Section I: What Are the Global Product Strategy and Global Product Stewardship?
BACKGROUND
In February 2006 in Dubai,
the International Conference on Chemicals Management, meeting
under the auspices of the United Nations, adopted the
Strategic Approach to International
Management (SAICM), a
framework for global chemicals management.
At that meeting, the chemical industry represented by the International
Council of Chemical Associations (ICCA) introduced its innovative Global
Product Strategy (GPS) to address public concerns regarding chemicals in
commerce and to meet evolving national, regional and international chemical
management policy pressures. The product
stewardship activities under GPS and also the Responsible Care®
Global Charter are industry’s global voluntary initiatives that will contribute to SAICM implementation. The GPS is also the program under which ICCA will establish and promote its
Principles for Chemical Management Systems, sponsor “capacity building”
initiatives and establish partnerships with intergovernmental organizations.
GPS also provides a platform for ICCA advocacy and communication.
The centerpiece of GPS is
the enhancement and expansion of product stewardship best practices within the
industry and throughout the value chain.
The effort unites several current stewardship initiatives under the auspices
of the Responsible Care program, builds a foundation for continual improvement
in product stewardship, fosters greater transparency to external stakeholders
and marks a major drive to take product stewardship to a higher level within
the industry.
The ultimate purpose of GPS
is to increase public and stakeholder awareness of, and confidence in, the safe
management of chemicals throughout their lifecycle by demonstrably increasing
chemical industry performance and transparency.
These product stewardship
guidelines were developed to facilitate improvement in industry performance.
They are based on common elements of existing ICCA member association programs
and include principles to be applied to research and development, raw materials
procurement, manufacturing, sales, distribution, handling, use, disposal and
recycling of chemicals. The guidelines
were also designed with enough flexibility to be implemented by small and medium-sized
enterprises (SMEs). These guidelines are
provided to ICCA member associations for use in the development of their own
regional or country-specific product stewardship programs, to be implemented by
their member companies.
The voluntary regional and
country programs based on these guidelines should be designed with enough
flexibility to account for national and regional legal, societal, economic and
cultural conditions. The eventual adoption of product stewardship programs by
ICCA member associations and the implementation of product stewardship programs
by ICCA member companies will demonstrate the global industry’s commitment to the
safe management of chemicals.
WHAT IS PRODUCT STEWARDSHIP?
Product
stewardship is the practice of making health, safety and environmental
protection an integral part of the life cycle of chemicals, as described in
these guidelines. It is an integral component of the global chemical industry’s
Responsible Care® initiative and includes evaluations of risks and
the development of actions to protect human health and the environment
commensurate with those risks.
Product stewardship is a
shared responsibility between chemical producers, their suppliers and their
customers. It requires the development of close, sustained dialogue and working
relationships with suppliers, customers, and others in relevant value chains.
These parties should share information up and down the value chain to ensure
that chemicals are used and managed safely throughout their life-cycle. In doing so, they will also help companies
and their partners meet the increasing demand for safe and
environmentally-sustainable uses of chemicals.
BENEFITS OF PRODUCT STEWARDSHIP
Product stewardship provides the platform for companies to
identify risks at an early stage and manage those risks along the value chain,
thereby enabling adequate protection of human health and the environment. This can result in increased customer loyalty
as well as expand the positive impact of product stewardship down the value
chain.
Evaluation and avoidance of risk reduces the potential for
harm and potential liabilities, making product stewardship a “value added”
business proposition.
Section II: How to Implement Product Stewardship
GETTING STARTED
These guidelines provide a
step-wise approach that can be used to design and implement a company product
stewardship program. They can also be used to perform an analysis of existing
company product stewardship practices, to define or address gaps and
continually improve those practices.
More in-depth information on
implementing product stewardship programs can be obtained from a variety of
resources. See the websites listed in
Section III.
THE FIRST STEP: LEADERSHIP, COMMITMENT AND POLICIES
Strong and effective leadership ensures that product
stewardship objectives are set and prioritized and practices are implemented to
meet performance targets. The link below provides examples of how company
management can demonstrate their
committment to product stewardship
Management is responsible for establishing clear policies
to define the organization’s direction and long-term objectives for product
stewardship. These policies should reflect the organization’s philosophy,
culture and scope of operations. The link below describes various aspects of
company policies that could support product stewardship.
The designation of one or
more management representatives, often designated as “product stewards,” may
also be an early step. These may be part-time people, especially in the case of
SMEs. The intent to make product stewardship one of the core business
activities should be communicated throughout the company.
