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Dr. Knoell Consult GmbHDr. Michael CleuversManaging Director Industrial Chemicals & BiocidesTel. +49 214 20658-170globalregistration@knoell.com

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Are you struggling with the continuously changing regulatory environment in your target markets? Are you in need of a clear picture about the global trends in chemical policies? Here comes a conference dedicated to bring you some relief!

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Topics include: Registration and evaluation of chemicals in Korea Management of chemicals in China and Taiwan Reform of the Toxic Substance Control Act (TSCA) in the USA NewsubstancenotificationinCanada Chemical regulations in ASEAN countries Regulations in Central and South America Registration of Polymers on a global scale How to deal with endocrine disruptors and other SVHC

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Chemical Watch | Global Service Providers Guide 2016 Page 1

Fore

wor

d

ForewordWelcome to the sixth annual Chemical Watch Service Providers Guide.

Combining in depth research with our annual survey results, this unique directory brings you a comprehensive view of the complex world of chemicals management and regulatory compliance. Gathering information from both service users and providers, it gives a 360 degree perspective of the global market, ranging from consultancy and legal advice, to laboratory and IT, to strategic management.

This year the updated findings on our annual survey indicate safe chemicals management within companies is coming under increased pressure from regulators and the market. And, our fourth year of reporting on salaries, career prospects and training, reflects this pressure. Twice as many people are seeing teams increase in size and demand is outstripping supply in the jobs market - suggesting strong growth in the regulatory compliance and service providers sectors.

In the complementary market analysis in this years guide, written once again by experienced chemicals market

researcher Cynthia Challener, we look more closely at two new areas: sector-specific chemicals legislation and how supply chains in those sectors are coping with increased regulatory and market pressure; and the latest experiences of chemical testing laboratories as they prepare for the influx of REACH 2018 testing.

We also look at the factors that influence companies choice of service providers.

This years survey findings are based on almost 700 respondents from across the world.

We hope you find these insights useful, alongside the directory of 374 service providers. This year we have a record number of companies taking a full profile - enabling you to view the services offered and select the best partner to support your compliance activities.

Emma ChynowethManaging Editor

View the Service Providers Guide online...24x7 access to all updated profiles

The online version of the guide is updated regularly to include the latest service provider data

Powerful search and filtering tools help you find exactly what youre looking for, fast

Hosted online, the Guide is accessible from anywhere, 24x7 - from any device

Our online and digital versions make sharing information with colleagues quick and easy

www.chemicalwatch.com/online-guide

Global Chemical Notification REACH, TSCA, K-REACH, CEPA, China Order No. 7

Biocides, Pesticides, Antimicrobials,Nanomaterials, Products of Biotechnology

Hazard Communication, GHS Classificationand Labelling, SDS

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A scientific and regulatory consulting firm providing strategic, comprehensive support for global chemical registration, regulation, and sustained compliance.

Jane S. Vergnes, Ph.D., DABTVice President, Scientific Affairsjvergnes@actagroup.com

Leslie S. MacDougall Director, Strategic Program Developmentlmacdougall@actagroup.com

Zameer QureshiLegal Consultant to Acta EUzqureshi@actagroupeu.com

Emma Louise JacksonRegulatory Specialistejackson@actagroupeu.com

Louise C. BoardallRegulatory Associatelboardall@actagroupeu.com

J. Brian Xu, M.D., Ph.D., DABTToxicologistbxu@actagroup.com

CONTACT OUR EU TEAM:

ACTA_ChemNWFullPg_2016:Layout 1 3/29/16 1:55 PM Page 1

Cont

ents

Chemical Watch | Global Service Providers Guide 2016 Page 3

ContentsChemical service providers editorial ....5Combination of factors drive growth .....5Career development in the chemicals management and control sector .........14Testing the limits ...................................22Challenges multiplying for industry sectors .................................................28Exciting times expected for 2016 following a busy year in 2015 ..............43

Profiles ...................................... 58 3E Company ........................................58ACTA ....................................................60APC ......................................................62Apeiron-Team NV .................................64Arcadis .................................................66ARCHE .................................................68bibra toxicology advice & consulting ..70Blue Frog Scientific Limited .................72bluesign technologies ag ....................74CEHTRA ...............................................76Chemex ................................................78ChemSafe ............................................80Chemservice ........................................82CHEMTREC..........................................84China National Chemical Information Center ...................................................86CIS Center ............................................88CiToxLAB ..............................................90CRAD ...................................................92DEKRA Insight .....................................94DHI .......................................................96DORUK SISTEM ...................................98Dr. Knoell Consult GmbH ...................100EAG Family of Companies.................102EBRC Consulting ...............................104EcoOnline ...........................................106ERM ....................................................108Eurofins ..............................................110Exponent International Limited ..........112Fieldfisher LLP ...................................114FoBiG..................................................116

GAB Consulting GmbH .....................118IHS ......................................................120International Cosmetics & Chemical Services Ltd .......................................122Intertek ...............................................124JSC International Limited ...................126KFT Chemieservice GmbH ................128Lisam Systems ...................................130National Chemical Emergency Centre (NCEC) ...................................132Ramboll Environ .................................134REACh ChemAdvice GmbH ..............136REACH mastery .................................138ReachCentrum ...................................140REACHLaw .........................................142Regulatory Services International Ltd ......................................................144Risk & Policy Analysts Ltd (RPA) .......146Royal HaskoningDHV .........................148SCC ....................................................150Sustainability Support Services (Europe) AB .......................................152The REACH Centre ............................154TNO Triskelion B.V. .............................156ToxMinds ............................................158Trade Wind B.V. ..................................160TV SD Industrie Service GmbH ....162TV SD Process Safety ...................164UL information & insights |The Wercs 166UMCO Umwelt Consult GmbH ..........168WIL Research .....................................170

