is used together with other data flows in order to show the quantities of substances imported, manufactured or exported.
The reports are not pushed but retrieved when needed for an annual year period by the users.
Refer to the dedicated training item for more explanations and screenshots. (broken link)

CANADA


1) Non DSL Tracking

The regulation:
  • When requesting to manufacture or import a substance that is not on the DSL, the requirements (and associated costs) vary depending on the annual quantity requested. Therefore requests are only made for a certain quantity, for example, <50,000 kg. It then becomes the responsibility of the importer or manufacturer to track the quantity used and not go over it.
  • There are exemptions from tracking:
    • Low volume / R&D / samples shipment
    • Substances regulated by another Act (ex Pesticide regulation, Waste)
    • Transient Reaction Intermediates
    • Polymers Subject to the "Two Percent Rule“
    • Impurities
    • Incidental Reaction Products
    • Substances Occurring in Nature
    • Hydrate substances: only the anhydrous part is tracked
What we implemented, concretely speaking:
  • The fact that substances are on the DSL or not is a regulatory information coming from SAP. For substances on the confidential portion of the DSL, we have to manually maintain the information in the Pure Substance
  • The quantity authorized for each substance is maintained in the Pure Substance in Substance Volume Tracking> Registration (Company Specific)
  • In BW, a report tracks the activity in Canada for all the substances not on the DSL
    • production
    • imports (based on purchased orders)
  • The cumulated quantity is compared to the allowed threshold and a cell appears in red when it reaches 75% of it
  • There are 2 columns: 1 for the actual cumulated quantity and 1 for the planned one, in order to better anticipate
  • An exclusion table allows excluding specific materials, such as intermediates or waste

    Refer to the dedicated training item for more explanations and screenshots. (broken link)

2) Extended Tracking

A full tracking report has also been developed in order to answer other types of reporting. In this BW report, there is no exclusion of substances that are on the DSL. All substances are tracked but water and impurities. In this report, there is no comparison with an authorized threshold.
Refer to the dedicated training item for more explanations and screenshots. (broken link)




Korea

Annual Reporting of Chemicals

Objectives
The objective of this tracking is to notify the yearly amount of all Chemical substances.
There are no exemptions currently automatically managed, all substances are tracked for the annual reporting. Thus, the Standard composition (or Legal Composition if available in KR) have to be tracked, with all component types.
Users also need to report the usage of each substance.
All kind of flows have to be considered: importation, domestic purchase, production, exportation, sales. They shall be grouped into 2 types of flows:
- In-Flows: Manufactured substance + Imported substance + Domestic purchase
- Out-Flows: Domestic + export sales
The period relevant for tracking is one calendar year, from January 1st until December 31st. But the BW report can be launched for any period.
SAP EHS
  • Specific composition: K-REACH composition as priority 1, standard composition as priority 2
  • Rule: ZCP_KREACH
  • Other PRCO classes to fulfill: Korea Usage for Annual Reporting
System where the tracking is done
  • Business Warehouse (BW) - WBP
  • Query : EHS - Substance Volume Tracking Asia > Korea > KR Annual Reporting (Core Workbook)
> Refer to the training item: SVT Korea 1 - Annual reporting of chemicals (broken link)

Registration

Objectives
The objective of this tracking is to calculate the yearly amount of Substances that shall be registered according to K-Reach / ARECS (Act on the Registration and Evaluation of Chemical Substances).
The substances to track for the registration are:
- Designated existing substances : the MoE shall provided lists of so-called “Designated existing substances” that must be registered at first priority.These substances must be registered if the cumulative quantity of all flow is > 1 ton/year. However, the report will display all volume, even if below 1 ton/year.
- New chemical substances after 2015 - no threshold limits.
Exemptions : some substances are not subjected to Registration
- Substances covered by another regulation : Cosmetics, Narcotics, Pesticides, Feeds, etc.
- R&D substances
- Chemicals designated by Presidential Decree as exempted (list not yet published)
- Other exemptions like water, impurities, polymers… so far not know and no further information on the conditions.
For registration, only the following flows are considered :
- Manufacturing
- Importation
The period relevant for tracking is one calendar year, from January 1st until December 31st. But the BW report can be launched for any period.

SAP EHS
  • Specific c omposition: K-REACH composition as priority 1, standard composition as priority 2
  • Rule: ZCP_KREACH
  • Other PRCO classes to fulfill: No
System where the tracking is done
  • Business Warehouse (BW) - WBP
  • Query : EHS - Substance Volume Tracking Asia > Korea > KR Registration (Core Workbook)
> Refer to the training item: SVT Korea 2 - Registration (broken link)

Japan

Annual Reporting of Chemicals

Objectives

The objective of this tracking is to notify the yearly amount of all Chemical substances listed on the Chemical Substance Control Law (CSCL). Those substances can be distinguished between 3 types:
- General Chemical Substances (GCS) : not classified CSCL substance, that is to say any substance listed on the CSCL - Inventory of Existing and New Chemical Substances (ENCS) and that is not a Priority Assessment Chemical, nor a Monitoring Chemical Substance, nor a CSCL SVE/LPN.
- Priority Assessment Chemical substance (PACS)
- Monitoring Chemical substances (MCS)
The reporting has to be done per MITI number and not per CAS number.
Exclusion: Substances which have conditions below will be excluded from composition:
- PACS or MCS present as impurities <1% in a product.
- GCS present at <10% in a mixture (both intentional component and impurity)
- Substances regulated by other special law
For shipped product, users need to report the usage of each substance.
The volumes of Registered New Chemicals must be calculated for the following flows:
- Manufacturing
- Importation
- Shipment (Domestic and Export sales)
The period relevant for tracking is one calendar year, from April 1st of year Y-1 until March 31st of year Y. But the BW report can be launched for any period.

