Chemical Global Regulatory Compliance
The global regulatory compliance chemicals team (GRC-C) is responsible for ensuring chemical compliance and safety throughout the life cycle of our products
Committed to chemical management
All engineered and SLB trade name chemicals go through our life cycle management framework, which includes a health, safety, and environment (HSE) and regulatory assessment. At the beginning of the life cycle of a product, we evaluate its chemistry with the goal to eliminate or reduce chemical-related risks. Our dedicated GRC-C team works in close coordination with our research and development team to identify and reduce HSE and regulatory risks early. Our product development and sustaining teams focus on identifying chemical-related opportunities and developing and using more environmentally sustainable chemicals. When purchasing and designing chemicals, SLB considers the chemical's life cycle up to and including disposition of the chemical.
We have long been committed to transparency in our chemical disclosure. We also require our suppliers to provide us with full disclosure regarding any chemicals that we purchase from them before we can include such chemicals in our portfolio.
We require that our products comply with applicable laws in the jurisdictions where they may be distributed. We also develop and implement compliance processes in accordance with applicable regulatory regimes, such as the European Union's Registration, Evaluation, Authorization, and Restriction of Chemicals regulation (REACH). In the last decade, we developed a robust REACH compliance program, under which we achieved timely registration of all required substances in accordance with applicable regulations. Our REACH registrations help us maintain our access to the European market and demonstrate our commitment to compliance. Safe management of SLB products and its life cycle are vital to SLB’s commitment to chemical management.
Product stewardship
Our product stewardship team, part of the GRC-C, manages many responsibilities:
- Assessing chemical compliance and ensuring new and existing products for all SLB business lines are compliant with regulations.
- Creation and updating regulatory documentation such as country specific globally harmonized system safety data sheets, product labels, and shipping or transport documents in multiple languages and formats as required.
- Working together with product development and sustaining teams to provide customized solutions and chemical-related opportunities to use more environmentally sustainable chemicals.
- Overseeing and controlling product supplier regulatory review forms from suppliers for SLB products, which are assessed by the team for risk and or compliance to ensure safe handling for our associates and customers.
- Ensuring all chemicals used in various regions are registered on the applicable inventories. The chemical must be on the inventory in order for it to be legally imported, manufactured, or used.
- Evaluating supplier chemicals for any banned substances listed in our SLB chemical standard.
- Enhancing supply chain and other stakeholder requirements by using our documented formalized process (the chemical quality management system). Managing the SLB confidential release procedure and disclosure management process to manage all disclosures centrally for maximum confidentiality and IP protection.
Product registration
Our product registration team manages many responsibilities:
- Evaluating and supporting various regional and international registrations—such as the Australian AICIS , US TSCA, Canada DSL/NDSL, China REACH (IESC), Japan METI/ENCS, Korea TCCL (K-REACH), New Zealand NZLoc, Philippines PICCS, Taiwan TCSI, Thailand DIW, the North Sea regulations OSPAR—there is a strict procedure in place to ensure all the chemical products are duly registered and registrations updated when needed, such as Cefas OCNS scheme (United Kingdom), HMCS Scheme (The Netherlands), Danish Product Registration notifications, Norwegian NEMS registration and health classifications, and other relevant regulatory requirements.
- Utilizing software to run chemical hazard assessment and risk management (CHARM) assessments on chemical products. The software is used in new product development as well as in modifying parameters for existing products. The use of the system allows the assessment of the optimum performance of products while adhering to the acceptable environmental limits set by OSPAR.
- Supporting biocide and pesticide registrations and ensuring compliance when placing them on the market in Europe, US, and other countries in which we operate. The team organizes ecological testing on chemical substances that are intended to be used offshore (North Sea). The substances are tested on biodegradation, bioaccumulation, and their toxicity to four different test species (algae, crustacean, fish, and sediment reworker).
- Assessing newly developed chemical products on their compliance to the national inventories applicable countries in which we operate.
- Supporting operations with environmental data needed for tendering, customer requests, or local regulatory requirements.
Product development
We are engaged in the development of new products to meet regulatory requirements around the globe. SLB customers around the world can be assured that chemicals from each division comply with the international, federal, state, and local regulations pertaining to their recommended use.
This is facilitated by various tools within the GRC-C’s data bank, including the Global Toxicity Database, which contains data, test reports, analysis, and hazard review on over 1,000 individual substances. The data is an accumulation of tests performed in-house in our ecotoxicological testing laboratories, such as the Bergen Eco toxicological laboratory and the Environmental Affairs Aquatic Bioassay Laboratory in Houston, in addition to other SLB laboratories worldwide. Assays and tests from contractors and laboratories outside SLB in addition to literature data are also available within the global database. Most of the data from the studies are either GLP* approved or have the highest Klimisch rating.
