November 19, 2019
Volume 3 Issue 2
Task Force Tackles Chemicals Reporting
European trade associations representing lubricant and chemical additive suppliers have agreed to create a task force on complying with chemical regulations including communication of sensitive information throughout the supply chain.
The decision to create the task force came at an Oct. 23 conference co-hosted in Frankfurt by ATIEL, the Technical Association of the European Lubricants Industry, and ATC, the Technical Committee of Petroleum Additive Manufacturers. Afterwards, on Nov. 12, ATIEL and ATC issued a joint press release saying attendees wanted to find ways to improve communication and trust between suppliers and customers. Complying with current rules is complex, the organizations said, and lubricant marketers, additive suppliers and their customers will need to understand each others’ operations before finding a solution.
“Once processes, data availability and customer requirements are understood, the lubricants industry can identify the challenges faced with sharing data through the supply chain and seek to improve the future,” the release reads.
Christine Marlet, secretary general of ATIEL, said additional information is not ready for release. “I will be able to say more in the next month. We are under negotiations,” she responded to an email of questions.
During the one-day conference, attendees were informed that today’s chemicals regulations create numerous hurdles for businesses.
The first is the level of data sharing that is mandated by some regulations, including what must be reported on standardized communication forms, including inventory declarations, formulation disclosures and explanations of any potential hazards presented by chemical contents and handling guidance.
Another issue is non-standardized communication and bespoke forms. Original equipment manufacturers want declaration on bespoke forms, which are time consuming and can mean 10 regional forms for one product to cover the globe, which can require considerable time and resources to deliver. Some believe that the number of declarations required of businesses could be greatly consolidated.
One of the biggest issues facing this new task force is how the industries should manage non-disclosure agreements. Oil and additive companies say these are needed to protect intellectual property rights, but they are time-consuming to set up and manage.
It’s extremely difficult for oil companies to get NDAs in place with multiple suppliers, or to obtain full formulation disclosures from additive companies. Even with them in place, additive companies do not always provide 100 percent formulation disclosures to oil companies, ATIEL staff said during the presentation.
”NDAs can restrict where the data can be shared, which can leave additive and oil companies unable to share with customers. The agreements can prohibit what can be shared, such as do not share an additive company’s identity and raw material names to customers,” the organization said.
How can the situation be improved? Rather than designing new forms, ATIEL suggested companies could discuss with their supply chain what information is required and how it can be efficiently delivered. Businesses should consider whether trust exists in the supply chain or whether product stewardship review work is repeated by their customers or OEMs. If all product stewardship work is repeated by OEMs, the entire process becomes very complex and slow.