India consumes around 15 million tonnes of Plastic annually which is expected to go up to 25 million tonnes in the next five years. There are approximately 25,000 companies producing plastic in India employing over 3 Million people.

Companies in this industry produce certain harmful waste, hazardous effluents and chemicals, causing air, water and soil pollution. As a result, there are serious implications on applicability of Acts and Compliances specially EHS (Environment, Health and Safety) in addition to safe working conditions for the employees. It leads to various registrations, licenses, approvals, consent orders and compliances for Pollution Control Board (PCB), Environment Protection Act, 1986, Plastic Waste (Management and Handling) Rules, 2011 which are required to be fulfilled by these industries immediately.

Our Client

Our client is one of the leading plastic manufacturing companies in the western india, having 3 factories and a corporate office, with over 1,500 employees including the contract labour and full time workers. It manufactures products in 12 different categories.

Our client is a major supplier of products to leading retailers in the USA and Europe. As a result, it would have to go through several customer audits every year. In these audits, the customer would look for evidence of compliance across 50 parameters including several permissions, licenses, registrations, maintenance of registers, returns, filings, challans in Labour Laws and EHS compliance categories.

Our client had several challenges in managing its compliances. The MD, who is the promoter and director as well, was concerned about their regulatory program. Some of the key challenges are as given below:

  • Lack of confidence in the list of applicable acts and compliances
  • Issues in day to day tracking of the status of key compliances as it was largely manual and spreadsheet based
  • Several critical observations in customer audits
  • Loss of business in one instance from an international customer due to failed compliance audit
  • Manual search for applicable Legal Updates across Central and States
  • No Central document repository of all Compliance documents
  • Several instances of financial penalties on account of delays and missed compliances
  • Multiple instances of missed display compliances

Our client was primarily looking for a compliance automation solution that could help them manage customer compliance audits well. Such a solution would help provide workflows, integrated document management, legal updates and manage client specific compliance requirements as well.

Avantis Engagement

Avantis engaged with the client in 2018, with the implementation of AVACOM. A team of 2 SMEs visited their office for a duration of 1 week to understand their business. The team met their Managing Director, Compliance Officer, Vice President Operations, Vice President International Business and Head of HR.

Phase 1 - Business Discovery

This phase of the project focussed on understanding their business to establish the applicability of Acts and Compliances. Comprehensive information was collected via in-person interviews / meetings / discussions with the Board & Management, individual department heads, and other representatives in the company. The following items were collated:

  • Business Set up (Group, Entities, Locations, number and nature of establishments, Industry, export)
  • Customer Base - Domestic and International
  • Product Range - Kitchenware, Storage containers, Laundry Ware, Chopping Boards etc
  • Equipment & Machines
  • Establishment Types
  • Mandatory repeatable items driven from their global headquarters

Phase 2 - Compliance Applicability Assessment

Avantis identified several Boilers, Pressure Vessels, Hoists and Lifts, Lifting tools and tackles, Gas Cylinders, Chemical tanks, HI-Tech Machines, among others. These equipment were located in various plants based in all 3 locations leading to applicability of different Acts, guidelines and Compliances.

Our Client being one of the leading exporters of plastic products also has to comply with global standards which were different for different countries. In addition, there were client specific requirements of processes and quality standards as well.

Phase 3 - Implementation

Avantis assigned a 4 member team of SMEs to work with the client in their respective manufacturing plants. Some of the key activities in this phase are as given below:

  • Map the Client Organisation (Group, Entities, Sub-Entities, Locations, Departments
  • Review of identified applicable Acts and Compliances with respective department heads
  • Discussion on identified gaps with MD, CFO and compliance head
  • Comprehensive audit by a team of researchers to obtain recent regulations by the central or state government to meet their proper compliance
  • Mapping of Compliances to specific users along with their roles
  • Hands on training sessions with user groups based on their locations and roles
  • Dashboards were created and provided to the users, having automated reminders, alerts
  • Assists in implementation of risk assessment process to stratify risk based on impact and likelihood of occurrence
  • Provides compliance program advisory and compliance work plan supplementation

A total of 22 users across all the locations were identified and grouped into Performer, Reviewer, Approver and Management Roles. The project was completed in 5 weeks. A total of 1,890 Compliances were identified and mapped across the users.

In Conclusion

Companies in Plastic Industry have to grapple with a complex compliance environment. If the company serves international markets, the requirements increase exponentially due to additional standards.

Compliance Management becomes a critical roadblock to scale. Missed or delayed compliance are a serious drag on top line and bottom line. It leads to anxiety, lack of predictability and undue stress on people and financial resources of the company.

Our client went digital in their Compliance Management. They migrated from an ad-hoc, people dependent and paper based to predictable, process based digital compliance program. The Compliance officer now has access to real time dashboards. This has enabled him to improve on time compliance dramatically. The penalties have gone down across the company. Missed compliances have almost disappeared. They are much better prepared for their periodic customer audits. The culture has seen a serious shift towards greater accountability and transparency.

Project Highlights