Team work is crucial for
effective product stewardship program. Dialogue with the wider business
organization and value chain partners should be appropriately encouraged, since
safe handling and environmental considerations need to be included in each step
of the process, from procurement through research and development,
manufacturing, sales and marketing, distribution, storage and disposal.
MOVING TO A SYSTEMATIC APPROACH
A management system approach will aid the company in
establishing and managing its product stewardship activities most efficiently. Experience with management systems across multiple
business sectors demonstrates that this approach provides a systematic and
consistent method for delivering higher levels of product stewardship
performance. There is no single model for a product stewardship
management system;
however, adopting an existing proven system with fine-tuning to the specifics
of the company can be both a productive and efficient way to maximise success
and save valuable time. A good starting point is the Deming Plan-Do-Check-Act
model , which comprises the following elements:
PLAN
A product stewardship plan should be prepared that is commensurate to the size of the company, its business activities and the risks it manages. The company’s product stewardship policy should be translated into objectives, and these in turn into more detailed plans.
In general, planning has three basic
elements:
- Identifying requirements;
- Developing a formal plan and;
- Organizing to implement the plan.
A. Identify Requirements
Initially, it is important to identify
and understand the product stewardship program requirements:
1. Understand significant product-related hazards and risks that
need to be addressed
Central to any product stewardship program is the need for the company to characterize the risk of its chemicals to human health and the environment. Risk characterization is an iterative process that bridges the ‘Plan’ and ‘Do’ phases of a product stewardship management system. For example, a new use for a chemical may require ‘planning’ new exposure studies. The actual conduct of such studies may be addressed in the ‘do’ phase of the process.
A high level of
capability is required in the planning and conduct of a risk characterization
and the development of risk management recommendations. It typically requires
knowledge of the chemical’s composition, an understanding of the hazards of
each component of the chemical, an ability to estimate exposure to those
components, and the expertise to characterize chemical risks.
Risk
characterization should begin when a new chemical is created, in the early
stages of research and development (R&D). As the chemical moves from
R&D to commercialization, typically more hazard and exposure information is
gathered and analyzed in a step-wise or “tiered” process. Risk management recommendations are developed
commensurate with the risks identified. More information on the risk characterization
process is provided in the link below.
2.
Understand
legal or other requirements that apply to the management of the organization’s
chemicals
An additional necessary step is to evaluate the relevant risk assessment or risk management requirements, including:
An additional necessary step is to evaluate the relevant risk assessment or risk management requirements, including:
·
Regulations or other legal obligations;
·
Company standards;
·
Customer requests;
·
Industry or company voluntary commitments.
3.
Understand other influences or issues that may affect
the product stewardship requirements
Finally, a number of other factors could influence
company requirements, such as public pressure that should be identified.
B. Develop a Plan
Set targets by considering identified requirements
and prepare plans to achieve them.
Below are some important elements of a plan:
1. Setting product stewardship goals, targets and objectives
To the extent possible, objectives and
targets should be:
·
Quantifiable with realistic timescales;
·
Agreed upon with those assigned
responsibility to achieve them;
·
Documented and communicated to appropriate
audiences.
2. Performance criteria
In the planning phase, consideration
should be given to the type of information that will need to be collected to
monitor performance or establish performance criteria.
3. Communication
On-going dialogue with relevant stakeholders is an important facet
of Responsible Care®. Good communication strategies can help
demonstrate management commitment, deal with concerns and questions, raise
awareness, provide information and improve motivation. Risk communication is a fundamental element
of product stewardship.
Product stewardship communication and training procedures should be established for employees throughout the organization who need to be aware of the importance of product stewardship requirements and their roles and responsibilities in meeting those requirements. A list of key internal and external audiences should be developed and the type of information applicable to each audience defined. For example, employees who handle chemicals need to be aware of risks and methods to avoid/reduce those risks.
4.
Value Chain Communication
Communication of risk characterization and risk management
information to those in the value chain who will design, buy, handle, sell,
use, store and dispose of chemicals is a fundamental component of product
stewardship. Product stewardship
requires effective two-way communication between chemical producers and
downstream customers to understand and take action to avoid risks. Such
communications can also be responsive to the concerns of other external
stakeholders, including regulators and the interested public. Feedback from downstream customers can
provide critical information on chemical uses and potential routes of exposure.
