Saturday 16 June 2012

Global Product Stewardship?



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:
  1. Identifying requirements;
  2. Developing a formal plan and;
  3. 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:
·         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.

D.     Making Relevant Product Stewardship Information Available to the Public 
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

Once the product stewardship program has been designed and implemented, it should be reviewed and enhanced at regular intervals to ensure continual improvement and higher levels of performance over time.  The management system process described on page 6 begins again with PLAN. 

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