In a recent conversation with one of our account managers, he asked, “So, what has the year that we’ve been in COVID lockdown been like for you?”
I had to admit, it’s been challenging at times. I can count on one hand the number of times I’ve been able to eat in a restaurant or felt comfortable enough to do so. The last time I set foot in our Northbrook office was March 13, 2020; I’m guessing all the tchotchkes that border my desk have a healthy layer of dust on them by now. But I was able to move to another state in that time, and get married, so it’s been a mixed blessing.
“No, no,” the account manager said. “I meant, how has COVID impacted the world of regulatory?”
Oh, that’s easy… it’s like it never happened.
“Wait a minute. How can that be?” he asked. “Everyone else has had their lives turned upside-down.”
This is indeed true. And, since those of us who have worked the regulatory desk for any length of time are used to “controlled chaos,” it was almost expected that there would have been waves of requests somehow related to COVID-19.
Let me explain. The regulatory world tends to operate on a hair-trigger of confusion and panic any time something new or unusual enters our realm. The instant any new threat creeps in, or any kind of change is announced, we become more popular than a relative who just won the lottery. A prime example is the furor that surrounded the Jatropha plant, which was supposed to be a saving grace for the biofuel industry some years back. Based on an FDA advisory that stated products such as oils, glycerin or protein derived from the Jatropha plant could be toxic, regulatory desks like mine were suddenly flooded with requests for statements that the resins we’ve been selling aren’t formulated with its derivatives. Oh — and they needed those statements now. In other words, a typical day for me. (Spoiler alert: it ain’t there.)
So, using history as a guide, it might seem surprising that we weren’t inundated with regulatory requests related to the coronavirus. But, if you step back and think about things, the fact that we didn’t get such requests shouldn’t be surprising. You see, animal-derivatives are not used in many plastic resins. For those that do utilize them, the substances (such as tallow) must undergo extremely strict sterilization procedures. The overlying belief (as well as the scientific traceability) is that COVID-19 is related to bats, while the most common animal from where tallow is derived is from the bovine family. I’m no resin engineer, but I can state with 99.9999% confidence that substances derived from bats are not used to make thermoplastic resin. If they were, Ozzy Osbourne would be buying railcars of the stuff.
In addition, plastic resins themselves are subject to high temperatures during processing. So, if there just so happened to be contamination lingering on the pellets (another spoiler alert: there isn’t), the processing process should nip that in the bud, to use the scientific terms.
As for the rest of the regulatory world? FDA-compliance is still FDA-compliance (and hasn’t changed in the 12 years I’ve been doing this job). CONEG is still CONEG. RoHS and SVHC are still RoHS and SVHC (as long as you don’t live in the U.K., that is — but that’s a rant for another day). You still have your systematic updates to various pieces of legislation — in fact, SVHC just underwent its second update during the pandemic — but other than those, the world has continued to spin normally for regulatory geeks such as myself. We’re just practicing our trade at desks set up in bedrooms, or kitchen tables… heck, anywhere we can grab a Wi-Fi connection.
The biggest difference in our world is, frankly, the same one that everyone else is facing — namely, how we interact with other people. Where we would have been visiting each other’s desks in a centralized office to discuss various items, or hopping on planes to meet with customers or to speak at events, we all now rely on telephone calls, emails and online meetings to conduct personal business. While I love being able to work from the comfort of my house, surrounded by my family, I do miss face-to-face interactions with my fellow Mployees, or discussing regulatory topics with industry leaders at conferences.
So, while our “normal” lives will probably never be like what they were just a year ago, regulatory has continued to chug along like a well-oiled machine. I guess there is some comfort to be taken from that.
Just as we were about to conclude our conversation, the account manager paused. “Wait a second… didn’t you just say we had an SVHC update a few paragraphs ago?”
That’s another story for another blog post…
Christopher Thelen is M. Holland’s Regulatory Specialist, responsible for obtaining, supplying and maintaining a database of documents covering numerous regulatory issues (e.g., CONEG, FDA, UL, NSF) for clients, as well as technical data sheets and MSDS. He has been with M. Holland for over 20 years.