Niche Profiles .............................1731cc GmbH ..........................................1733S-SafelyServingScience ..................173A.S.C. .................................................173Altox....................................................173Anthesis-Caleb ...................................174BIG vzw ..............................................174Bootman Chemical Safety .................174CFCS ..................................................174Chementors Ltd .................................175

chemtrac .........................................175ChIR - Chemical Innovation and Regulation ..........................................175Chymeia ApS .....................................175CONUSBAT Regulatory Services ......176Danger and Safety srl ........................176Distefano Law Office ..........................176DR MACH Chemical Compliance & Competence ......................................176eSpheres ............................................177Eurideas Linguistic Services .............177HDTS Chemicals Inc. .........................177I+K AG................................................177Infotox .................................................178Jongerius Consult BV.........................178KREATiS .............................................178Linmark Consulting ............................178LKC Switzerland Ltd ...........................179Oriental Chemical Information Co., Ltd ......................................................179Peter Fisk Associates .........................179Prefusion LLP .....................................179Randis ChemWise (Shanghai) Co., Ltd. .....................................................180REACH Global Services S.A. .............180REACHWise .......................................180ReFaC ................................................180RegScan Inc. ......................................181Rovaltain Research Company ...........181SCAS Europe .....................................181SciVera ...............................................181Siam S.L. ............................................182Spring Trading Company, LLC ...........182Tox Focus, LLC ...................................182toXcel .................................................182Toxicon ...............................................183ToxServices ........................................183VRS Regulatory ..................................183WRc plc ..............................................183WSP UK Ltd .......................................184

A-Z Listing .................................186

CW Research Ltd, trading as Chemical Watch, publishes news and intelligence to help companies achieve sound chemicals management that responds to the many non-regulatory drivers as well as meeting responsibilities under chemicals legislation worldwide, including regimes such as REACH, CLP, GHS and TSCA. We keep you abreast of policy and business trends across the EU, North America, Asia and the rest of the world. Because we are not tied to any trade associations, government or campaign group, we are able to offer objective news and analysis for all sectors.CW Research Ltd, 2 Nettles Lane, Shrewsbury SY3 8RJ, UK Tel: +44 (0)1743 818 101 Fax: +44 (0)1743 818 121 email: cw.enquiries@chemicalwatch.com www.chemicalwatch.com US office: +1 (202) 803 5869

Editorial Director Mamta Patel, mamta@chemicalwatch.comManaging Editor Emma Chynoweth, emma@chemicalwatch.comContributing Editor Cynthia Challener, cynthia@chemicalwatch.comProduction and Information Editor Nick Hazlewood, nick@chemicalwatch.comAccount Managers Kerry Williamson, kerry@chemicalwatch.com Lotte Spencer, lotte@chemicalwatch.com Sonja Davidson, sonja@chemicalwatch.comHead of Marketing Richard Butterworth, richard@chemicalwatch.comCommercial Director Stuart Foxon, stuart@chemicalwatch.comManaging Director Julian Rose, julian@chemicalwatch.com

Distribution policy Copying of this document including electronic circulation is not permitted without consent of the publisher.Disclaimer While Chemical Watch takes every effort to ensure the accuracy of this guide, we cannot take responsibility for any adverse consequences arising from actions taken in response to our content and we recommend that readers take appropriate professional advice.Designed and typeset by Ministry of Design, Bath, UK www.ministryofdesign.co.ukPrinted by Trident Printing, London.Printed on 9 Lives 80 recycled stock.Front cover images Shutterstock, fotolia and Nick HazlewoodFirst published 2016 Copyright and Database Rights 2016 CW Research Ltd. All rights reserved

KFT TheCHEMICAL COMPLIANCECompany

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Chemicals Management and Control

INTRODUCTION

Demands for chemical controls, from basic raw materials to those in finished products for both consumer and industrial applications, nearly anywhere in the world, are expanding. The pressure is coming from legislation, consumers, consumer advocacy groups, other non-governmental organisations (NGOs), and retailers and manufacturers. Any company that manufactures, uses, handles or transports chemicals, regardless of size, must comply with a burgeoning list of regulations and trade group and end customer requirements. In many cases, there is little harmonisation; the requirements may relate to the same chemicals or products, but the data needed may differ and/or be expected in slightly different formats.

In the EU, the need to register small-volume chemicals for the 2018 REACH deadline is affecting a whole new set of small and medium-sized companies that have little or no experience with chemical control regulations. Overarching substance regulations, like REACH, continue to be developed and introduced in other countries around the world, as do regulations targeting specific types of products. Greater data and reporting requirements are anticipated in the US with the reauthorisation of TSCA finally moving forward. Even so, individual states continue to actively pursue their own regulations, creating an even more intricate and challenging patchwork of compliance requirements. The country-by-country variations in the implementation of the Globally Harmonized System (GHS) of classification and labelling of chemicals are also burdensome for companies that participate in international markets.

On top of growing legal requirements, consumer product companies face intense pressure from retailers who are responding to demands from NGOs. Many large retailers, industry trade groups and manufacturers have developed restricted substance lists (RSLs) and specific chemicals management and control policies to which suppliers must commit. Suppliers are thus inundated with requests for data from multiple customers, each with their own expectations.

Tracking expanding regulatory requirements and data expectations from customers has become an enormous task. Effective supply chain communication has become increasingly important, but continues to be challenging. Concern that many chemicals will be withdrawn from regulated markets is heightened.

Specific trends related to REACH, GHS, TSCA, other country-specific regulations and sector-related legislation are presented below, along with the key findings of the sixth annual Chemical Watch survey of service providers and in-house experts involved in chemical regulatory compliance. Results of our fourth annual jobs survey are also provided. A total of 693 people provided input to the survey. Additional sections on the laboratory services market and the challenges faced by the retail, cosmetics and personal care, toy, electronics, furniture and textile industries are included as well. Finally, we discuss the perceptions and general expectations for the chemicals management and control service provision market in 2016 of respondents to the Chemical Watch survey.

OVERVIEW

Combination of factors drive growth

When it comes to regulatory drivers, REACH has been the most influential factor by far each year of the Chemical Watch survey. In fact, the number of respondents indicating REACH was the most important factor rose for the second year in a row from 77% in 2013 to 79% in 2014 to 83% in 2015 [Figure 1]. This number is, however, still lower than its peak value in 2012 (89%), which coincided with the run up to the 2013 REACH deadline.

The REACH 2018 registration deadline was specifically noted by 62% of respondents. REACH compliance in Europe remains a very large effort for speciality chemical manufacturer Celanese due to the high number of chemicals, the need for coordination with substance

information exchange fora (Siefs) and the requirements for dossier preparation. Global product steward Philip Brondsema believes that registration of smaller volume products may be more complicated than that of large volume products. Not only are there many more chemicals; the Siefs will be smaller, and the amount of existing data is likely to be limited, he notes. Obligations for substances of very high concern (SVHCs) under REACH; compliance with US regulations; compliance with the EU classification, labelling and packaging of substances and mixtures Regulation (CLP) requirements; REACH evaluation activities and dossier updates; and China regulations were the other top regulatory drivers for respondents to the survey in 2015.

