Product Stewardship Guidance

Product Stewardship integrates all aspects of a product’s health, safety and environmental management through its lifecycle, taking into account existing and emerging regulatory requirement, societal pressures and best business practices. An integral part of Responsible Care, product stewardship provides a valuable framework to improve on chemicals management.

This guideline has been designed to accommodate the fact that product management tends to be organised along functional lines: manufacturing, distribution, research and development (R&D), sales, marketing and in many cases supported by a regulatory affairs team, providing the details of responsibilities for each role in a company to contribute to a sound product stewardship programme. 

In March 1989, the Chemical Industries Association (CIA) launched its Responsible Care initiative following the successful development of the concept by the Canadian Chemical Producers’ Association (CCPA) and its subsequent adoption by the US Chemical Manufacturers Association (CMA). The concept is spreading worldwide – for example throughout Europe and to Japan, Australia and Brazil.

In February 2006, the International Council of Chemical Associations (ICCA) launched the Global Product Strategy (GPS), an initiative designed to improve chemical management practices around the world. Part of the GPS programme is about enhancing product stewardship programmes across all 54 trade associations’ signatories to Responsible Care including CIA.

In the UK, chief executives of all CIA member companies have signed a commitment to the Responsible Care Guiding Principles for demonstrating performance improvements in, and achieving an acceptably high level of protection for, the health and safety of employees, customers, the public and the environment.

 

The Chemical Industry operates today in a world where people are increasingly aware of the environmental and human health impact of the products we make and use. The industry and its downstream users constantly face regulatory and societal pressures to continuously drive improvements to ensure safe and functional products are delivered to consumers. Product Stewardship provides a valuable framework to improve chemical management as it integrates all aspects of a product’s health, safety and environmental management taking into account regulatory requirement, societal pressures and existing best business practices. When considering product management, it is vital to think of what happens to the product throughout its life cycle, from the moment of invention until it has ultimately been used and disposed of, or potentially recycled, so that no aspect of management is neglected. It focuses on what happens to the product irrespective of ownership or organisational responsibility. Hence, Product Stewardship is seen as a vital component of Responsible Care.

An effective Product Stewardship process maximises the care a producer can exercise towards all his customers in the total supply chain (including customer’s customers and others who may be aff ected) through to ultimate use and disposal or possible re-entry into the lifecycle through recycling. As such, it adds value to the product by simultaneously increasing its attractiveness; reducing the risk of harm both to human health and to the environment; reducing the risk of marketing a defective product and, in consequence, reducing potential liabilities. Additional investment early in the product’s life cycle to prevent, minimise or protect against HS&E problems in the long-term will reduce the need for greater expenditure to correct or mitigate such problems later.

“Product stewardship and eff ective application of product life cycle management approaches play an importance role in Johnson Matthey’s overall company sustainability strategy and commitment to Responsible Care. Through continued eff orts to raise standards in product stewardship across the supply chain, including communication of relevant safety information, industry will continue to demonstrate, and further enhance confi dence in, its safe management of chemicals throughout their life cycle.” Nissanka Rajapakse, Group Product Stewardship Manager, Johnson Matthey

“Product Stewardship is important for all companies. As an SME this is a major challenge for us but one we must face to ensure we continue to raise our standards, take responsibility for our products and guarantee a future place in our chosen markets.” Harry Swan, Managing Director, Thomas Swan

Value to business

The purpose of a company’s Product Stewardship is to reduce product risks. This is achieved by continuous improvement in all aspects of HS&E performance of each product throughout its life cycle, resulting in a continuous minimisation of risks to people and the environment. The benefits for companies include an increase in product value ensuring regulatory compliance, a reduction in product and business risks and a reduced probability in marketing defective products and related potential liabilities.

Financial benefits

With manufacturing costs on the rise, embracing such a strategy provide companies with some control over increasing insurance premiums. Without a doubt, it is in the insurance company’s interests to determine the fi nancial risk they are taking. Maintaining product stewardship practices demonstrates to insurance companies the organisations eff ort to ensure its products are safely handled and only supplied for suitable applications, reducing its potential liabilities. Other financial benefi ts off ered by PS can include reduced waste management costs, reduced audit costs as a result of less prominent follow-up actions being recommended and better investment opportunities with many banks making commitments to the environment.

