Stewardship 2016: A Look Back

Stewardship
INNER HARBOR BALTIMORE + MAY 23–25
# ST E WA R D S H I P 1 6 • P R O D U C TST E WA R D S CO N F E R E N C E .O R G
2016
A LOOK BACK
A LOOK BACK AT STEWARDSHIP 2016
Stewardship 2016 brought together hundreds of professionals from
over a dozen different industry sectors and throughout the value chain.
A record number of attendees convened in Inner Harbor, Baltimore
to talk about the challenges specific to their profession, including
operations, regulatory compliance and how product stewardship
programs contribute to business value.
I
n addition to networking with each other, product stewards
also attended the conference to hear from key business leaders,
including ExxonMobil VP Elissa Sterry, who outlined five areas
where product stewards in any organization can positively
affect the business.
Many sessions dealt with how products stewards can go beyond
compliance and impact the organization’s bottom line. Attendees
heard about a framework for measuring product stewardship
activities. They also heard about specific methods for finding and
gathering the right data to drive product stewardship objectives.
Product stewards also deal with emerging regulatory and compliance issues, so the conference included sessions addressing
these topics. Attendees learned the latest about stewardship and
www.ProductStewards.org
compliance for nanomaterials from a panel that included attorney
Lynn Bergeson. OSHA representative Maureen Ruskin talked with
attendees about the agency’s latest guidance and future regulatory agenda. At the same time, Health Canada representative
Amira Sultan briefed attendees on the country’s progress toward
GHS implementation.
Employing the best talent is key to a strong product stewardship
program. Several sessions addressed the challenge of recruiting,
developing and managing talent. Attendees heard about how 3M
grooms its next generation of product stewards. They also heard
from representatives from the PSRA, Johnson & Johnson and BASF
with advice on how to identify and manage product stewards.
1
CONTENTS
ExxonMobil VP Elissa Sterry Praises Product Stewardship . . . . . . . . . . . . . . . . . . . . 3
Use Data to Drive Product Stewardship Objectives . . . . . . . . . . . . . . . . . . . . . . . . . 5
No Data, No Market: Start Your REACH Registration Now . . . . . . . . . . . . . . . . . . . . .8
OSHA Rep Updates Product Stewards on GHS and Beyond . . . . . . . . . . . . . . . . . . . . 9
Canada Moves Closer to GHS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10
How Product Stewards at HP and Shell Report Key Metrics . . . . . . . . . . . . . . . . . . . 11
Integrating Product Stewardship at Abbott Vascular . . . . . . . . . . . . . . . . . . . . . . . . 13
Attracting the Next Generation of Product Stewards . . . . . . . . . . . . . . . . . . . . . . . 14
Experts Talk About Alternatives Assessment . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15
Nanomaterials: Information for Product Stewards . . . . . . . . . . . . . . . . . . . . . . . . . 18
Methods for Dealing with Regulatory Nuance . . . . . . . . . . . . . . . . . . . . . . . . . . . 19
Green Chemistry: A Case Study in Transparency . . . . . . . . . . . . . . . . . . . . . . . . . . 20
We Ensure Market Access: The Business Value of Product Stewardship . . . . . . . . . . . . 21
Product Stewardship Talent Management at J&J and BASF . . . . . . . . . . . . . . . . . . 22
EXXONMOBIL VP ELISSA STERRY
PRAISES PRODUCT STEWARDSHIP
ExxonMobil’s mission is to expand energy supplies, deliver energy where
it’s needed and unlock new sources of energy, said Elissa Sterry, global
intermediates vice president. Product stewardship plays an integral role
in fulfilling that mission.
D
uring a keynote address at Stewardship 2016, Sterry told
attendees that product stewards at ExxonMobil are part
of a group that’s often on the leading edge of developing
new methods of assessing product risk. Although it’s a technical
profession, good product stewards are also great communicators
and have inherent leadership skills.
Sterry outlined five areas where product stewards in any organization can positively affect the business. “I would like to encourage you to test your own participation in each of the five areas,”
she said. “I encourage you to think about getting involved in those
areas where you aren’t involved but you have an interest.”
