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EH&S Product compliance - Standard composition per production plant for 1 material

Dear EHS specialists,

I’m looking for more information about the specification per
material code, and more in particular about the standard composition.

At my current client they have the situation that the
standard composition (chemical composition) is not the same per production
plant for a specific material, but the end product for the customer is the
same. Some pure substances are in the standard composition of 1 production plant for that 1 material, but not in another production plant. This has impact on the registrations for REACH/SDS creation. They have
created now different material codes per production plant (as from the REACH
implementation) and assigned 1 specification per production plant. This has major impact
on sales and planning (substitution of material code needed if planning
changes).

Is there maybe a solution to indicate the production plant
in the specification without creating new material codes? For example using a batch
code (specific per production plant) as identifier, and then having a SDS per
batch/specification, instead of per material?

Any advice is welcome.

Thanks

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1 Answer

  • Best Answer
    Posted on May 08, 2013 at 08:11 PM

    Dear Marianne

    this is an "old" problem coming up very often. It is related to them "BOM" problem (BOMBOS interface is used here as well often). Main issue: what is your definition of the "material" (do you use SAP standard ROH, FERT, HALB?) and that of "Real_sub".

    Related to that to a certain extent is the topic of "batch" and assignment of batch classes to material numbers (to e.g. indicate the content of ingredients) to "store" some additional informations.

    One option to deal with the situation is shown here:

    Create REAL_SUB; attach e.g. one material

    This material does have per plant a "different" BOM (= composition) (alternative BOM per plant; but could be as well produced in mnay plants but in different way).

    Now you can try to take care that in using a different approach in "usage". You can use th validity area type "PLANT" to do so.

    So you can/could maintain on one REAL_SUB many compositions and you know which composition is valid for which plant. There is only one "but". Normally you have or can have different BOMs in one plant per thee sam material (alternatives)

    Here you could add a "note" in the data value assignment to reflect that or you could use a "user defined text". The main issue is: you have not "useful" selection criteria for many subsequent processes. Only by using the "note" you could may be differentiate

    E.g. if you have two BOMs per material (alternative BOMs) with "different" compostion in the same plant the result would be:

    Sort Seq 1: Usage: STANDARD / 0001 (0001 should be the code for the plant)

    Sort Seq 2: Usage: STANDARD / 0001 (0001 should be the code for the plant)

    So the usage is the same.

    But may be I did not completely understood your scenario correct

    Regarding REACH I can provide only suggestions: don't do it like you seem to have implemented it. You will get trouble in SVT, DG...... and many other EH&S processes; not talking about the trouble in SAP SD, PP, MM, QM, BW .... etc. etc. (check please: configurable material as search criteria as well; the same: recipe etc.)

    Second option

    E.g. let us assume this: you would like to drink a cup of coffee. Sometimes you add two pieces of sugar, three or one; sometimes you add more milk, some times less milk. At the end you "as the consumer" is completely satisfied with your cup of coffee.

    In terms of EH&S: we have three "ingredients"; Coffee, sugar, milk but in "mixed" proportions. What you can do is to maintain like this in composition (high level example; only to give you the idea)

    Min Max Ave value

    Milk 1 ml 3 ml 2 ml

    Sugar 1 piece 3 piece 2 piece

    Coffee 40 ml 60 ml 50 ml

    In doing so normally you satisfy any product safety demand, dangerous goods etc. needs including SDS/MSDS generation etc. etc. This is the most common used approach to deal with your situation (if I understand your situation correct). REACh demands can be fulfilled the same

    C.B.

    PS: normally such discussions as yours are coming up due to SAP EHS SVT installation (or as in your case because of REACh SDS); here you will get trouble as well if you would like to track something with SAP EHS SVT.

    Reach SDS/MSDS: here you should have "less" stress as you in case of a mixture normally you need only to take care chapter 2, 3, 8; but not taking care about appendix; in case you are mixing (as in my coffee example) you will have less problem in SVT; in case of reaction: you will have problems

    Proposal: before you go on: make an analysis; how often is the problem coming up in your company; if we are talking about < 1000 materials: keep your solution simple; if the problem comes up to often you need to figure out which approach might be the right one starting with "As is" situation and defininig new "to be" one. Regarding Reach in general: you are to late if we talk in IT topis; this year (this month !) your company must ! register the next wave of substances which are Reach relevant; then 2018 we (than means chemical companies) need to deal with the last wave; this is a further reason to use a very simple solution to fulfill Reach needs.

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    • Dear Marianne

      regarding:

      "I see a solution in the first option, but how is the link with the SDS then in the specification? Can you create a SDS per validity area in a specification? So that the correct registration numbers (which are different per production plants) appears on the SDS?"

      That is the standard approach by many companies as you can not compare a SDS valid in e.g. belgium with a SDS in france (data is different). Therefore the SDS distribution set up is "critical"; the problem you might have is now: the REACh registration number is valid in REach area; so there is no differentiation any more. BUtr what you can do is "you can collect any number independen of plant (as plant does have a relation to company code); this is the most used option to solve your topic

      From REACH Perspective: the "sals org" is the primaroy contact to the customer and the plant is assigned to a company code; the same is true regarding the plant. There is only one but: should you have the situation that you have two plants assigned to the same company code but you have different compositions; then you have a "problem"

      Regarding:

      I think with the second option we will have a problem to define a range, because the pure substances are not the same per production plant (so the range will be for example then 0 till 10%, I'm not sure if this is possible).

      From EHS perspective this is "ok"; from legal perspective this is my understanding of your problem;

      The company is selling "XXXX" (material name). This XXXX does have different compositions based on plant. From the "customer" point of view there is no difference in getting a "XXXX" which have been produced in plant 1 in comparison to plant 2. (trade name is the same).

      This is the "crucial" topic in any EHS set up. How is the material defined per plant? How is it sold (using which name etc.); and is the "chemistry" the same? With REACH the answers are "more" complex as in the past.

      Pay attention: REACh is related to "substances" and not "mixtures" ! We have to differentiate the needs regarding SDS generation to that of EHS SVT.

      Pay attention: based on your "final" decisions you might get problem in DG and HSM as well. If there is no "robust" data model in place (how to do set up of material, how to link it to EHS) there is high probability that your project will get a big problem;

      May be my suggestions give you hints how to go on.

      C.B.

      PS: If we talk about SDS/MSDS WWI: using something like "STANDARD/0000" (0000 code of plant) is not "helpful"; and if you have two plants in the some country there a difference exists in composition the problem will grow once again; the country is reflected by validity area in EHS. Therefore: if the problem is on the level of < 1000 materials then go on with the "split" of material numbers; if the number is higher you need a good concept to migrate form "As is" to "To be" (whatever your new "to be" would be; and it is not done within short time

      As mentioned shortly above: regardgin any new material number you need to define a REAL_SUB; you need to excetue DG classification etc. etc. and you need to "regenerate" a lot of WWI reports (may be) uncluding GLM labels (may be)