SAP EHS
  • Specific composition: JP Compo for Annual Reporting
  • Rule: ZCP_JP_SVT Japanese SVT Compo calculation
  • Other PRCO classes to fulfill: Japan Usage for Annual Reporting
System where the tracking is done
  • Business Warehouse (BW) - WBP
  • Query : EHS - Substance Volume Tracking Asia > Japan > JP Annual Reporting (Core Workbook)
> Refer to the training item: SVT Japan 1 - Annual reporting of Chemicals. (broken link)

Annual reporting of Small Volume Exempted substance or Low Production Notified substances

Objectives
The objective of this tracking is to notify the yearly amount of all Small Volume Exemption (SVE) or Low Production Notification (LPN) of New Chemical substance.
Two regulations are involved:
- the Chemical Substance Control Law (CSCL)
- the Industrial Safety and Health Law (ISHL)
Among these lists, we can distinguish 3 types of new chemical substances:
- Small Volume exemption (SVE)
ISHL SVE : New chemical substances under ISHL, applied for SVE
CSCL SVE: New chemical substances under CSCL, applied for SVE
- Low Production Notification (LPN)
CSCL LPN: : New chemical substances under CSCL, applied for LPN
Each new chemical substance has an authorized volume allocated by authorities which cannot be exceeded.
Exclusion: Substances which have conditions below do not have to be reported.:
- ISHL SVE substance present as impurity <10% in a product.
- CSCL SVE/LPN substance present as impurity <1% in a productSubstances regulated by other special law
The volumes of SVE/LPN New Chemicals must be calculated for the following flows:
- Manufacturing
- Importation
- Shipment (Domestic and Export sales)
The period relevant for tracking is one calendar year, from April 1st of year Y -1 until March 31st of year Y. But the BW report can be launched for any period.
JP authorities allocate volumes to applicant of CSCL SVE or LPN. So applicants have to submit their reports before the fiscal year (April – March) starts.

SAP EHS
  • Specific composition: JP Compo for Annual Reporting
  • Rule: ZCP_JP_SVT Japanese SVT Compo calculation
  • Other PRCO classes to fulfill: No

System where the tracking is done
  • Business Warehouse (BW) - WBP
  • Query : EHS - Substance Volume Tracking Asia > Japan > JP SVE-LPN Annual Reporting (Core Workbook)
> Refer to the training item: SVT Japan 2 - Annual reporting of SVE and LPN of chemicals. (broken link)

China

Tracking of Registered New Chemicals

Objective
The objective of this tracking is to notify the yearly amount of Registered New Chemicals, that is to say substances that are NOT listed on the Chinese Existing Chemical Inventory but that have been notified to Chinese authorities.
These chemicals have a notification certificate and can be notified according to a simplified or a full notification process, with an allocated volume (different for each substance). If this authorized quantity is exceeded, the company needs to update the notification dossier.
The Registered New Chemicals can be contained in mixtures and/or substances commercial products (PROD_COM).
For substance type PROD_COM, the notification of the volume can be made on the full PROD_COM* (main substance + impurities) or only on the main substance. It is thus not possible to make the calculation on the standard Composition.
The volumes of Registered New Chemicals must be calculated for the following flows:
- Manufacturing
- Importation
- Sales (Domestic sales and Exportation)
- Environmental release : cannot be tracked as information are not maintained in SAP – this flow will NOT be part of the BW report.
The period relevant for tracking is one calendar year, from January 1st of year Y until December 31st of year Y. But the BW report can be launched for any period.
The deadline for reporting is February 1st.
SAP EHS
  • Specific composition: Z_EHS_CN_COMPO - CN Compo for Registered New Chemicals to be maintained if there are exemptions. Otherwise, the report will use the standard composition.
  • Rule: No, the composition is manually filled
  • Other PRCO classes to fulfill: No
System where the tracking is done
  • Business Warehouse (BW) - WBP
  • Query : EHS - Substance Volume Tracking Asia > China > CN Registered New Chemicals (Core Workbook)
> Refer to the training item : SVT China 1 - Registered new chemicals. (broken link)

Retro calculation

Composition changes:
  • If the WP1 composition is modified during the year X and if you generate the report after this date, all the quantities will be calculated with this new composition for all the current calendar year
  • Besides, compositions are frozen at the end of each calendar year in BW (December 31th) If you generate the report on the year X-1, the quantities will be calculated with the composition of the December 31th of the year X-1 and not with the current composition.

Log

In each report, there is a tab for the "log", this aims at highlighting potential data maintenance issues. The log tab contains data that could not appear in the report itself because of missing information:
  • no composition maintained for the PROD_COM
  • no regulation found for the PURE_SUB
  • no usage found for the PROD_COM
  • no link between material and PROD_COM

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