KFT TheCHEMICAL COMPLIANCECompany

Would you like more information? Please contact us:

Trade Wind B.V.Haagsche HofParkstraat 83 2514 JG The HagueThe Netherlands

T: +31 (0) 70 - 214 13 40F: +31 (0) 84 - 747 24 99M.: +31 6 5319 2758E: info@twnl.comW: www.twnl.com

ARE YOU IN NEED OF: Software to create your SDSs, Volume Tracking, Worker Exposures,

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Draft Workplace Instruction Cards and any other document you may require Draft Workplace Instruction Cards and any other document you may require Comply with the Detergent Directive (EC) 648/2004 Distribute SDSs to your customers with full tracking and automatic

distribution of updates Communicate with your ERP

DeDoks will Distribute your (multilingual) SDSs to your customers Send new versions automatically Publish your SDSs on your website with a multi-language interface Allow you to include other documents Enable your distributors to distribute your SDSs to their customers Interface with your ERP through FTP- or Webservice Work without any local installation (Webbased)

If you dont want to do the work yourself, we can Create your SDSs and Labels according CLP and all worldwide GHS-dialects Create your SDSs and Labels according CLP and all worldwide GHS-dialects

in over 45 languages. We just need your formulations, supplier SDSs and in over 45 languages. We just need your formulations, supplier SDSs and physical properties

Draft Workplace Instruction Cards and any other document you may require Draft Workplace Instruction Cards and any other document you may require Comply with the Detergent Directive (EC) 648/2004 Distribute SDSs to your customers with full tracking and automatic

distribution of updates Notify your products with the Poison Centres in Europe

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Figure 1

LEADING REGULATORY DRIVERS FOR SURVEY PARTICIPANTS83%

62%

49%

46%

45%

44%

40%

30%

27%

24%

23%

22%

21%

20%

19%

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18%

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0% 20% 40% 60% 80% 100%

REACH (any)

EU REACH 2018 registration

EU REACH SVHC obligations

US (any)

EU CLP regulation

EU REACH evaluation related activities/dossier updates

China regulations

South Korea regulations

Biocidal product regulations

National GHS classification, labelling and inventory notification regulations

US HazCom 2012 (GHS) Standard

Food contact material regulations

Taiwan regulations

US EPA Work Plan on Chemicals

US: California Safer Consumer Products Regulation

Nanomaterials risk assessment

Turkey regulations

RoHS regulations

Japan regulations

Brazil regulations

Canada Chemicals Management Program

Packaging regulations

Canada pending GHS in workplace legislation

International Carriage of Dangerous Goods by Road (ADR)

Malaysia regulations

US CDR

Conflict minerals legislation

International Maritime Dangerous Goods (IMDG) Code

Other Asean regulations

Cosmetics regulations

Agrochemical regulations

Mexico regulations

Russia regulations

Other US state legislation (Washington, Vermont etc)

Toy Safety regulations

Argentina regulations

Pharmaceutical regulations

Medical devices regulations

Israel regulations

Veterinary product regulations

% of participants

Intertek Scientific & Regulatory Consultancy places chemicals management and control regulations into two groups:

O legislative programmes that require the assessment and management of human health and environmental risks associated with existing chemicals that have already been present in the marketplace for many years, but whose risks have not yet been determined; and

O environmental and human health protection rules that require the upfront risk assessment of chemicals deemed to be new.

Both types of regulations are presenting challenges to manufacturers and users of chemicals. For regulations addressing existing chemicals, Joyce Borkhoff, senior director of Intertek Scientific & Regulatory Consultancy, notes that burdens on industry can be lessened by addressing data needs, targeting information gathering

SIEF AND CONSORTIA MANAGEMENT

SCC Scientific Consulting Company Chemisch Wissenschaftliche Beratung GmbH Am Grenzgraben 11 55545 Bad Kreuznach Germanyinfo@scc-hq.de www.scc-gmbh.de

COST EFFICIENT TESTING

REACH DOSSIER (IUCLID/ CSR)

TIME IS RUNNING THE COUNTDOWN FOR REACH 2018 IS ON

GLOBAL REGISTRATION SERVICES

OR AND TRUSTEE SERVICES

GHS/ CLASSIFICATION AND LABELLING

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activities, and balancing non-testing approaches with the need for more data. For new chemicals, multijurisdictional notification strategies and smart testing plans are also crucial for enabling timely and cost-efficient notification of substances in many countries/regions simultaneously while avoiding unnecessary duplication of efforts.

Regardless of the type of regulation, it appears that their number is increasing without any sign of a let up, according to Peter Douben, director of REACHWise. Smaller companies are faced with rising costs that are decreasing their margins to an unsustainable extent, all to implement increasing control measures for which they see little evidence of effectiveness, he says. He would like to see more effort directed towards raising standards in other countries to the European level, where the return on investment would be significantly greater. That would greatly benefit human health and the environment. he adds.

Chemical Watch survey respondents were also asked about several non-regulatory drivers of the need for chemicals management and control services. The reason given by most respondents in 2015 (65%) was downsizing of in-house teams the first time this factor has been cited most often [figure 2]. Customer demands and the growth of restricted substance lists and economic growth were chosen as important drivers by 49% and 42%, respectively, of survey participants.

Figure 2

LEADING NON-REGULATORY DRIVERS FOR SURVEY PARTICIPANTS

66%

49%

42%

29%

29%

26%

23%

20%

14%

8%

2%

0% 20% 40% 60% 80%

Downsizing of inhouse chemical management and control teams

Customer demands/restricted substance lists

Economic growth

Governmental policies/spending

Redistribution of regulatory compliance responsibilities withinorganisations

NGO pressure

Non-statutory voluntary corporate initiatives/CSR

Standards

Outsourcing of business support functions (by client organisations)

Increased commercialisation/better management of serviceprovider business

Other

% of participants

Downsizing of in-house teams probably reflects a greater need for specialised expertise and the hope of increasing efficiencies and reducing costs through outsourcing. Our main challenge with respect to chemicals management and control is complying with so many varied customer requests and requirements and the sustainability and chemicals voluntary standards that are proliferating, says Thaddeus Owen, a safety and sustainability engineer with furniture maker Herman Miller. Consultant Florian Soldner adds: Politicians need to act rapidly to develop legislation that ensures protection of health and the environment, but does so in a reasonable fashion that should not hinder innovation and new business development.