Product Safety
Companies are responsible for making sure the products they sell
are safe for intended use. To sell products with confidence requires
testing and analysis. Sterry’s team works with toxicologists, and
the product stewardship team is responsible for communicating
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the results with executives. Because the assessments can be complex, they require a unique skill
set that product stewards bring.
Compliance
Sterry noted that compliance activities span
a range of activities, from material selection
to recordkeeping. It also involves tracking
regulatory changes around the world.
Regulatory Engagement
Product stewards are uniquely qualified to engage
in the development of regulations, something that industry doesn’t participate in as often as it should. Product stewards
know from experience where existing legislation is lacking.
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For example, when REACH was first being implemented,
ExxonMobil actively provided guidance to meet the intent of the
law efficiently. Solvents had been identified by the feedstock used
to produce them – an outdated system, said Sterry. As a result, her
team developed a new, simple naming convention to differentiate
fuels from high-performing fluid. The system better informs producers and customers about the composition of products they’re
buying. Ultimately, the OECD recommended that the naming convention be used for future regulations.
New Product Development
Product stewards can also provide great value in new product development. In Sterry’s group, product stewardship is integrated in the
process. Doing so helps anticipate regulations and consumer concerns. In one instance, Sterry’s team recognized consumer concern
over oil and gas drilling, so they developed drilling fluids for fracking operations that don’t require Aquatic Hazard labels under GHS.
Advocacy
Sometimes misinformation is a bigger challenge than regulations,
she said. Product stewards help their companies by demystifying
science and helping consumers make good choices. Risks can be
potentially much higher if well-tested chemicals are replaced with
less well-tested chemicals, for instance.
Sterry said that customers will
gravitate to suppliers who have
a strong grasp of the regulatory
environment. Increasingly she
asks her product stewards to
engage with the supply chain to
explain the difference between
hazards and true risk.
Sterry said that customers will gravitate to suppliers who have a
strong grasp of the regulatory environment. Increasingly she asks
her product stewards to engage with the supply chain to explain
the difference between hazards and true risk.
www.ProductStewards.org
4
USE DATA TO DRIVE PRODUCT
STEWARDSHIP OBJECTIVES
Product stewardship helps ‘future-proof’ a company’s portfolio, but only if it
anticipates customer requirements. That means building customer insights
around environmental attributes that could turn into strong drivers.
B
ecause marketing departments and R&D focus on product
performance, product stewards need data to show that
environmental leadership also matters. John Ortiz, director
of product stewardship at HP, offered strategies for gathering the
right data.
The government, NGOs, competitors and customers are all sources
of data. For example, as more companies incorporate sustainability
initiatives, they issue corporate sustainability reports. These are
sources of information about what they’re doing in the marketplace. Safety data sheets and annual reports are also sources of
competitor data.
Eco-labels are another source of competitive analysis. If your competitors tout a certification, you can relay that back to senior management. “If you’re competitors are doing it, nobody really likes to
be behind,” said Ortiz.
Eco-labels also foreshadow future market access requirements.
Take the individual performance attributes necessary to achieve
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the eco-label and compare how well you match to competitors. If
regulators propose a rule around the attribute, competitors won’t
argue with it and you’ll be behind. Showing design teams how far
you are behind can influence changes, said Ortiz.
Internal Data
Companies can also generate data internally.
For example, a team at HP gathers every
customer inquiry about environmental
attributes, whether it’s a consumer phoning the call center or an enterprise prospect whose RFP requests additional
information. The team responds to the
inquiries but also tracks and categorizes
the requests “Most of you have some mechanism for receiving customer inquiries, but
actually tracking and parsing the data — how
many do you get, etc. — is trickier,” said Ortiz.
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Insights from this data are folded into future product design. For
example, the team received many inquiries about air emissions, so
the company created documents to address the inquiries and made
them available.