Best in class

There are also a number of benefits for a customer purchasing from a company with a good product management record. Suppliers who are able to offer information and support on SHE issues are not only adding value to their product package but are reducing any associated risks throughout the product’s life cycle, avoiding consequential costs and reputation damage. Many customers are now keen to be associated with prestigious suppliers as part of their own reputation agenda. Inevitably, a Product Stewardship programme that is well perceived by the customer will enable the sales force to improve their contacts within industry opening doors to new potential commercial opportunities. Furthermore, customers are increasingly ranking their suppliers based on supplier systems such as ISO 9000, ISO 14,000 and Product Stewardship. Good Product Stewardship made known to and appreciated by a customer is just another reason that diff erentiates a supplier from the ‘rest’ – providing that much needed competitive advantage for businesses and encouraging customer loyalty.

“As part of our commitment to product stewardship, we implemented a pollution management programme in order to minimise the impact we have on the environment. The launch of VECAP (Voluntary Emissions Control Action Programme) brought us much closer to our customers, particularly in terms of product handling and waste management practices and we gladly recommend setting up similar voluntary programmes to chemical companies.” K Kannah, Manager, European Advocacy, Chemtura

1. Design, develop or modify products both to meet customer needs and minimise HS&E impacts throughout the value chain, taking into account resource use and waste minimisation throughout a product lifecycle
2. Ensure all product changes likely to affect the original HS&E assessment of the product are reviewed.
3. Provide information to and work with customers to foster safe storage, use, handling and disposal of products. Seek feedback on customer use and misuse of products.
4. Ensure customer facing workforce has clear understanding and communicates information of product safety, related legislation as well as product benefit.
5. Ensure raw materials are responsibly sourced from suppliers who have embraced good HS&E standards and where appropriate, include these considerations in purchasing policies.
6. Provide education and training for employees, based on their job function, on the safe storage, handling, use and disposal of products.
7. Select and work with contract manufacturers and contract distributors to meet appropriate HS&E standards.
8. Be open and communicative with employees, the supply chain and external stakeholders, anticipating and responding to their concerns about the potential hazards and impacts of the products.
9. Businesses with international interests should apply these principles worldwide and ethically comply with all HS&E legislation, codes of practice and guidelines; they are also encouraged to participate proactively in the development of local laws and regulations in all countries in which the company has significant resources.
   
10. Businesses with international interests should apply these principles worldwide and ethically comply with all HS&E legislation, codes of practice and guidelines; they are also encouraged to participate proactively in the development of local laws and regulations in all countries in which the company has significant resources.

The first principle of Product Stewardship requires the senior management of a company to:

‘Demonstrate that the management of product HS&E issues ranks amongst the highest corporate priorities and maintain commitment to continuous improvement’.

Without this demonstrable commitment, which is in any case implicit in the Guiding Principles of Responsible Care, there can neither be success in achieving excellence against the other Principles of Product Stewardship, nor credibility for Product Stewardship in the eyes of employees, customers and the public. This chapter deals with functional responsibilities for implementing Product Stewardship throughout the lifecycle of a product.

The following management functions are considered:

• Senior management • Research & development
• Purchasing
• Manufacturing
• Customer services, marketing and sales
• Distribution of products
• Regulatory affairs
• Waste disposal and recovery

Key Responsibilities for Senior Management

This section deals with the overall corporate and line management responsibilities for integrating all aspects of Product Stewardship.

• Establish and communicate a written Product Stewardship vision and actively lead its implementation through meaningful objectives/aims including the provision of adequate resources.
• Define the line management responsibility and instigate management systems for the effective implementation of Product Stewardship. Allocate individual responsibility for all aspects of Product Stewardship.
• Establish goals for the continuous improvement of performance in relation to Product Stewardship and measure actual performance against these goals.
• Product stewardship should be an integral part of the culture of the workplace and included as an element of performance appraisal of both management and employees.
• Ensure that the necessary communication, education and training procedures required to maintain the concept are in place for all functions.
• Ensure conformance with all the Principles of Product Stewardship (see page 4) and ensure that systems are maintained, regularly reviewed and audited in a manner consistent with these guidelines. Seek third party certification to an independent standard, e.g. the ISO 9000 series or other appropriate standard.
• Develop and maintain the business public relations response on product HS&E issues and, where appropriate, participate positively in the development of public opinion, the influencing of relevant legislation and the development of the industry’s position.
• Establish an overall measurement of progress against the guidance given in this document. The focus should be on continuous improvement from year to year, rather than on absolute measures.

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Guidance Content