Daniel E. Sullivan – The Impact of Chemical Regulations on Global Contracts


Businesses that fabricate products in different regions of the world have a goal to optimize the procurement processes that support their manufacturing operations. Global procurement contracts are becoming more prevalent as customers with international manufacturing facilities seek to take advantage of scale and to standardize the quality of the products that they place into multi-national markets. This presentation introduces the many factors that need to be considered to ensure that product pricing and facility support services are competitively determined.

This presentation starts with a simple scenario for discussion. The interaction between the supply chain, sales and marketing, and regulatory affairs groups of the lubricant manufacturer are outlined. Questions are raised about the acceptability of lubricant products that address regional issues by offering technically and functionally equivalent product formulations. The discussion delves into the challenges of moving products into countries having different and varying chemical regulatory requirements. Some detailed discussion is provided that addresses Asian and European chemical registrations. Lubricant manufacturers that form integrated teams to prepare global procurement contracts for their customers have a better chance of avoiding unanticipated issues while building their brand and reputation in the international arena.


Daniel E. Sullivan earned a B.S. degree at the University of Maine and a PhD at Vanderbilt University. Dan began his 30 + years in the industry and consulting as an instructor in Chemical Engineering at Vanderbilt. Dan joined Procter & Gamble with research responsibilities for studying the environmental impact of new chemical substances used in detergents and paper products. Dan left to join Weston Consultants to set up and run their environmental fate and effects laboratory and later took a position with the Allied Corporation where he became a senior technical service engineer for their water soluble polymer line. Dan traveled throughout the U.S. supporting the sales force and servicing key accounts that faced regulatory action because of wastewater violations. Dan subsequently took a position with G.D. Searle where he was responsible for developing environmental risk assessments required to support drug registrations in the U.S. and Europe. Dan was promoted into a director role responsible for environmental compliance of global manufacturing plants. In that capacity, Dan was part of a joint USAID and industry team that built a green field pharmaceutical dosage facility in Moscow to manufacture medicines for the Russian market. Through a series of mergers and acquisitions, Dan integrated into Pfizer to lead a global network that supported chemical registrations in the U.S., Europe, and Asia. Dan was an active member in the PhRMA (pharmaceutical) trade association and chaired the work group which evaluated and commented on new global chemical policies and regulations.

After 20 years in the pharmaceutical industry, Dan retired to join a start-up consulting firm helping to develop the U.S. market and support companies looking to sell or manufacture chemical substances in China. Dan simultaneously took a short-term assignment as Program Director of the Product Stewardship & Regulatory Affairs Council of The Conference Board (New York) where he supported vice-presidents and senior directors of 25 leading companies in the area of product stewardship. In a part-time capacity, Dan contributed to online university programs as an adjunct professor teaching and developing environmental courses at Columbia Southern University. In 2011, Dan became the Manager of Global Product Stewardship for Houghton International that produces more than 4,000 products which are sold into 100 + countries around the world. Dan now leads the chemical regulatory affairs team at Houghton as a senior advisor focusing on the Asia-Pacific and North American regulatory environments.

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