Likewise, if an RFQ worth millions of dollars specifies certain
requirements, product stewards will use that data to influence
the design team. In packaging, for instance, the customer may not
want polystyrene foam. “We might have to eat the cost to do a
paper-based alternative, but now here’s the dollar value that could
be lost, and showing that is powerful,” said Ortiz.
He recommends incorporating a bid and tender tracker that shows
revenue wins and losses. When you show the amount of dollars
tied to an attribute, like packaging with paper instead of foam,
“that’s extremely powerful stuff,” he said.
What Works and What Doesn’t
Ortiz also shared some practical advice for achieving buy-in from
executives. He reiterated that speaking about compliance doesn’t
affect change. When talking about possible regulations, for
instance, executives want to know the likelihood they’ll be enacted,
which can be hard for product stewards to quantify. Likewise,
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conversations about lifecycle analysis and carbon footprints have
less impact on design teams than data about competitor products.
Finally, environmental data is not a real driver in many customer
focus groups, but if you look to leading-edge customers and
extreme users, they will point in a direction you can show to marketing departments.
When you show the amount of
dollars tied to an attribute, like
packaging with paper instead of
foam, “that’s extremely powerful
stuff,” [Oritz] said.
6
WHY DID YOU ATTEND?
HERE’S WHAT SOME ATTENDEES HAD TO
SAY ABOUT WHY THEY ATTENDED THIS
YEAR’S STEWARDSHIP CONFERENCE:
TIM BOTTS
DIRECTOR OF REGULATORY AFFAIRS
ECOLAB
This was my first time attending Stewardship. My primary reason
for attending was to benchmark what my team is doing compared
to others. One session talked about preparing the next generation of
product stewards. We have a lot of folks that fall into the millennial
generation. We’re doing many of the things the speaker mentioned
but a few that we aren’t that I plan to try.
I was also able to build my product stewardship network. It was
encouraging to learn there are others dealing with stewardship
issues like me and they’re open to willingly share best practices. I
don’t know where else you could go and be this immersed in stewardship. If you do stewardship as your job, you have to be here.
www.ProductStewards.org
“I DON’T KNOW WHERE ELSE YOU
COULD GO AND BE THIS IMMERSED
IN STEWARDSHIP. IF YOU DO
STEWARDSHIP AS YOUR JOB, YOU
HAVE TO BE HERE.”
7
NO DATA, NO MARKET: START YOUR
REACH REGISTRATION NOW
F
or many companies, registering chemicals before the REACH
deadline will not be an easy process, given the technical,
legal and financial considerations. Additionally, a larger
number of registrants and an increase in the number of specialty
chemicals registered will present challenges. “For a large portfolio
you need a lot of time. That’s why you need to start now with your
activities,” said Sandra Meijer, director of business development
at The REACH Centre.
The deadline is May 31, 2018. It can take up to 30 weeks to complete a registration, even if everything goes smoothly. “There’s only
a certain number of labs who can do some of these tests,” said
Meijer, and some are already at capacity.
Technical Considerations
mechanism. Meijer also cautioned attendees not
to run afoul of EU competition law. She referenced
a list of Dos and Don’ts available at www.cefic.org.
Financial Considerations
Registration costs include the data sharing and ECHA fees. There
can be ongoing cost and unforeseen costs as well. Depending on
the testing required, the costs add up, especially if you are the only
registrant. Ultimately whether to register or not is a business decision. If chemicals in your inventory haven’t been registered yet, you
may need to take the lead and incur a large upfront cost. If the
costs outweigh the benefits of being in the market, some companies may reduce their exports to less than one tonne or replace the
substance with something else.
Data gathering is a huge part of REACH. Competitors are expected
to collaborate to develop one hazard data set for the chemicals.
Though some hazard data may be compiled already, there are
always gaps, said Meijer. You can potentially fill those gaps with
read-across, waiving arguments and QSAR. If confidentiality is an
issue, you can submit your uses separately from the lead dossier,
but then you have to conduct your own safety assessment.