REACH Companies participating in the European market continue to invest significant internal and external resources to ensure compliance with many different aspects of REACH. On the one hand, firms that registered substances in 2010 and 2013 are working to address issues raised in substance and dossier evaluations. On the other, companies are faced with dossier preparation for the much larger number of small-tonnage chemicals that must be registered by the end of May 2018.

Many companies require assistance with authorisation applications, the development of authorisation roadmaps, and support during the public consultation phase for SVHCs, according to Ingrid Sekki, marketing manager for REACHLaw. She says the process is challenging due to the limited experience of all involved, particularly for authorisations based on socio-economic arguments.

REACHWises Dr Douben agrees that authorisation is a complex process and welcomes efforts by the EU Commission to simplify it. He is also surprised that so many companies are unaware of the implications of having substances added to the Annex XIV list. REACHLawis concerned by the fact that many companies believe that the job is finished once their registration dossiers are submitted. These companies do not understand the importance of having a chemical compliance programme to monitor changes/updates to regulations, reporting requirements and dossier evaluations, Ms Sekki states. Companies that lack substance management programmes are also concerned about the recent EU court decision on articles. These companies do not know what substances are present in their products [articles], nor do they have the IT and data management systems necessary to support compliance, says KFT Chemieservice managing director Karl-Franz Torges.

His clients are also frustrated by the lack of effective enforcement of REACH. They are watching other companies who have not invested significant resources to ensure compliance over the past five years continue to do business without any consequences. As a result, some clients with excellent compliance records halted activities in 2015, Mr Torges notes.

Echa has been active in getting the word out about the third and final registration date in May 2018, according to 3E Companys senior regulatory research analyst Scott Stephens. Those efforts are important because this deadline affects companies that place substances on the EU market in relatively low quantities (1-100tonnes/year), many of which are small or mid-sized enterprises (SMEs) that have not previously registered a substance under REACH. In addition, the number of registrations is

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expected to be much higher than observed for the previous two deadlines. Given these challenges and the fact that SMEs have a general lack of knowledge regarding the implications REACH registration, the impact of this last deadline has yet to be fully felt, Mr Stephens says.

It is important to distinguish between substances that have not been previously registered and those that already have, according to REACHWises Dr Douben. First-time registration of substances presents challenges of substance identity, working in a Sief, setting up of consortia or not, and so on. Even identification of a lead registrant can meet obstacles, he notes.

For substances that were previously registered, no lead registrant needs to be identified, but the fees for letters of access (LoAs) can be very high, and may even appear anti-competitive, particularly in small Siefs, he says. It is also important to note that, while at first glance smaller tonnage substances may seem to present little difficulties, most of the compounds CEHTRA is supporting can be classified as difficult substances, according to senior ecotoxicologist and director Paul Thomas. It is crucial to get as close to the true value as possible for experimental endpoints in order to avoid the possibility of misclassification and other pitfalls, he says.

Many industry sectors are slowly becoming aware of the growing need to take action with respect to REACH. Pharmaceutical companies, which use a large variety of chemical substances, some of which are SVHCs and/or exotic chemicals, are aware that they have to commit more budget and resources to chemicals management, according to Philip Capel, marketing director for software firm eSpheres. One problem is that some manufacturers are not aware that non-European suppliers may elect not to proceed with registration of substances they import into the EU in small volumes. What the impact will be on pharmaceutical end products is not clear. It will most likely not be realised until the point when chemical manufacturers announce that they will not be registering their products for REACH 2018 or applying for an authorisation dossier for candidate substances that were previously registered, he comments.

Lynn L Bergeson of law firm Bergeson & Campbell, PC says companies really should already be assessing their regulatory options, deciding what each wishes to do and advising downstream customers accordingly, not to mention determining their testing needs to reserve adequate and appropriate testing capacity. Failure to secure suitable capacity could trigger disastrous consequences. The law firms international consulting affiliate, The Acta Group, is already seeing the impact of inadequate planning and there is a lot of scrambling going on now, Ms Bergeson says.

SMEs and first time REACH registrants do not fully understand that they need to start preparing their registration dossiers and that the challenges will be different from those faced in 2010 or in 2013, states Ms Sekki of REACHLaw. For instance, there are many Siefs without lead registrants, and many Sief members who submitted pre-registrations will in fact not register at all, which means there will be fewer companies to share the costs and build registration dossiers. Many companies are not only putting off the costs of registration; they are delaying the decision regarding which products to remove from the market because registration costs make them economically unnviable at low tonnages, according to Daniele Campi Martucci, general manager of Toxicon.

REACH testing presents its own challenges due in part to a lack of understanding of the regulations. BioReliance has observed that the requirements for genetic toxicity/mutagenicity testing are particularly confusing for many companies. Although the initial guidelines and subsequent guidances have spelled out the assays, it is difficult for registrants to navigate the integrated testing strategy (ITS) and understand why and when each assay should be used, explains toxicology marketing manager Scott Hickman. For the REACH 2018 deadline, in vitro bacterial gene mutation data must be reported, and any tests that provide positive results must be followed up with additional testing. Mr Hickman adds that the REACH regulations call for registrants to seek expert advice in this area.

GHS: SIGNIFICANTLY MORE COMPLEX ENVIRONMENT The varied implementation of GHS around the world is challenging companies that sell products in multiple markets. Whilst GHS is supposed to provide harmonised regulations, to date there are significant differences in how each country has chosen to implement its hazard communication programmes, with individual customs regulations and national laws. In addition, some companies have applied older versions of the legal text whilst others are using newer versions, explain Jos V Cantavella Cabedo, project manager for ChemSafe. The environment is significantly more complex now than even three years ago due to the need for communications from suppliers, knowledge of product compositions, the many destination countries and the regulation variations, agrees Dr Philip Brondsema of Celanese.

The SDS development process is also quite complicated. New information and documents must flow from chemical suppliers to speciality chemical manufacturers, formulators, distributors, warehouses and finally to store shelves. At each step, a regulatory expert must review component SDSs, make a classification decision and work through an SDS and label publishing process, according to Dr Brondsema. Importantly, each step in the supply chain can move only as fast as the pace of its slowest supplier. Since formulator companies tend to have lower regulatory expertise and larger numbers of products to be reviewed, the pace for reaching compliance for products on the shelf is very slow, he says.

