INTRODUCTION
Getting new products into the market in a
cost-efficient manner is important for the fertilizer industry.
Addressing Product Stewardship, to ensure that the fertilizer product
meets the expectations of product quality and nutrient efficiency, can
be handled and used safely without harm to people, property and the
environment, and is as important as looking after the economic,
technical and commercial aspects of product management.
In this guidance, product development includes both the creation of new products and the improvement of existing products.
LEGAL REQUIREMENTS
The responsibilities of management and the workforce
in ensuring that all workplace activities - implicitly including those
associated with product development - are carried out safely, are
defined in national health and safety regulations. If product
development involves supplying samples to third parties, then a number
of further requirements may apply. These relate to the provision of
Safety Data Sheets, to packaging and storage, and to distribution.
Commercial exploitation of new products may not be possible until compliance with a number of legal controls has been achieved. In some cases, legal requirements apply to changes in existing products.
Commercial exploitation of new products may not be possible until compliance with a number of legal controls has been achieved. In some cases, legal requirements apply to changes in existing products.
FERTILIZERS
PRODUCT ASSESSEMENT
In a simplified manner, product development takes place in three phases:
- Phase I - Ideas generation (normally at creation stage)
- Phase II - Feasibility assessment
- Phase III - Commercialisation and/or product change
For
each phase a simple matrix of information should be established. Each
item of information should be assessed, and its effect on the overall
risk - and its manageability - of the product identified.
Confirmation that the product is acceptable should
be made before moving forward to manufacturing, marketing and sales.
Reference is made to the example checklist below.
Specification
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Market
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Use
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Phase I - Ideas generation (normally at creation stage)
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Identity
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New ingredients or components
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Potential regions
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Broad nature of potential use
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Any new chemistry of raw materials, additives, coatings, and in the processing of the materials
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Consider (technically driven)
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Inherent SHE issues in process
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Marketing issues
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Product HSE concerns (current/potential)
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Phase II - Feasibility assessment
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Define
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Composition
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Countries for which approvals are required
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Prime and possible applications
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Develop (driven by product steward or technical)
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Technical and physical properties
Any new data required due to: - new substances (from inventory check) - composition changes (from classification changes/SDS) - new ingredients Core Safety Data Sheet Containment/packaging options Process SHE issues |
Understanding of national inventory/classification/application regulations for ingredients/product
National transport and storage regulations
All regulatory approvals necessary for release of the product on the market
Ability to provide relevant language SDS
Any new data required for national inventory check
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Understanding of customer issues in use and potential for misuse and abuse
Risk assessment in use
Understanding of waste concerns and waste minimization
Handling and use information
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Phase III - Commercialization (and/or product change)
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Define
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Product name and specification
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Countries for sale and those for which approvals needed
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Intended applications and any exclusions
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Complete and integrate into business
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All actions in Phase II (reviewing assumptions)
Establish Safety Data Sheet
All actions within Implement through all stages of the product cycle
Actions required for the Product dossier for documenting the findings of the product development and for submitting documents for regulatory approval
Assessment of Impact on business
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PRODUCT DOSSIER
It is recommended
that the Members of Fertilizers Europe establish a product dossier for
all fertilizer products. A product dossier brings together in one place
all the information that the company holds on a product or on generic
products. It facilitates maintaining and updating the information in a
quality fashion. The dossier forms a useful checklist, ensuring that all
aspects of the lifecycle have been adequately considered.
The typical information to be collected in a product
dossier is shown in the form of headings below. Information will be
held in different parts of the organization and if it is not physically
to be treated in the dossier, then clear signposts needs to be in place
to show how it can be retrieved and examined.
The dossier is not only important to the SHE
function. Business and sales staff need to be familiar with its contents
in order that they can market and supply the company's products
effectively and in a responsible way.
A product dossier can be organized as follows:
Classification, labelling and basic data
This section sets out the basic information,
including backing papers, for the formal hazard assessment of the
product, including its hazard classification and required labelling for
supply and/or transport if appropriate (see also). A record is also kept of the calculations used in the hazard assessment.
The UN Globally Harmonized System of Classification
and Labelling of Chemicals (GHS), Third Revised Edition 2009. ISBN
13-978-92-1-117006-1 Available from the Fertilizers Europe secretariat includes
harmonized criteria for classifying substances and mixtures according
to their health, environmental and physical hazards and harmonized
hazard communication elements, including requirements for labelling and
safety data sheets.
This section also provides the test results from
detonation tests, decomposition tests, oxidation tests, etc. See for
example UN Recommendations on the Transport of Dangerous Goods: Manual
of Tests and Criteria. Fourth revised edition, 2003. ISBN 92-1-139087-7.
Available from the Fertilizers Europe secretariat
Safety Data Sheets
Under this heading are copies of the present and
past Data Sheets for the product. Additionally, if anything in a Data
Sheet is based on non-obvious information, the source of the information
should be recorded (see also).
Specifications and detailed analysis
Manufacturing specifications and product
specifications for marketing and sales are listed in this section,
together with all known impurities.
Uses/applications
Under this heading are recorded all intended uses
and applications for the product. Any particular constraints or controls
on these uses, the procedures/measures to be taken to conform to them,
and the need for customer training, for example, are identified (see also)
Agronomic data and environmental fate
The agronomic benefits of the product should be documented, based on R&D tests, field trials and farmer applications.
