EPA RMP/OSHA PSM/DHS Regulations and SVT

[akash_agrawal5]

Hello Group !

We are reviewing few regulations (mentioned below) and in each of these regulations there is a section which defines the tracking of certain Substances and take preventive actions if the presence of these substances are beyond the specified threshold. 

• Environment Protection Agency Risk Management Plan (RMP),
• OSHA Process Safety Management Plan (PSM), and
• Dept. of Homeland Security (DHS) CFATS regulations.

Though, as per regulatory bodies, business is required to initiate certain set of actions or prepare a Risk Management Plan or do much more than just tracking, if the threshold exceeds. However, this requirement, if limited to tracking, takes us to SAP Substance Volume Tracking and that’s where we have few questions –

1. Threshold tracking to be done at PLANT level; The thresholds for the same chemical may be different for different plants, Can Plant Specific Threshold and multiple thresholds for the same substance be set up in SAP SVT?
2. Threshold tracking maybe needed not just for exceeding Max threshold but also if quantity goes below past minimum. So, can there be two thresholds for one regulation?
3. Can we enable tracking in such a way that a substance present in a material below a specific concentration level does not need to be tracked?
4. Has anyone worked on the solution mapping of any of the above mentioned regulations ?
   

Any inputs will be highly appreciated.

Thanks,

Akash

[Former Member · Accepted solution]

Please check out the functionality that became available in component extension 4.0 under risk assessment, then managing chemicals for health and safety processes. It is intended for these use cases.

Managing Chemicals for Health and Safety Processes - Component Extension for SAP Environment, Health...

[akash_agrawal5 · Accepted solution]

Mary,

I went through the documentation of Component Extension 4.0, the "add-on" seems to be very interesting and addresses quite a number of pain points of Business.

However, if I look at my current requirement and business perspective, though, the section "Generate BI analytical reports for chemicals" seems like providing standard solution about using the chemicals within a time frame at various inventories, I am not clear whether system will be able to provide customizable functions to set up multi-layer thresholds at Plant level or threshold based on given concentration ? Would you be able to post some more information in this regard  ?

Thanks,

Akash

[Former Member · Accepted solution]

I am not entirely sure that I understand your question. Are you asking if you can have a different "action level" for different locations? For example, in the US, my threshold is 100 kg, but in Germany my threshold is 50 kg. Or are you asking if you can add up the contained amount of the chemical? For example, I have 1 ppm benzene in 100 barrels of gasoline plus 2% benzene in 400 barrels of crude oil and I need to get the total amount of contained benzene? I think you mean the second use case since that is similar to SVT.

[akash_agrawal5 · Accepted solution]

Mary,

Both use cases mentioned by you are going to be required. My colleague Krishna will reply back with exact use cases shortly.

Thanks,

Akash

[Former Member · Accepted solution]

Hi CB and Mary,

In continuation of Akash question, the requirement is like this:

1. The threshold limit for a Chemical (within USA) in a state TX - 75 lbs and  for the  same chemical in AZ it is 70 lbs.

2. According to EPA RMP : Substances will have both initial Threshold and Maximum Intended inventory target values. Again these minimum and maximum threshold limits may differ from state to state with in USA.

3. Base on Composition : For example :

• 1 ppm Benzene in 100 barrels of gasoline -> should not be considered for tracking.
• 1.5 ppm Benzene in 100 barrels of gasoline -> should be considered for tracking
• also 2% Benzene in 400 barrels of crude oil -> should be considered for tracking.
• Aqueous material below a specific concentration does not need to be tracked.

4. With a Company Code the Upper and lower limits of Threshold values are to be defined according to the plant location.

5. The FMs that are used for SVT : Can we use the same FMs by reconfiguring to the above requirements as the data has to pick up from the threshold values that are applicable at plant level not at CoCd level.

I am not sure, what would be the amount of changes for FMs as well as configuration that needs to done to meet the above requirements.

Based on your experience, any inputs and suggestions are appreciated.

Regards,

Krishna Mohan.

[Former Member · Accepted solution]

The reports in the component extension 4.0 for EHS Management don't currently support these use cases. If you use Business Objects for reports, you could handle it there. From my past experience working in the chemical industry, I remember that getting the annual reports is not the biggest challenge. You set up the appropriate report, and run it as needed because it is typically infrequent. The bigger challenge is having a good busines process that prevents going over a threshold. For example, if your operating permit or other regulation restricts the amount you are allowed to have on site or within a certain storage area, then you need to manage this with the purchasing and warehouse management business processes. Waiting until someone looks at a report is too late. I am not an expert on those solutions, so I cannot advise how to put rules in place to prevent ordering too much.

[christoph_bergemann · Accepted solution]

Dear Krishna

some comments:

1. The threshold limit for a Chemical (within USA) in a state TX - 75 lbs and  for the  same chemical in AZ it is 70 lbs.