Even at this stage, many downstream users do not have complete chemicals inventory lists of mixtures and substances used within their companies, and thus need to start by building them. They are not really prepared to construct safety data sheets (SDSs), let alone receive, request and evaluate them, according to eSpheres Mr Capel. The most important document for hazardous chemicals communication in the supply chain is the SDS. While the quality of SDSs has generally increased, inclusion of exposure scenarios which is required for certain substances and mixtures in the EU remains limited. In addition, those provided by chemical manufacturers are often very complicated, making it difficult for their customers to read and understand, he adds.

In Europe, companies still find it a challenge to maintain compliance, agrees REACHWises Dr Douben. He also notes that record keeping is particularly important when the classification of a product changes so that companies have a clear archive of who received which version.

Ashland Inc finds keeping track of SDS updates from suppliers including those that are not provided centrally

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a very demanding task. Labelling of its products is one of the most challenging aspects of GHS, according to global hazard communication programme manager Esmeralda Michilsen. We recognise the importance of accurate labelling and are working hard to make sure we have the most efficient way to label products that are sent all over the globe, she says.

In the US, many companies are still awaiting information from their suppliers before creating their US GHS SDSs, and those that are ahead of the curve are now getting ready for GHS in Canadawhile managing an ongoing stream of GHS implementations and updates around the world. The level of regulatory complexity that companies must manage in order to achieve compliance continues to increase with globalisation and heightened environmental scrutiny, says Uday Virkud, president and CEO of 3E Company.

In 2015, Osha recognised the impossibility of the entire supply chain being compliant with GHS by June 2015, deferring the deadline and giving chemical manufacturers and formulators time to work in good faith to bring their products into compliance. However, distributors and warehouses anticipate significant and very expensive re-labelling issues, according to Dr Brondsema.

US: POSSIBLE TSCA REFORM, EPA ACTIVITIES AND MORE STATE REGULATIONSThe big question in the US these days is what will TSCA reform look like? The EPA and state legislatures are not waiting to find out, though.

The TSCA Modernisation Act (HR 2576) was passed by the House of Representatives in June 2015. The Senate followed suit in December, passing the Frank R Lautenberg Chemical Safety for the 21st Century Act (S 697), a significantly different approach to TSCA reform than set out in HR 2576. The House and Senate must reconcile the two bills to achieve passage in Congress and send a final version to President Obama for signing. TSCA reform supporters hope this will occur sometime in 2016 before the November general election. Ms Bergeson, a Washington, DC-based lawyer, notes that while House and Senate insiders are expressing optimism over the enactment of TSCA Reform legislation this year, it remains to be seen if election-year politics will prevent that from happening. Another uncertainty is reconciling the vastly different House and Senate versions and trying to anticipate what will emerge.

Once the law goes into effect, individual regulations will need to be outlined, drafted, reviewed and promulgated. Since TSCA is the sole domestic industrial chemical management law in the US, implementing a massively revised approach will take time and careful scrutiny. Because the timing for passage is at best unclear, most companies are waiting before taking any specific actions. Despite the high level of uncertainty, there is a general consensus that most reform will impact the existing chemicals regulatory framework, according to Michael Cleuvers, managing director for industrial chemicals and biocides with Dr Knoell Consult. As with any new regulations, however, he recommends that companies need to track regulatory updates while maintaining compliance with requirements that have yet to be changed.

The biggest challenges, according to James Lee, senior regulatory analyst with 3E Company, are the uncertainty

around what new rules EPA will promulgate as a result of TSCA reform and when the changes will take effect. EPA has a limited budget, and promulgating and implementing new regulations will be a daunting task. In addition, the rulemaking process in the US can take a number of years, and companies will want to know when the new laws effects will trickle down to their day-to-day operations, he says.

In the meantime, companies are proceeding as usual with new chemical notifications and preparing for the next round of chemical data reporting (CDR). Dr Cleuvers notes that there is a major shift underway towards electronic data submission (all TSCA notifications must now be made electronically), and Dr Knoell Consult is receiving numerous requests regarding how pre-manufacturing notices (PMNs) and CDR information must be submitted electronically via the EPAs CDX portal.

The EPAs Office of Pollution Prevention and Toxics continues to make progress on its Work Plan Chemicals programme and on issuing significant new use rules (Snurs).

At the state level, California will continue to attract much attention in 2016. It recently issued a draft of the Stage 1 Alternatives Analysis Guide under its Safer Consumer Products Regulations (SCPR) and is trying to amend Proposition 65. The heightened activity in California can be attributed in part to the acceleration of TSCA reform, according to 3E Companys Mr Lee, who suspects that the state does not want to deal with federal pre-emption battles. Ms Bergeson adds that the growing number of chemical product regulations emerging from California and other states, including Washington and Oregon, has definitely accelerated the demand for TSCA Reform. The sophistication and maturity of state product laws have made states and their federal Congressional representatives fiercely protective of states rights to regulate, and they are aggressively committed to narrowing TSCAs pre-emptive effect. Without question, federal pre-emption is the single most controversial aspect of TSCA Reform, Ms Bergeson asserts.

GROWTH OF CONTROL LEGISLATION IN ASIA, EXPECTATIONS FOR LATIN/SOUTH AMERICAAsia-Pacific is the region with the fastest development of new legislation. Asean countries including Thailand, Malaysia, Indonesia and Vietnam have recently announced changes in their local chemical legislations. China, Taiwan and South Korea are also active. In addition, movement is expected in Russia, India and African countries. Governments in Latin and South America are discussing the introduction of chemical inventories as a first step towards chemicals management legislation, but it is not yet clear what type of approach they will take.

In China, the fact that there are no tonnage limits for the registration of hazardous chemicals will have a significant impact, according to David Wan, head of strategic operations for Chemical Inspection & Regulation Service (CIRS). Even if only one kilogram of a hazardous chemical is being brought into the country, that substance must first be registered, he says.

In addition, chemical identification testing will need to be completed twice, because the National Registration Centre of Chemicals (NRCC) and Chinas Inspection and Quarantine (CIQ) Services each only accept testing results

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Chemical Watch | Global Service Providers Guide 2016 Page 13

from their specific qualified laboratories. Finally, Mr Wan notes that beginning in 2015, notification to provincial authorities is required for existing disinfection products, which is complicated, because the different provinces have different registration processes, approaches to supervision and timing requirements. Yong Jiang, project director of the Product Registration and Compliance Department with the China National Chemical Information Centre (CNCIC)believes, on the other hand, that decentralisation of administration licensing will have the effect of simplifying regulations and making them more practical.