The Wider Impact of REACH
Legal Considerations
Also, ECHA uses the data it gathers to see which chemicals need
better controls. The agency may check the dossier to ensure that
it’s scientifically sound. It may conduct an evaluation if it’s concerned about the substance, or it can ask registrants for more information. Depending on the results, ECHA could restrict a chemical,
impose a ban or propose a reclassification, which could lead to
other impacts. “Know your substances. Communicate with your
fellow registrants in your supply chain,” Meijer advised.
Every Substance Information Exchange Forum (SIEF), should have an
agreement outlining how you’ll work together. It should express the
obligations for each member and how you’ll share costs. It should
also address potential refund mechanisms, in case more companies
join the registration than anticipated. An ECHA regulation now stipulates that the agreement address whether or not there’s a refund
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“REACH registration is only the start of the process,” said Meijer.
Registrants must update dossiers when new hazard data or new
uses become available (if new members join, for example). Similarly,
updates are required if your company changes names or size as a
result of M&A activity.
8
OSHA REP UPDATES PRODUCT STEWARDS
ON GHS AND BEYOND
C
ompanies should be in compliance with GHS labeling
requirements by now. That said, OSHA continues to issue
guidance. Maureen Ruskin, office director, office of chemical
hazards at OSHA, talked about that guidance and shared updates
on the agency’s regulatory agenda.
Hazard Classification Guidance
Ruskin reminded attendees that they should be labeling their containers with updated pictograms and including updated safety
data sheets. There is some discretion for companies working
through existing stock with old labels. By June 1, 2017, companies
should have worked through all existing stock and only be using
updated labels.
OSHA published Hazard Classification
Guidance to address how companies would
make a hazard classification in general
terms, how to identify chemicals with CAS
numbers, where to look for data and more.
The publication also addresses physical and
health hazards and provides guidance along
with the classification criteria. Each chapter
covers a different hazard class, with criteria for the
substance and a discussion on the criteria for mixtures.
Highlighted Issues
Guidance for the Weight of Evidence
Ruskin talked about enforcement activity in the past couple years.
Companies that triggered violations around hazard communications were mostly related to requirements that haven’t changed —
if they didn’t have a written employee training program or updated
safety data sheets, for instance.
OSHA also published Guidance for the Weight of Evidence. This document, in its comment period at the time, explains HCS’ weight of
evidence analysis requirements. “We have kept it strictly to how you
can apply this to the hazard communication standard,” said Ruskin.
The document addresses how to use authoritative evaluations.
Another issue is the amount of information required on labels. In
some cases, packaging is too small to include all the information.
OSHA has looked to examples from the UN and issued letters of
interpretation for what’s allowed when there’s not enough room.
Ruskin pointed out that the signal word and the pictograms must
go together, but the rest the information can be on a different part
of the label, which provides companies with some flexibility.
To summarize, evaluations are given greater weight for studies that
are in humans or that can be readily translated to humans. Also
they look for animal studies and how they were conducted along
with the statistical power of the results. You might also have to do
a conflict resolution if some studies are positive and some negative.
www.ProductStewards.org
The publication will likely be updated in the summer, with final
publication in the fall.
9
CANADA MOVES CLOSER TO GHS
Canada continues its progress toward GHS implementation. Amira
Sultan, senior regulatory & risk management supervisor, Workplace
Hazardous Materials Bureau at Health Canada, talked about the
implementation’s current status.
I
n general, Health Canada is taking an approach similar to
OSHA. It will release guidance documents and adjust them as
needed. The agency is currently working on technical guidance
to help manufacturers and importers to comply. The guidance
document is targeted for release this year.
The U.S. and Canada have a process for working out differences
in their requirements. The Regulatory Cooperation Council (RCC)
strives to implement a collaborative relationship to implement
GHS. The RCC meets with an understanding that both countries’
regulatory processes will be respected and worker safety will not
be reduced. “With implementation of the GHS in place in both countries, the workplace hazard communication regulations in Canada
and the U.S. are now aligned,” said Sultan.
Deadline and FAQs
After May 31, 2017, manufacturers and importers are required to
use the WHMIS 2015 label. Distributors and employers have more
time to comply.