=> in EHS classic: look for a property/value assignment type which can  be used; if it does not exists create it by yourself; establish two (or more) new validity areas. E.g. TX and AZ and maintain two data records

2. According to EPA RMP : Substances will have both initial Threshold and Maximum Intended inventory target values. Again these minimum and maximum threshold limits may differ from state to state with in USA.

=> in EHS classic: look for a property/value assignment type which can  be used; if it does not exists create it by yourself; establish two (or more) new validity areas. E.g. TX and AZ and maintain two data records

3. Base on Composition : For example :

• 1 ppm Benzene in 100 barrels of gasoline -> should not be considered for tracking.
• 1.5 ppm Benzene in 100 barrels of gasoline -> should be considered for tracking
• also 2% Benzene in 400 barrels of crude oil -> should be considered for tracking.
• Aqueous material below a specific concentration does not need to be tracked.

=> if SVT should be used. you need "only" to maintain the composition. E.g. in your case:

you can prepare a "chemical" composition and a "SVT" composiition (using different rating). In the SVT composition you remove, benzene etc. but in your case it is a "different" demand. The "tracking" on and off is not "easy". E.g. in SAP standard you can define e.g. a material defining 100 barrel; here you would switch off tracking; It can be expected that you can ignore the 1 ppm and 1.5. ppm cases, In practical real life there is less chance to separate them; Same solutions as mentioned can be applied for400 barrelcrude oil etc.; may be on the top you need to think about using suitable composition data.

4. With a Company Code the Upper and lower limits of Threshold values are to be defined according to the plant location.

=> in EHS classic: as mentioned: you can prepare validity areas refering to plant code. Then just simply create two data records (nearly same solution as with the "State" topic above) one for plant code 1 and the other for plant code 2; easy and cheap

5. The FMs that are used for SVT : Can we use the same FMs by reconfiguring to the above requirements as the data has to pick up from the threshold values that are applicable at plant level not at CoCd level.

I am not sure, what would be the amount of changes for FMs as well as configuration that needs to done to meet the above requirements.

Based on your experience, any inputs and suggestions are appreciated.

=> No plant specific threshold limit is possible. Only company code threshold limits are supported (ok there are workarounds but... too complex !) But I believe this is not what you need here. e.g. CBRC20 can be enhanced ("easily"). In CBRC20 the aggregation of tracking is done on level:

legislation

company code

material number

plant code

spec id (REAL_SUB)

tracked substance

Therefore you might have the "need" only to display the "plant" specific threshold limit data). This can be done by using SAP standard, and "ignoring" SVT standard set up. You would add come columns in CBRC20 and you would doa "direct" ready of value assgnment as establised according top process above. Quite tricky (and good design is required ! but it will work

C.B.

PS: may be check: with a lot of references to other SVT threads

[former_member190809 · Accepted solution]

We had similar kind of requirement and I quote you 'For example, if your operating permit or other regulation restricts the amount you are allowed to have on site or within a certain storage area'

Unfortunately 4.0 version doesn't support Inventory tracking as it has no ties to SAP Inventory Management or WM. You can manually upload excel file in each location to see which chemical is present in which location at what amount but again this does not check the amount that is already present in warehouse.

I am expecting the new release would have some kind of ties so these kind of requirements can be met.

[akash_agrawal5 · Accepted solution]

CB & Mary.

Thanks for your inputs and help. We appreciate it. We are analyzing various solutions in full throttle, since there are no more questions, we are closing this thread.

Akash

[ramesh_reddy99 · Accepted solution]

Hi Akash,

I do have the same requirement from my client. Could you please let us know what was final solution implemented.

Thanks & Regards,

Ramesh

[akash_agrawal5 · Accepted solution]

Hello Ramesh,

Finally SVT was customized and we were able to accomplish most of the requirements listed in this thread.

If you have any specific questions, do post here and I will try to address.

Thanks,

Akash

[christoph_bergemann]

Dear Akash

regarding

1. Threshold tracking to be done at PLANT level; The thresholds for the same chemical may be different for different plants, Can Plant Specific Threshold and multiple thresholds for the same substance be set up in SAP SVT?

Answer. No. SVT supports to my knowledge even in the last SP etc. update only threshold level´s on company code and not plant level. By use of "clever" enhancements may be you may be can  achieve this

To gove you some gerenal ideas here: in Cg02 you can define validity areas. It is possible to use "plant codes" as validity area. So the management of the threshold values is not a problem using CG02; in tracking the trackoing is done on "plant""/company" code" level. So to a certain exetent your demand is supported. But there is no standard solution available to conisder plant specific threshold levels. ButI have the feeling that you might be able to enhance SVT using standard SAP options but you need a good concept for doing it (business requirement should be clear, technical design gnhsould be "stable")

1. Threshold tracking maybe needed not just for exceeding Max threshold but also if quantity goes below past minimum. So, can there be two thresholds for one regulation?