In South Korea, there has been a lot of confusion regarding the joining of chemical substance information communicative organisations (Cicos) under the Korea REACH regulations, since a deadline of 30 November 2015 was set for companies to come forward as lead registrants, according to Taro Ishikawa of the Japanese consultancy Jemai. Cicos are similar to Substance information exchange fora (Siefs) for EU-REACH. The Korean Ministry of Environment (MOE) announced on 21 January the list of 120 substances subject to registration for which lead registrants have been selected. Dr Knoell Consults Dr Cleuvers is interested to see how the Korean authorities will manage the high number of dossiers that are expected under K-REACH, as well as joint submissions and data sharing.

Celanese is planning on using its European REACH technical expertise with Asian leadership to meet the requirements of K-REACH, although Dr Brondsema expects the dynamics to be different. EU-REACH compliance is largely accomplished by European experts, typically working from significant corporate regulatory centres. Koreas industry has a very small group of Korean conglomerate companies and many multinationals, many of whom do not have a regulatory centre in Korea, he explains.

In Japan, Jemai has many clients that are working to meet the requirements of the amended Industrial Safety and Health Law (ISHL). Under the revised regulation, risk assessments must be conducted on an additional 640 substances by 1 June. These compounds must also be labelled correctly by that date.

The enormous amount of data management and the lack of consistency between regulations globally, where mandatory classifications are not aligned and existing information cannot be efficiently utilised in multiple regions is a real challenge for us, says Ashland Services Ms Michilsen. Her company relies on the assistance of trade associations such as Cefic and participation in various association working groups to stay up to date on various regulatory developments.

Advocating and compliance in countries like the Philippines, Indonesia and India are more difficult than in China, Europe and the US. The ability to effectively work with regulators and regulations in these environments must be developed, asserts Dr Brondsema.

The OECD Clearing House for New Chemicals (CHNC) is attempting to address some of the issues mentioned above. Interteks Dr Borkhoff says: These opportunities focus on streamlining the new chemicals notification and assessment processes by enhancing information-exchange and work-sharing, facilitating greater mutual recognition of assessments (MRA) and progressing towards mutual acceptance of notifications (MAN).

Companies should be aware that regulators across the world are reaching out to each other to understand the chemical risk assessment and risk management initiatives

of their fellow governments, and that risk assessment decisions will be increasingly spreading from one country to another, according to Dr Borkhoff. Consequently, a risk assessment decision made in one country may very quickly impact a global business.

PRODUCT-RELATED REGULATIONS In Europe, and increasingly in other parts of the world, end product manufacturers are faced with regulations targeting specific industry sectors, such as biocides and cosmetics, material types (nanomaterials) and specific categories of chemicals (perfluorooctanoates (PFOAs), microbeads).

Many use-specific regulations in the EU have an overlap with REACH because the different sector-specific uses have to be addressed in REACH registration dossiers. In addition, as there are differences between chemical notification regulations from country to country, there are also differences with product- and sector-specific regulations. These differences across all chemicals management and control regulations can only be addressed by building areas of very specific knowledge. There is usually no one size fits all approach possible, but a need for a really individual, case-by-case assessment, concludes Dr Cleuvers of Dr Knoell Consult.

SUPPLY CHAIN ISSUESAs well as communicating effectively about the substances they make, use and handle, companies in supply chains face increasingly complex patterns of customer needs, requiring more and better information, according to Toxicons Mr Martucci . Communication within the supply chain has become crucial when we are talking about chemical compliance, and companies are struggling, states REACHLaws Ms Sekki.

There is an pressing need for companies to actively manage the regulatory risks, because regulatory actions can mean considerable investment to improve operating conditions, replacement or substitution and potential supply chain disruption. Therefore, a strategy and action plan is recommended to determine the potential risk management options that the authorities may apply and how to act accordingly, says Dr Ying Zhu, Partner-COO at REACHLaw. For downstream users, such exercises should start with the inventory of chemicals used along the supply chain.

Doing so is not an easy task, though, as most downstream users do not have chemical or toxicological competences to determine which substances are EHS relevant, according to eSpheres Mr Capel. In addition, it is necessary to gather and manage a large number of different data sets from safety data sheets and other documents. Many companies are relying on inadequate IT tools largely Excel spreadsheets and are unaware of the negative impacts and potential enforcement consequences that not using an auditable and secure chemical data management tool can have on their businesses, Mr Capel says.

Advanced software solutions are increasingly being used to help companies manage data and respond to the growing numbers of questionnaires they receive from customers throughout the supply chain, according to Mr Riku Rinta-Jouppi, Partner-Head of Global Compliance at REACHLaw. These data management solutions can significantly reduce the workload involved in determining the compliance status of raw materials and raw material suppliers while also increasing transparency in the supply chain, he adds.

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Ton van der Kaaij, senior SHE coordinator at Quaker, , says while all parties are learning, the process is quite time consuming.

Ensuring internal consistency of interpretation and compliance is an additional concern for Celanese. More customers are asking for product compliance information for multiple countries, and supplier companies must ensure that regulations are consistently interpreted and applied, says Dr Brondsema. Celaneses solution has involved establishing compliance teams that are global instead

of regional and documenting decision practices as a department or as teams.

Innovative companies located in the middle of supply chains may have the greatest opportunity to influence them, according to Mr Martucci. Such companies can elect to use suppliers that guarantee complete and proper documents, import products without restricted substances and place less hazardous, alternative substances and safe products on the market, he says.

CAREERS AND SALARY SURVEY

Career development in the chemicals management and control sector

The ongoing trend of increasing chemical management and control regulations and continued growth of the global economy created conditions in the sectors jobs market in 2015 very similar to those observed in 2014. Demand outstripped the supply of experienced candidates and recruiting continued to be a challenge in most chemical control areas, according to John Sherratt, regulatory affairs business manager with recruitment firm VRS Regulatory. While the conditions resulted in upwards pressure on salaries for many jobs, some positions saw a decline in wages. Companies looking for experienced hires are competing fiercely to attract/retain staff, while those few that are willing to hire and train new graduates are being creative with enticements in order to attract high-quality candidates.