Sultan reviewed some frequently asked questions the agency
receives. In response to whether the initial supplier identifier must
be identified, the answer is yes. An exception is that if the importer
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is using the chemical in its own workplace, it can leave the foreign
supplier on the data sheet.
In response to a question about whether suppliers can email a link
to an SDS, the answer is no. You must send a hard copy or an electronic document directly. In other words, you could send an email
with the SDS attached electronically, with the English and French
versions separate. You could also send a USB drive or CD. However,
you cannot provide the purchaser with a link where they have to
download it.
“With implementation of the GHS in
place in both countries, the workplace
hazard communication regulations in
Canada and the U.S. are now aligned,”
said Sultan.
10
HOW PRODUCT STEWARDS AT HP
AND SHELL REPORT KEY METRICS
Metrics are key to communicating the business value of product
stewardship, but knowing what to measure has been an ongoing challenge.
Much of the work that product stewards do is intangible or difficult to
accurately quantify. For example, how do you quantify the economic impact
of completing a regulatory submission faster than expected? Likewise, the
diversity of businesses and geographic locations makes it difficult to
establish cross-cutting metrics.
S
o how should product stewardship programs move forward?
Members of the Product Stewardship and Regulatory Affairs
Council (PRSA) proposed some answers to that question in
a recent report. Measuring the Performance and Business Value
of Product Stewardship outlines an overall approach to metrics
program design and describes a broad menu of potential measures
in two areas: core stewardship work and “business value” work.
PRSA Program Director Rob Shimp gave an overview of the report
and some suggestions for implementation. The first step is to be
clear about your purpose of capturing data. Is it to improve the performance of the organization? To ensure you have the right people
in the right jobs? Is it to quantify how product stewardship contributes to the growth of the business? Or to aggregate the overall
health of the organization? “A good metrics program can be any
one of these or all of these,” said Shimp. The key is to specify what
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you want to accomplish. “Otherwise you
can choose any one of the thousand things
to measure, but they may not be fit for the
purpose,” he said.
How HP Does It
Kathy Brewer, senior program manager at
HP, explained that gathering data wasn’t the
problem. “We don’t lack for metrics,” she said.
But HP’s chief supply chain officer wanted those
metrics rolled up into a single metric that would indicate
how the function was performing.
Initially, Brewer’s team considered creating a weighted index, but
she wasn’t sure that the final number would mean anything. A peer
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reminded her that metrics are meant to trigger conversations and
actions. If one performance area is doing well, but another is a red
flag, a weighted average might hide that fact. Instead, he recommended using dashboards, and reporting the metrics that needed
attention. “If everything’s good, you don’t need the conversation. If
something is not going the way you want, trigger the conversation.
That’s what we started looking at,” said Brewer.
For their top level dashboard work, Brewer and team focused on
lost and delayed revenue. They set dollar thresholds corresponding
to green, yellow or red to reflect if products were delayed getting
into a country, for example.
Another metric is related to the company’s takeback operations.
Brewer reports on the program’s financial standing. They also report
on response rates to requests and inquiries that come in for customers from sales. The goal is to respond to those inquiries on-time.
instance, the length of time it takes to issue an SDS is an indicator
tied to operational excellence. The company uses a dashboard to
visualize its performance.
Another objective is to ‘master regulatory complexity.’ Visually, this
metric is conceived as a tank that fills up. You set a target for number of ‘regulatory wins’ in a year and employees report on them. A
‘win’ isn’t too strictly defined, said Andrews. It could be for completing a regulatory submission sooner than expected, for example.
The point is that if you set a target — say 20 per year — and you
only have three at the 3rd quarter, then you might not be focused
enough on the goal, and it triggers a conversation.
Andrews also noted that the group’s dashboard includes comment
fields. When reporting the data, the comments fields also help start
conversations when necessary.
How Shell Does It
Jason Andrews, product steward at Shell LP, said metrics help the
company’s business leaders have a sense of the group’s overall
health. The data is designed for internal stakeholders to make decisions, rather than as a benchmarking exercises.
