Management Practices 1 through 3 serve to give direction, provide resources, set priorities, and establish responsibilities within your company that provide an appropriate atmosphere and foundation for successfully implementing product stewardship.
Management Practices 4 and 5 address the need to continually increase the body of knowledge surrounding chemical products in order to improve identification and risk characterization at every stage in a product’s life.
Management Practices 6 through 12 work together to manage risks at every stage of a product’s life. They extend the risk management process beyond traditional boundaries to consider risks beyond the point of sale.
1. Leadership:
The objective of this Management Practice is to set the driving force for the Product Stewardship Code. To this end, senior management must first adopt a policy that reflects the company’s vision of product stewardship. This policy should state clearly how senior management expects product stewardship to be managed within the company.
To be effective, the policy should emphasize that product stewardship, like quality and safety, must be woven into the company’s culture. It should be clear that the commitment is an ongoing, long-term part of the company’s operations and business.
The words of a policy must be reinforced by actions and behaviors that continuously reaffirm the goals senior management has set. Senior management is responsible for conveying throughout the organization its involvement with, and support of, product stewardship — especially to the next level of management and encouraging it to do the same.
2. Accountability and Performance Measurement:
One of the key ways senior management can convey the importance of product stewardship is by establishing it as a priority in business planning and individual performance planning. The objective is to develop a process that will result in continuous improvement through goals that are well-defined, achievable and measurable.
3. Resources:
The commitment of resources, both human and financial, is a critical signal that management can send to show its commitment to product stewardship practices and is a vital component for some implementation activities. The commitment of resources should be consistent with product stewardship implementation plans and sufficient to support continuous improvement.
4. Health, Safety and Environmental Information:
The objective of this Management Practice is to establish a knowledge base of human and environmental hazards and reasonably foreseeable exposures and, once established, to maintain it. Under this practice, companies gather information to support the system that characterizes a product’s risk and, ultimately, the system that develops the methods to manage that risk. All companies should have a process to continuously gather relevant product information and to review existing information to determine if it is accurate, current and complete. Sources of information may include published, unpublished and/or internally generated scientific reports on health, safety and environmental effects and exposures. Generally, the types of information could cover animal or human toxicity, ecotoxicity and chemical and physical properties that affect exposure or the environmental impact.
Information on a product’s handling, use and reasonably foreseeable exposures in research, development, manufacturing, transport, storage, packaging and disposal may be obtained by a number of means. These could include surveys of customers and other product receivers, technical reviews or visits to customers, and/or observations reported by sales and marketing personnel.
5. Product Risk Characterization:
This practice has two objectives. The first is to use the information gathered in Management Practice 4 to develop a thorough understanding of the product’s risk. This characterization may be either quantitative or qualitative. A product may be characterized as a single entity or it may be characterized in a group of products based on similar uses, compositions or physical properties. Product risks may vary with different uses or exposures.
The second objective is to establish a system that triggers re-evaluation. Triggers for re-evaluations might include significant new hazard or exposure data, significant new use or misuse information as it becomes known or a substantial increase in sales volume, suggesting new uses or markets.
6. Risk Management System:
The objective of this Management Practice is to establish a system for identifying and implementing risk-management actions. Risks involved in the production and use of chemicals can be managed and controlled if each company takes the basic information on a product’s risk, characterizes it, and then implements a series of risk management actions. These risk management actions are a result of a conscious weighing of technical, ethical, societal and business issues surrounding a product. Actions taken as a result can range from no action, to providing MSDSs and labels, to product reformulation or repackaging, to removal of the product from a market.
7. Product and Process Design and Improvement:
Designing products and processes (or redesigning existing products and processes) with a system to identify health, safety and environ-mental impacts throughout the product lifecycle is one of the most effective ways of managing the product risks identified in Management Practice 5. One objective of this practice is attainment of the preferred environmental hierarchy: source reduction; reuse; recycling; and disposal. Source reduction includes equipment or technology modifications, process or procedure changes, product reformulation or design, substitution of raw materials, and improvements in housekeeping, maintenance, training or inventory control.
This practice also addresses the need for proper energy and natural resource utilization - important considerations for reducing potential adverse environmental impacts and achieving sustainable development. The health, safety and environmental attributes of the product throughout its entire lifecycle should be addressed at the beginning, and during the concept and design (or redesign) phases. Research and development, manufacturing, distribution, sales and marketing and regulatory personnel should be consulted. Re-evaluation should occur on a periodic basis or whenever changes to the product or process are contemplated.