In this sixth edition of the Chemical Watch survey of professionals involved in global chemical management and control, we present our fourth consecutive set of data regarding salaries, pay rises, bonus levels and career prospects in the sector. We were once again fortunate to have the participation of people holding numerous different positions and representing many different types of organisations, and we sincerely thank them all. Without their participation, it would not be possible to provide this information. The results are summarised below and, where appropriate, are compared to those obtained for the 2014 survey.

It is first worth providing some information on the survey participants. Over 80% are 30-60 years old, and just over half (54%) are men. The largest percentage (30.6%) identified themselves as specialists/technicians. Nearly as many are project or team managers (28.4%) and senior managers (22.8%). The remainder include directors or associate partners (11.2%), juniors/graduate trainees (3.5%) and government officers (3.5%).

Staffing trends indicated by survey participants in 2015 were similar to those in 2014. Slightly more than double the number of respondents reported that their regulatory teams increased in size in the last 12 months, compared with those saying they were downsized, an indication of the increasing regulatory demands and improving economies (33.4% increasing versus 15.4% decreasing, Figure 3). Looking towards the next 12 months, the trend continues, with just 9.5% saying their team is likely to be downsized, compared with 34.2% saying they are likely to be increased.

Figure 3

STAFFING TRENDS

33.4% 34.2%

51.2%56.3%

15.4% 9.5%

Last 12 months Next 12 months0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

% of participants

Decreasing Static Increasing

In addition, a slightly higher number of Chemical Watch survey respondents (37.2%) believe that job prospects are good within their own country compared to a year ago (35.5%). On the other hand, more participants also believe their prospects are poorer (14.0% in 2015 versus 8.4% in 2014, Figure 4). Global opportunities are greater, with 53.7% of respondents seeing them as good and just 5% as poor. However, they do not see things as positively as they did two and three years ago, when 57.1% and 59.0% of respondents rated global job prospects as good. There may be a positive note, here, however: for the first time in three years, the percentage has increased year on year. The number of respondents in 2014 that saw their global job prospects as good was 52.2%.

Figure 4

JOB PROSPECTS

% of participants

37.2%53.7%

48.8%

41.3%

14.0%5.0%

In your country Globally0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

Poor Stable Good

The numbers are also slightly improved with regard to career progression. More survey respondents continue to see greater opportunities within their own companies and across the wider jobs market, although the latter results are nearly twice the former. Specifically, 60.5% and 34.0% of Chemical Watch survey respondents see good prospects in the overall market and with their current employer, compared respectively to 59.3% and 31.2% last

year [Figure 5]. The number of survey participants in 2015 that believe their opportunities for advancement are poor if they do not move elsewhere stayed similar (28.4% versus 28.5% in 2014). These results suggest that many chemicals management and control professionals are willing and even eager to switch companies.

Figure 5

CAREER PROGRESSION OPPORTUNITIES

% of participants

34.0%

60.5%

37.6%

32.4%

28.4%

7.1%

In your company Wider jobs market0%

10%

20%

30%

40%

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Poor Neither Good

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On the other hand, while survey participants may see job prospects within their companies as limited, more of them feel similarly secure in their jobs than in the previous year (68.2% versus. 65.3%, Figure 6), as slightly fewer felt more secure (20.9% versus 23.5% in 2014). Across all roles, similar levels felt that job security improved (20.1% in 2015 compared to 20.3% in 2013 and 19.9% in 2014).

Figure 6

JOB SECURITY COMPARED WITH 12 MONTHS AGO

% of participants

20.9% 20.1%

68.2% 64.5%

11.0% 15.4%

In own role Across all roles0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

Less secure Similarly secure More secure

Meanwhile, unlike in 2014, the level of job satisfaction increased slightly in 2015 to 58.0% from 55.9% in 2014 [Figure 7]. The number of respondents that were neither satisfied nor dissatisfied also increased from 31.5% to 30.7%. The number of participants that were dissatisfied with their jobs declined from 12.6% in 2014 to 11.3% in 2015.

Figure 7

JOB SATISFACTION

Satisfied58.0%

Neither satisfied or dissatisfied

30.7%

Dissatisfied11.3%

Another difference from the 2014 Chemical Watch survey appears in the distribution of average salaries by job title [Figure 8]. While little variation was observed in 2014 and 2013, a much larger distribution was revealed in 2015.

Salaries ranged from 45,200 to 48,700 in 2014 and 37,400 to 56,700 in 2015, indicating both significant increases and decreases for different positions (although clearly samples vary year to year which means this comparison is indicative only). Most notably, the average salary for regulatory positions show a decline from 47,700 in 2014 to 37,400 in 2015, while the environment, health and safety (EHS) management category showed an average salaries increase by a similar amount, from 49,000 to 54,800. The average salaries calculated for consultants and regulatory affairs managers also increased, but those for product safety/ stewardship managers and scientists declined from 2014 to 2015. Interestingly, however, the average salary increased slightly from year to year (47,200 in 2015 versus 46,300 in 2014).

Figure 8

AVERAGE SALARY BY JOB TITLE

47.2

52.2

54.8

56.7

42.5

37.4

48.6

40.3

47.2

0 10 20 30 40 50 60

Business management/development

Consultant

EHS management

Other

Product safety/stewardship

Regulator

Regulatory aairs management

Toxicologist/chemist/scientist

Average salary

Euros 000s

There is similar variation in average salaries when considering the type of organisation [Figure 9], and noticeable differences compared to the results obtained in 2014 (again, presented with the caveat of different samples). For instance, survey respondents working in other sectors earned the highest average salary by far (57,300); this position was held by those in engineering, automotive, aerospace and similar fields in 2014 (average salary 57,700 in 2014 compared to 49,200 in 2015). Participants with positions service providers earned the next highest average salaries (49,500) in 2015, significantly higher than the value in 2014 (45.800). Positions in the chemical and life sciences and other manufacturing industries earned average salaries of 47,200 and 46,300, respectively. Those working for government agencies once again earned the least of all survey participants (39,600).

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Figure 9

AVERAGE SALARY BY ORGANISATION TYPE

47.2

42.9

49.2

39.6

57.3

46.3

49.5

46.0

0 10 20 30 40 50 60 70

Chemicals, life sciences and similar

Consumer products, cosmetics and similar

Engineering, automotive, aerospace and similar

Government & agencies

Other

Other manufacturing

Service provider, including consultants,laboratories, lawyers etc

Trade association or professional body

Euros 000s

There was once again very little difference in average salaries when considering company size. Participants at companies with over 250 employees earned an average of 47,400, while those at medium-sized organisations with 50-250 employees earned an average of 46,700, and those at firms with less than 50 employees earned an average of 46,900.

