Possible Risk Management Actions To Consider FOR PRODUCT STEWARDSHIP

Possible Risk Management Actions To Consider

Risk management can range from providing hazard and safe handling information via (Material) Safety Data Sheets and labels, to requiring customers to demonstrate the ability to safely receive, store and use the chemical prior to sale. If the customer fails to demonstrate the ability to safely handle the chemical, the supplier should take steps to help the customer improve its practices. Below are some additional risk management options, though many other risk management actions are possible:

A.     Chemicals

1.  Manufacturing specifications.

2.  Product hazard classification.

3.  (Material) Safety Data Sheets.

4.  Classification and packaging labels.

B.   R&D

1.  Sourcing of alternative raw materials.

2.  Changes to product physical form to reduce exposure potential.

C.   Purchasing

1.  Supplier materials contracts.

2.  Switching suppliers.

D.   Manufacturing

1.  Legislation and operating permits.

2.  Engineering controls.

3.  Personal protective equipment.

4.  Maintenance schedules.

E.   Contractors

1.  Toll-manufacturing contracts.

2.  Audits.

F.   Marketing

1.  Voluntary restrictions on applications and uses.

G.   Sales

1.  Customer assistance.

2.  Assessment of customer’s safe handling of chemicals. 

3.  Provision of advice, possibly equipment.

4.  Halt sales.

H.  Distributors

1.  Product stewardship agreements.

2.  Distributor training.

3.  Audits.

I. Recycling and disposal

1.  Feasibility of recycling or reusing used and unused product or packaging.

2.  Labels, safety data sheets and other relevant guidance contain adequate disposal information.

3.  Expertise available to advise on product & packaging disposal.

Examples of Strategies For Making Product Stewardship Information Available To The Public

There are many possible ways this can be accomplished, including:

·         Provide the contact information for a responsible person within the company who would be available to answer questions about the company’s chemicals;

·         Place a summary of the risk characterization on the company website in a format such as a “product profile;”

·         Provide product risk management information on the company website such as  (Material) Safety Data Sheets, and guidance on safe-handling and disposal;

·         Work jointly with others to produce information on a group of chemicals and their uses.

Considerations When Developing An Internal Monitoring Program

·         Compare results to defined perfomance criteria;

·         Describe actions completed or planned to be taken as appropriate;

·         Define responsibility for monitoring and reporting;

·         Establish monitoring frequency;

·         Identify trends through data analysis;

·         Provide inputs to management review;

·         Communicate results key internal and extenal audiences;

·         Seek and utilize customer feedback.  

Parameters of Audits

The frequency and scope of the audits will depend on:

·         Importance of the activity concerned, based on consideration of risk, business, societal, or health or environment impact, etc.; 

·         Historical performance and results of previous audits;

·         Compliance with relevant practices and commitments or standards (e.g., organization auditing policy, customer requirements, ISO quality systems).

Points To Consider Relating To Management Review

The Management Review could comprise at least some of the following elements, though this will depend on company policy.

A.  Discussion topics

1.       Policies, objectives and targets.

2.       Resource allocation.

3.       Program priorities.

4.       Communications.

5.       Organization changes.

6.       Research and development projects.

7.       Procurement, marketing and selling strategies.

8.       Status of action items from monitoring and auditing programs.

B.  Documentation

1.       Reasons for the review.

2.       Decisions taken and criteria used.

3.       Action plans, including completion dates and reporting requirements.

4.       Progress against previous action plans.

C.  Communication

The output of reviews should be communicated to all those who have made an input or are affected by outputs from the review. This includes those who:

1.       Are responsible for action or monitoring performance.

2.       Need to ensure conformance is achieved.

3.       Lead other review or line meetings.