The metrics are tied to specific company goals, including financial
performance, operational excellence and others. The group looks
at key performance indicators aligned with those objectives. For
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The data is designed for internal
stakeholders to make decisions,
rather than as a benchmarking
exercises.
12
INTEGRATING PRODUCT STEWARDSHIP
AT ABBOTT VASCULAR
P
roduct stewardship is not a standalone function. It works
best when it’s integrated throughout the company. Kathleen
Hall, group leader at Abbott Vascular, talked about the
division’s trajectory toward an integrated program.
The product stewardship program at Abbott Vascular includes six
pillars: product parts and packaging evaluation, chemical evaluation, conflict minerals, supplier communications, emerging issues,
and extended producer responsibility (EPR).
As part of the design control process, R&D submits a list of materials it wants to use. When there are changes to existing products,
they’re routed through product stewardship so the group can determine whether the materials are part of their restricted substances
list. “We closed that loop for new products as well as existing products,” said Hall.
The product stewardship group categorizes substances in three
groups: critical use only, discouraged and vulnerable. Substances in
the first category undergo a risk assessment. Chemicals that are considered vulnerable are on candidate lists or targets of NGO advocacy.
They’re either designed out or watched carefully. They may undergo
a risk evaluation to determine the long-term defensibility, the value
of use versus the cost of future reformulation and so on. Also important is whether replacing the substance will cause a performance
issue. After the evaluation is completed, you determine whether to
reformulate and move away from the chemical or continue to use it.
Gathering Composition Data
Hall said it’s a challenge to obtain 100 percent material composition
data from suppliers, which affects the risk evaluation. They’ve begun
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including the request in agreements so suppliers know it’s a requirement to do business with them. They’ve also signed NDAs in cases
where 100 percent composition data was absolutely necessary. “It’s
not the least expensive option, but it’s an option nonetheless,” said
Hall. The company will also test materials, especially in new product
development, to determine chemical exposure in their products.
Tools Keep It Together
A different challenge is the growing number of regulations and chemicals of concern. For medical devices specifically, Hall said it can be
confusing to know which regulations and chemicals to worry about.
To work it out, the company hired a consultant to list all applicable
regulations, along with the relevant chemicals and their restrictions.
The list is formatted as a color-coded spreadsheet that indicates the
risk level, with categories like “concern,” “trending towards restriction” and “restriction.” Listings of chemicals are sortable by geography, regulatory listing, and hazard and restriction risk. The tool also
links to the relevant regulations. Another benefit is that the tool is
accessible to stakeholders who don’t work in product stewardship.
They can look up a chemical and get the information directly without necessarily having to contact the product stewards.
A new system also makes tracking material information more efficient. Different departments organized the information differently at
their local level. Now the company integrates the corporate database
so that users can see if materials are being used in a different product
already. “It was important for us to be able to pull information that we
already know,” said Hall, instead of having to go back to suppliers.
13
ATTRACTING THE NEXT GENERATION
OF PRODUCT STEWARDS
P
roduct stewards come from varied backgrounds. So how do
companies effectively recruit and retain talent in the field?
3M has a robust program designed to cultivate product
stewards and make sure they have the necessary skills to be
successful in their careers.
Abbey Dahlgren, advanced regulatory affairs analyst at 3M, shared
her story with Stewardship 2016 attendees. After graduating with
a chemistry degree, Dahlgren worked as a product stewardship
contractor with 3M and was eventually hired full-time. She currently works in the abrasives division.
The development philosophy at 3M is that employees are responsible for their careers, said Dahlgren. But there are multiple ways to
advance your knowledge and skills.
On-the-Job-Training
The majority of professional development comes from learning
on-the-job while partnering and working with colleagues. At 3M,
this is realized in opportunities to join projects with international
teams, volunteering to lead a project or shadowing coworkers —
sales people on the product lines you work with, for instance.