Also, the environmental impacts of heavy metal
impurities should be identified along with potential environmental
impacts of unbalanced use of fertilizers (too much or too little). See also
Packaging
A record of the packaging options available, and
what is used at present and why is given under this heading. Any
circumstances for which the current packaging is not suitable should be
stated. Routines for recycling of packaging materials should be
identified. See also
Safety and security precautions
Specific safety and /or security restrictions on the
manufacturing, handling and use of the product should be given,
together with any measures that can be taken to prevent incidents.
Information to distributors, logistics operators and farmers
Specific information to the distributor, logistics
operator and to farmers should be provided, e.g. information leaflets
and training material (see also).
Market
Depending on the nature of the company's operations,
it may be helpful to describe the product markets under this heading,
identifying country, distributors, agents, customers, tonnages etc. This
information will help in deciding what is appropriate in the rest of
the dossier, and it will also enable the product to be marketed in a
responsible fashion.
Relevant regulations
This section outlines any special regulations
relating to the manufacture, distribution, supply or use of the product
not covered above.
Improvement plans
Action plans to further reduce any risk associated with the product at any stage in its life can be summarized in this section.
Review process
This section records any particular measures needed
to keep the dossier contents up-to-date, together with a target date for
a review of the information and assessments which it contains.
In addition, in order to have a new fertilizer
permitted to be designated EC Fertilizer according to Directive
2003/2003/EC, the registration of this product should be proposed to the
EU Commission. Article 32.2 of that Directive makes references to Council
Decision 1999/469/ECof 28 June laying down the procedures for the
exercise of implementing powers conferred on the Commission (articles 5
and 7) OJ L184 17-7-1999 p23. A technical file according to the guidance given in Guide
to the compilation of a technical file on applications to designate
fertilizers EEC fertilizers pursuant to Directive 76/116/EEC. 94/C
138/04 of 20-05-1994 should be submitted. Many of the above mentioned sections are part of this guidance.
The EC2003/2003 fertilizers law is currently under revision.
IMPACT ON BUSINESS
An important part of the Phase III of the product
assessment is to evaluate the SHE impacts on the business. A
structured impact assessment provides a way of prioritizing potential
adverse effects for management attention, and for highlighting SHE
opportunities.
The impact assessment uses the outputs of existing
assessments and also identifies where further detailed and technical
risk assessment might be warranted. It is not a technical risk
assessment in itself. Its output is primarily a prioritized risk and
opportunity list which can be addressed by the business plan.
Companies should rate the potential damage to their
business arising from possible adverse SHE events caused by, or
involving, their products. They should also identify potential
commercial opportunities which could arise from foreseeable SHE
scenarios relevant to their products. Events may occur at any stage in
the product lifecycle, and may be short or long term. By taking account
of the probability of such events occurring, suitable action plans
should be produced that manage and mitigate any risk and that take
advantage of any opportunity.
The impact assessment should combine the
conclusions of technical risk assessments with the risk perception and
value-judgments of users, customers and society, in order to assess the
overall implications for the business.
The impact assessment may be carried out as an
internal business process, involving personnel whose responsibilities
and expertise are relevant. It is best suited as a team activity. The
following steps can serve as guidance:
Step 1. Describe the product range
Identify the product under consideration:
- specification - chemical, physical and packaging
- market - region or countries, industry or public
- use - broad area of use or application
Similarly, identify competing products in the market (own produced, third party products, and competitors' products). Identify the importance to the business of each product by considering volume and profit contribution.
Step 2. Identify threats and opportunities within the product lifecycle
Understand what happens at each stage of the product lifecycle including both within the organization and downstream at contractors and customers. Consider, for example, how the product is stored, handled and used, including the number of people involved and their competence. Identify any occurrence with significant potential for causing damage, harm or benefit, taking into account the product description in Step 1.
Address the business impact of risks to people,
property and the environment - taking into account any technical risk
assessments that have been completed. Address business risks - taking
into account commercial, financial and perceived risks. Carry out a
comparison with the impact of competitors' products and operations, and
also consider the expectations of customers and society.
Identify any positive SHE attributes of your products by comparing the various analyses.
Step 3. Evaluate circumstances and consequences of risk
Rate each occurrence identified in Step 2 according to the magnitude of its impact.
Disastrous
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Loss of business; loss of major part for several years
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Damaging
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Major business image concern; significant sales loss; authority prosecution
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Costly
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Significant business cost; threat to business growth; loss of customer, poor image
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Minor
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Modest business cost; operational concern; action that is not good practice
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Beneficial
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Enhanced business direction; improved business image
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Step 4. Establish potential causes and consider likelihood of event
Decide how likely it is that each event which could
lead to harm or opportunity will arise. Also, consider how likely it
is that, should the event happen, harm or opportunity will actually
occur. It may be difficult to quantify these probabilities - evaluating
them as high, medium or low may be sufficient.
Step 5. Agree suitable action plans
By subjectively combining the severity of different
events established in Step 3 with their probability, as determined in
Step 4, a priority list of events - good and bad - which should be
managed can be produced. The team should address the higher priorities
and develop action plans for these.
Step 6. Review
The assessment will need to be reviewed:
- following any change to the product identity - specification, market or use
- following any change to the activities of the business
- periodically (to ensure change has been recognized)
Additionally, a periodic review of progress in carrying out the action plans is essential to maintain momentum.
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