Producers
of chemicals have the responsibility to provide risk characterization and risk
management information to their customers for the chemicals they produce. Their customers, in turn, have the
responsibility to pass this information to their customers in the value
chain. It is the responsibility of those
downstream customers that formulate or transform the chemicals to assess the
risk of their products and to
determine adequate risk management practices in view of the actual chemical
uses and circumstances they know best.
Each chemical producer should strive to obtain adequate knowledge about
its customers’ products and uses in order to better evaluate potential exposure
scenarios and improve risk management recommendations. If customers do not share information about
their uses (for proprietary reasons) or do not share information on their
downstream customer’s use (perhaps because they have no reasonable way to
determine those uses) this lack of knowledge should be highlighted in the risk
characterization and its impact on risk management measures noted.
C. Organize
The successful implementation of the product stewardship plan
requires the commitment and active participation of everyone in the organization. Key aspects to consider when identifying the
necessary resources to implement product stewardship include responsibilities,
resources and skills, documentation and communication.
1. Structure and Responsibility
The roles, responsibilities, authority and
inter-relationships of key employees to be involved in the implementation of
product stewardship should be defined. This includes individuals that will:
·
Provide
management leadership;
·
Develop
and lead the implementation of the product stewardship program;
·
Define
potential hazards, exposures and risks;
·
Investigate
and record product non-compliances and incidents;
·
Recommend
actions from non-compliances, monitor progress and verify implementation;
·
Act
in emergency situations.
2. Resources and skills
The organization should identify and allocate the appropriate
resources including personnel, financial resources, equipment and technologies
for the management, operation and verification of specific product stewardship
activities.
Companies may target training programs to include staff at all
levels in the organization that will be involved in product stewardship
activities.
3. Documentation
Documentation is an important part of an organized product
stewardship system. It provides the basis for training, consistent implementation,
communication and continual improvement of the product stewardship
program.
DO
A.
Risk Management
Risk
management measures are predominantly implemented at this stage and are
intimately linked to, and flow from, the risk characterization process.
Once
risk characterization has been accomplished, appropriate risk management
measures associated with the type and level of risk can be identified. Risk management should be commensurate with
the characterized risks with the aim of controlling risks associated with the
use of a given chemical.
Where
there are existing risk management practices in place, they should be evaluated
to determine whether or not they are likely to adequately protect human health
and the environment. Additional risk management measures may need to be
considered and implemented.
B.
Risk Communication
Making
information available about chemical risks and risk management measures to
suppliers, customers is an important element of product stewardship. Effective
risk communication provides the necessary information for safe chemical
handling and environmental protection. There are a variety of risk
communication mechanisms available, such as Material Safety Data Sheets and
product labels, training and education, etc.
C.
Public Concern Evaluation
In
addition to risk management measures, if there is public concern about
particular chemicals, a communication strategy may need to be developed or
modified to address perceived risk. In some cases, public concern can be
a significant driver, and a company may wish to expand its risk communication
for certain chemicals beyond the scientific assessments of exposure and hazard
that are typically used to characterize risk.
The approaches to considering public concern will vary according to the
customs, laws and practices in a region.
Increased
transparency regarding chemicals and other relevant product stewardship
information helps build credibility for the company’s product stewardship
program. It further helps build trust
for the entire chemical industry by clearly demonstrating to all that the
industry is knowledgeable about its chemicals and their related risks and implements
appropriate risk management measures.
With
this in mind, an essential element of the Global Product Strategy is that
companies will make relevant product stewardship information available to the
public. Below is a link to examples of how
to make product stewardship information available to the public.
CHECK
A. Internal Monitoring
Monitoring should provide evidence
that the management system requirements are being met, and provide the basis
for defining any action needed to improve product stewardship performance. Of central importance is
assessing the degree to which the company and business policies, objectives and
product stewardship performance targets are being supported by effective
product stewardship systems and programs.
Chemical risk characterization and
related product stewardship communication and risk management efforts are
important starting points for determining what activities are a priority to
cover in a product stewardship monitoring program.
B. Auditing
Conducting audits is another method
for identifying areas for improvement in the product stewardship management
system.
Individuals conducting the audit
should be experienced in product stewardship practices and systems. If they are considered “independent” from the
area being audited, that can improve the rigor of the audit outcomes.
Audit results should be communicated
in such a way that the parties responsible can take appropriate corrective
action. Providing audit results and
reports of subsequent actions taken to company management can improve audit
effectiveness.
ACT
Periodically, the product stewardship system should be
reviewed with company management to obtain support for ongoing implementation
measures. It is also advisable to regularly review the management system to
identify opportunities for continual improvement.
CONTINUAL IMPROVEMENT
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