3.3 Fundamental Program Elements for Product Stewardship
In reviewing the abovementioned definitions, common elements and principles do become clear. PS is about the SHE aspects of products throughout their life cycle. PS requires that a company manage its products from their inception to disposal, commonly referred to as “cradle to grave.” When implemented it is designed to make health, safety, and environmental protection an integral part of the design, manufacture, distribution, use, recycle, and disposal of products. As such PS has clear links to occupational hygiene and overall pollution prevention efforts.
So what are the stages or specific activities in the PS concept? They include the following:
Product Design and Development. This stage includes bench‐top research as well as the markets or uses anticipated for the product being developed. Depending on the region of the activity it can include some elements of compliance. More often it requires sound professional judgment on the possible hazards of a product, developing appropriate handling procedures based on the known and suspected hazards of the products being developed and the development of appropriate hazard communication documents when full information on the product may not be available. This stage also requires consideration of possible use conditions as they relate to potential use and exposure scenarios.
Purchasing. Obtaining services and products, feed stocks, and processing supplies should be considered as an important part of the life cycle of a product and included in PS practices. These practices should include assuring you are doing business with companies with good SHE practices, assuring your service providers are doing business in an environmentally sound matter and obtaining appropriate information on the products you buy.
Manufacturing. This is the stage most familiar to occupational hygienists. It is the activity involved in the product manufacturing and handling facilities. This is the stage of PS with many regulatory requirements that benefit PS. It is the stage where classic industrial hygiene is practiced.
Distribution. Once a product leaves the manufacturing location, the direct ability to control the risks of the product begin to decline. This phase in the product life cycle includes transit, in transit storage, packaging/repackaging, and other distribution activities. There are regulatory requirements for transportation of specific defined hazardous materials that define container specifications and some elements of hazard communication, but for complete PS all products need to be considered commensurate with the hazard and risk.
Marketing. This includes the applications and uses that the company intentionally sells to, marketing literature on applications, and the representations made by the marketing personnel. It is important that marketing literature does not conflict with technical literature and is appropriately descriptive of the hazards and handling needs for a product without becoming a substitute for an material safety data sheet (MSDS).
Use Conditions. Being aware of customer uses and commensurate with the hazard of the product, the customers' ability to handle product safely is key to accomplishing good PS goals. Having a formal system in place to respond to customer questions and indications of misuse are also integral to a good risk management program. Considering the feedback you have received in the ongoing development of your hazard communication or handling documents for the customer can result in improved risk management and communication.
3.4 Interdisciplinary/Organizational Issues
Based on the aforementioned elements, it is clear that implementing PS takes a cross‐functional approach and affects many departments or functions in a company. This requires significant effort in a company to maintain an understanding of each function's role and to assure each function is performing the activities needed. Furthermore, the PS function itself can be comprised of several distinct disciplines including Toxicology, Occupational Medicine, Industrial Hygiene, and Regulatory Affairs. If specialists in these fields are not within the PS function of an organization, the different forms of expertise will need to be available, or those doing PS will need to develop a working proficiency in the mentioned areas. This is a challenge Occupational Hygienists are familiar with. It is quite normal for a hygienist to bring together engineering, management, hourly, and union personnel to solve a problem or implement a solution. These skills and experience translate well to working in a PS program.
3.5 Regulatory Foundation for Product Stewardship
There are no specific regulatory requirements for chemical producers or other manufacturers to have PS programs. However, if one can agree to describe the elements of PS as discussed in this chapter, then there are clear regulatory requirements that support individual elements of the concept.
At this time, in the United States Federal statutory authority to control the environmental impacts of products downstream from the manufacturing operations as contrasted to manufacturing locations and operations is limited. SHE regulation has traditionally focused on regulating manufacturing facilities. Transportation regulations apply to the portion of the products in commerce that meet specific Department of Transportation (DOT), or equivalent transportation agencies, hazard classifications. However, some select elements of PS are becoming increasingly evident in regulations, or requirements, involving the life cycle aspects of products. These range in scope from individual chemicals to manufactured articles. There is a new emphasis or focus on human and environmental protection through the regulation of products. As an example the revised Toxic Substances Control Act (TSCA), now known as the Lautenberg Chemical Safety Act (LCSA) is resulting in a broader scope of authority for the US Environmental Protection Act to regulate the commercialization and use of existing chemicals (2).
Much of this regulatory activity is outside of the North American region, best exemplified by registration, evaluation, and authorization of chemicals (REACH) in the EU but it has impact on this region as business is increasingly global in nature. Details on REACH are found later in this chapter.
3.6 Hazard Communication
At the heart of PS is risk management through the communication of hazards and handling recommendations to those handling chemical products throughout the supply chain. Hazard communication regulations exist in the many parts of the world. The fundamental requirement to develop and distribute SDSs for chemical substances and products and to supplement this information with product labeling are relatively mature and understood by many. It should be noted that even this requirement is still relatively new as evidenced by the Hazard Communication and WHIMS programs in the NAFTA region and the EU regulations in continental Europe. These requirements as written have only existed since the mid‐1980s. There are product labeling requirements administered by a range of agencies including the US Environmental Protection Agency (EPA), consumer product safety organizations, and food and drug agencies on a global basis (3).
The landscape and requirements for basic hazard communication have changed as GHS is implemented. GHS is an acronym for The Globally Harmonized System of Classification and Labeling of Chemicals (4). It was first adopted as an International Standard in 2002 and has been undergoing revisions and implementation by countries since that time. The GHS is a system for standardizing and harmonizing the classification and labeling of chemicals. To the extent that countries adopt the GHS into their laws, the regulatory changes would be binding for covered industries. However, “GHS compliant” Safety Data Sheets and labels are becoming a minimum for suppliers from many companies. It is anticipated that ALL existing hazard communication systems will need to be changed in order to apply the GHS. New country regulations will be based on GHS and generally consistent from region to region. The global effort required for this transition including input of product stewards and health professionals such as IHs has been very significant and may stay that way for some time.
Providing detailed hazard information to customers and/or other product handlers, including the general public continues to be a growing business to business requirement. The common elements of PS have expanded this aspect to include a higher