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Former Member

EPA RMP/OSHA PSM/DHS Regulations and SVT

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

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2 Answers

  • Best Answer
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    Former Member
    Mar 17, 2014 at 05:08 PM

    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, and Safety Mana - …

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    • Former Member Ramesh Reddy

      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

  • Mar 15, 2014 at 11:09 AM

    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

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    • Former Member Christoph Bergemann

      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