8. Employee Education and Product Use Feedback:
This practice has two parts. The first is to ensure that all employees who are involved with products have the training and education necessary to understand product (and packaging) hazards, proper use, handling, reuse, recycling and disposal procedures. The second is to help ensure that any new information that may alter the way risk is being managed is factored into the risk characterization process on a timely basis (Management Practice 5).
The training and education of employees should be tailored to specific job functions. For example, marketing and sales personnel are in a unique position to know how customers are using products and must be aware of product hazards, reasonably foreseeable exposures, appropriate uses and proper handling procedures. They should be able to identify product deviations and to recognize adverse health or environmental effects. These personnel should be alert to the comments or perceptions of the customer and the public. It is essential that there be timely feedback of this safety, health or environmental information or concerns into the risk characterization process.
9. Contract Manufacturers:
The objective of this Management Practice is to encourage the use of contract manufacturers who have sound health, safety and environmental practices for the specific operations under contract. Companies are responsible for assessing the capabilities of each contract manufacturer and for supplementing their expertise with enough guidance to foster proper handling (including storage), use and disposal. While companies are committed to working with contract manufacturers to help them improve performance, improvement to meet appropriate health, safety and environment standards should occur within a reasonable time frame.
The level of a company product’s involvement and review will vary according to the degree of product risk. “Working with” may include providing detailed health, safety and environmental product information, providing technical assistance on product handling techniques and waste minimization and management, and possibly visiting the contract manufacturer’s facilities. All contract manufacturers should be subject to periodic performance reviews.
This management practice constitutes an important outreach component of the Product Stewardship Code. The long-term result of implementing this practice, like the other outreach management practices, should be better health, safety and environmental performance.
10. Suppliers:
The objective of this Management Practice is to extend product stewardship practices to suppliers. Where appropriate, health, safety and environmental factors should be an integral part of the procurement process, including product exchange. For some companies, this management practice may mean close cooperation within the purchasing, manufacturing, health and loss prevention functions to determine how the supplier can contribute to a safer environment. Other companies may opt to make these health, safety and environmental considerations part of their supplier quality reviews or to factor them into contractual decisions. Suppliers should describe health, safety and environmental programs and goals. Reviews of suppliers will be commensurate with product risk.
This management practice constitutes an important outreach component of the Product Stewardship Code. The long-term result of implementing this practice should be better health, safety and environmental performance.
11. Distributors:
The objective of this Management Practice is to encourage distributors to establish and implement proper health, safety and environmental practices involving our products. It should be implemented in conjunction with Management Practice 4.6 of the Distribution Code, which focuses on the inbound/outbound and storage aspects of distributor operations. The emphasis in the Product Stewardship Code is on working with distributors to help them achieve an appropriate level of performance on other aspects of their operations, such as recycling, handling, storage, use, disposal, waste minimization and management and the transmittal of information to downstream users. A company may decide to terminate the business relationship with those unwilling to implement corrective actions for achieving the health, safety and environmental objectives of product stewardship. The level of involvement with a distributor will vary according to the product’s risk. That risk should also trigger the frequency of the periodic performance reviews mandated in the Distribution Code. It is recognized that distributors perform a broad range of functions, from repackaging the original product to reformulating it into a new product with new health, safety and environmental characteristics.
Product changes made by the distributor may mean that the information originally supplied with the product no longer applies. In these cases, the distributor needs to issue information that reflects the current health, safety and environment information. Reviews of distributors will be commensurate with product risk.
12. Customers and Other Direct Product Receivers:
The objective of this Management Practice is to encourage customers to establish proper health, safety and environmental practices involving our products. While the emphasis is on providing information to customers, other assistance may be appropriate where the product risk requires it. This management practice recognizes that if those efforts are unsuccessful, a company has a range of actions that it can take. Possible actions include, in the exercise of the company’s independent judgement, not selling a given product to the customer. The level of involvement will vary according to the product’s risk. Activities could include reinforcement of previously provided health, safety and environmental information, additional training, etc. At a minimum, both parties should share any accumulated knowledge that would enhance health, safety and environmental protection. Product changes made by the customer may mean that the information originally supplied with the product no longer applies. In these cases, the customer needs to issue information that reflects the current health, safety and environment information. Reviews of customers will be commensurate with product risk. This Management Practice constitutes an important outreach component of the Product Stewardship Code. The long-term result of implementing this practice should result in improved health, safety and environmental performance.
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