Answer. Once again we need to differentiate maintenance options in CG02 and content of SVT standard; once again the same aplies as before: by clever enhancements oin Cg02 you can maintain the data and may be by clever (very ! clever) enhancements this demand can be solved using SVT

Can we enable tracking in such a way that a substance present in a material below a specific concentration level does not need to be tracked?

Answer: if I understand your requirement: imagiunge material linke to REAL_SUB contains 3 components (from chemcial perspective)

Component 1 90%

Component 2 8 %

Component 3 1%

If now the regulatiuons alows to defene "1%" as threshold limit than just do not maintain your composition using 3 components but only two.

1. Has anyone worked on the solution mapping of any of the above mentioned regulations ?

Answer: thes regalation are new to me. Never heard abiout them and no indication that companies using SAP uses SVT top solve the demand. Sorry

C.B.

PPS: many regulations talk about mass of chemistry per plant to  start actions. For such purposes "indirect" solutions are used. E.g. SAP EHS IHS

Mabe you should check SAP IHS. E.g. Seveso and many similar regulations "force" companies to "think" about: how many kilogramm etc. of a certain chemistry is present in a plant/location; this type of rewquirement is linked to a certain extent to the "Fire brigade" topic. In most cases not SVT is used to deal this type of regulation demand; but it is possible (or seems to be possible)

So therefore check e.g.:

http://help.sap.com/erp2005_ehp_07/helpdata/en/8a/3b6e361b2fac0be10000009b38f839/frameset.htm

Hazardous Substance Inventory - Industrial Hygiene and Safety (EHS-IHS) - SAP Library

Chapter "Hazardous Substance Inventory"

Pay attention. PLease check in any case as well: Component Extension for SAP Environment, Health, and Safety Mana - SAP Library

and solutions available as part of Component Extension for SAP Environment, Health, and Safety Management

[christoph_bergemann]

Dear Akash

not checked in deep the three regulations mentioned. Just executed small survey via google. So I believe this is true:

The regulations listed are dedicated to "industrial Hygiene" activities. That means: most of them specify like this: if in a "plant" per year more than X tons of chemical Y is present than...

This type of demand is normally not solved via SVT. In most cases IHS can be used. On a general level the "greatest" issue is that the "plant" definition used within a company is not the same as regulaiton si requiring (they talk about locations/Sites ....). So normally IHS is a hood choice. Here you prepare work areas (or you can do that) and assign materials to them (handeled) at that level. Then you assign specifications to the work area and the you can use IHS functionality (e.g. as fire brigade list and others). This demand is well knwon (e.g. SARA ....)  The main issue is still: the ERP set up does not fit the legal demand, And there is "less" chance to convince the people tp use a different set up. Main topic is that the regulation is requiring to a certainextent to "model" your production in SAP (e.g. you need to define tanks). On the top: SVT "adds" only amounts. But some of the regulations are aksing for. at which point of timne do you have the "highest" amountz stored somethere and then you have to act like.. (risk plan). This is not possible with SVT. SVT is only "adding" and not talking care about "moin" or "max" amounts of a chemistry present in a plant/location at a certain popint in time.

Using SAP ERP you will in most cases not get a 100 % solution and as mentioned only because you will not get a "better" SAP ERP set up as the logistic processes are not in most case not "willing" to support ehs demands (as system would get complexer from their point of view).

Clear work arounds exists as well but these are "own" developped solutions and not using SAP standard.

C.B.

[akash_agrawal5]

Hi CB,

Appreciate your detailed response on each question. Indeed the requirement falls under Industrial Hygiene and if one looks at the details of each regulation, there is much more than just tracking the volume of regulated substances. The main objective of these regulations is to protect human health & environment, the perspective is Industrial Hygiene & safety and environment protection.  Keeping all that in mind we considered various solutions and as you said in your second post, a 100% solution is not possible. The problem is less integration with Core Logistics and limited tracking capabilities of IH&S functions. From Business perspective, if they are aware of what all chemicals are present in various inventories and what specific volume is on a given day, they can trigger all actions outside SAP. Let it be preparing risk plans or initiating a preventive measure, since volume tracking does not have any integration with risk assessment, the EHS classic solution is not suitable unless own solution is developed. I know with this approach they do not cover the whole set of regulatory requirement but this is intended to just track the volumes in SAP and perform all subsequent actions outside it.  So, I am thinking of analyzing SVT in more detail based on various clues given in your post about enhancing SVT Function Modules. Please let me know what you think about this approach.

Thank you!

Akash