On the other hand, company location continued to have a significant impact on earning potential, according to the results of the Chemical Watch survey [Figure 10]. Respondents in Europe still earned the highest average pay by far (54,100), while those in North America and the rest of the world earned on average slightly over two thirds that amount and less than the average annual salary of 47,200. Interestingly, the average European salary declined slightly from the 2014 figure, while salaries elsewhere increased, particularly in North America.

Figure 10

AVERAGE SALARY BY JOB REGION

54.1

39.5

38.0

47.2

0 10 20 30 40 50 60

Europe

North America

Rest of world

Average

Euros 000s

As expected, salaries also varied with respondent age [Figure 11]. Survey participants ranging in age from 36-40 and 46-50 earned the most on average (53,400 and 51,500) respectively. The shift in the lowest earning age bracket from the oldest respondents to the youngest continued in 2015, and survey respondents just entering the workforce earned a higher average salary of 35,900 in 2015 compared to 26,300 in 2014, and more than the average salary they earned in 2013 (31,300).

Figure 11

AVERAGE SALARY BY AGE

35.9

40.6

48.5

53.4

48.1

51.5

50.1

43.3

33.7

51.1

0 10 20 30 40 50 60

21-25

26-30

31-35

36-40

41-45

46-50

51-55

56-60

61-65

>65

Euros 000s

For survey respondents who did not receive a promotion in 2015, the average pay rise was 2.4% (up on the 2.0% in 2014) and ranged from 1.7% in Europe to 2.2% in North America and 5.6% in the rest of the world (up significantly from 3.8% a year ago) [Figure 12]. On a positive note, over two thirds of Chemical Watch survey respondents earned an average bonus of 11.6% in 2015, which is slightly up from 11.0% in 2014. Participants in Europe and North America earned bonuses close to the average (10.4% and 10.5%, respectively), while those located in other parts of the world reported receiving much higher average bonuses of around 18%.

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Figure 12

AVERAGE PAY RISE

1.7

2.2

5.6

2.4

2.5

2.9

7.4

3.3

8.5

8.5

11.0

9.2

0 2 4 6 8 10 12

Europe

North America

Rest of world

Average

%

Excluding promotions Including promotions

Only promotions

The results of the Chemical Watch survey reflect key trends in the industry identified by recruitment professionals. The demand for experienced chemicals management and control professionals continues to exceed supply. The number of job openings increased in 2015, resulting in some upward pressure on salaries, according to Mr Sherratt. The inevitable effect has been an increase in interest to switch companies, he says. The upcoming REACH 2018 deadline may be a factor as well; he notes that people often see the passing of a big deadline as a line in the sand and an opportunity to look for something new. Companies are fighting hard to retain staff, and over 80% of job movers have been counter offered, Mr Sherratt adds.

Quality of life is also an increasingly important issue for most candidates, and people are less willing to move from one company to another if it requires uprooting their families or giving up other benefits, according to Terry Leyden, president of recruitment firm the Leyden Group. He also notes that most experienced chemicals management and control professionals are fully employed and engaged in their jobs, so real incentives beyond higher pay are needed to get them to switch employers. Such incentives include promotions and/or greater opportunities for advancement, more fully encompassing relocation packages, continuing education opportunities and more frequent salary reviews. Companies seen as being in more attractive locations or offering greater stability may also draw experienced candidates away from a current job.

Many companies are also offering cross-training into new regulations, rather than waiting for someone with the exact regulation/directive knowledge, and increasingly putting faith in general regulatory knowledge. This approach is attractive to candidates looking to broaden their knowledge base, according to Mr Sherratt. Patrick B Ropella, president and CEO of recruiting firm Ropella,

agrees that in todays competitive jobs market, companies cannot worry about finding candidates with the perfect skill sets. Companies should hire for attitude and train for skills, otherwise they will lose quality candidates and end up with unfilled positions, he says.

Mr Ropella adds that hiring is just like dating, and the relationship-building aspects of recruiting are as important as the financial package. In addition, a quick decision-making process is essential in a competitive jobs market; the longer it takes to choose a candidate, the more choices he/she has and the more likely the candidate will go elsewhere.

An additional concern for Mr Leyden is the aging of the workforce across all industries; a large portion of workers, including chemicals management and control professionals, is rapidly nearing retirement age. Most companies still do not see regulatory/product stewardship positions as places for career advancement and continue to seek people with experience that can start working immediately without much need for training, whether they are people with regulatory experience from other companies or internal employees that have an understanding of the companys products, technology and culture and are likely to quickly learn the regulatory/product stewardship requirements, he explains.

That viewpoint is confirmed by Celaneses Dr Brondsema. New graduates are rarely recruited into chemical compliance roles. In these positions, experience in industry functions such as R&D, technical service or toxicology are highly valued and provide needed perspective to compliance experts, he states.

Hiring is difficult, though. The market for compliance professionals is mature in North America and Europe. But in Asia there is a very limited pool of established compliance professionals, and hiring and retaining qualified staff in a young regulatory culture is a significant challenge, Mr Brondsema notes.

The situation is only expected to worsen, according to Mr Leyden, given that many companies continue to assume they will be able to find experienced people to meet their needs without investing in the training and education of a new generation of professionals.

Another consequence of this hiring approach is that there are limited entry-level positions available for new graduates looking to start a career in chemicals management and control. One exception, according to Mr Leyden, is jobs related to safety data sheet (SDS) creation/authoring, which have increased in response to new GHS regulations; new graduates are often hired for these positions. Mr Sherratt agrees that there was increased demand in Europe for positions dealing with classification, labelling and packaging during the first half of 2015, with demand continuing today for SDS writers at companies with very large product portfolios. Biocide regulatory skills were in demand in the latter half of 2015 and continue through 2016 due to coming product authorisations.

On the other hand, Mr Ropella notes that graduates with science, technology, engineering and maths (STEM) degrees remain in short supply, and it will be years before this situation is resolved, if ever.

Universities are trying to address the need for candidates with more practical experience by aligning curricula with industry needs and developments, according to Mr Sherratt. Many of these programmes include a period of time working with a company, and this relevant experience in the industrial workplace is seen as very valuable. I think we will see an increase in these types of

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