The Global Product
Stewardship Forum
At 3M, Tech Forums are an internal program
meant to bring employees with mutual interests together to discuss important issues and
learn from one another. There are currently 41
self-assembled ‘grass-roots’ chapters, including nanotechnology, global product stewardship and so on. The Global Product Stewardship
forum has a mission to create EHS&R leadership through training, development and networking,
Dahlgren said. The forum meets monthly onsite and online.
The Tech Forum also has 12 leadership committees that are centralized around one large event per year, which provides employees with the opportunity to interact with non-EHS employees and
leadership.
Another outlet to groom potential products stewards is the company’s New Technical Employee Orientation (NTEO). Dahlgren
attended the NTEO and noticed they didn’t talk about EHS. She
joined the committee and added EHS to the NTEO agenda, so now
new employees are exposed to the group early on.
Formal Learning
There are opportunities for self-study through e-learning, as well as
attending industry conferences.
www.ProductStewards.org
14
EXPERTS TALK ABOUT
ALTERNATIVES ASSESSMENT
Alternative assessment tools are meant to evaluate the health and
environmental safety aspects of chemicals, but they vary in their
conclusions. The American Chemistry Council evaluated several
tools to see how they differed when comparing the same
chemicals, and to understand why they didn’t come to the
same conclusions.
T
he demonstration study involved seven chemicals with
wide-ranging properties. They were subjected to the
assessments for each tool following the same protocols that
a contractor using a tool would follow.
After converting the scores so they’d be comparable across tools,
the ACC found that for some chemicals the conclusions varied significantly. For instance, caffeine rated from ‘low’ to ‘very
high.’ “How is that helpful to us,” said Ann Mason, senior director, Chemical Products & Technology Division at the American
Chemistry Council.
ACC found that the data-driven tools were more harmonious in
their conclusions than list-based tools, perhaps because datadriven tools have more end points. Another issue was the way
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tools handled data gaps. For some, gaps were
treated as neutral and others treated them as
contributing negatively to the overall score.
The marketplace is focused on safety and hazard
information, said Mason, but ultimately it needs to
push for more complete evaluations, including exposure
and lifecycle assessments.
Lifecycle Assessments
Erin Mulholland, analyst at thinkstep, talked about conducting
lifecycle assessments (LCA), which quantify all the resources
used and emissions across all stages of a product’s lifecycle. ISO
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standards offer a framework for conducting a lifecycle assessment.
The first step is to ask what questions you’re trying to answer with
the assessment.
chemical for which you have no data. “It’s not like today you have a
bad chemical, tomorrow you’re going to have a better one,” he said.
Finding suitable alternatives can be a long-term process.
Mulholland noted that you might only have data for one stage of
the product’s lifecycle. To complete the assessment, you’ll need the
material and energy inputs for the stages you don’t control. A consultant can help by providing a software model to fill the gaps.
Instead, Plugge recommends looking for substitutes that are similar to the chemicals you’re worried about but not as much of a concern. If that’s not possible, then you’ll have to design something
from scratch. He noted that no alternative is better, then you will
have to conduct an exposure screening.
LCA addresses potential environmental impacts but does not predict absolute or precise environmental impacts, said Mulholland.
Also, the assessments do not say anything about the inherent hazard of the product. One of the challenges with LCAs is that the data
can’t be used to assess exposure. The inventory data focuses on
releases. It has no temporal dimension or concentration.
Finding Substitutes
Hans Plugge, senior toxicologist at 3E Company, reminded attendees that the ultimate goal is to reduce overall environmental and
health risks. That said, there are always tradeoffs. When dealing with alternatives assessments, functionality is important. If
you have data for one chemical, it’s pointless to replace it with a
www.ProductStewards.org
Hans Plugge, senior toxicologist
at 3E Company, reminded
attendees that the ultimate
goal is to reduce overall
environmental and health risks.
16
WHY DID YOU ATTEND?
HERE’S WHAT SOME ATTENDEES HAD TO
SAY ABOUT WHY THEY ATTENDED THIS
YEAR’S STEWARDSHIP CONFERENCE:
VICTORIA FEDOR
PRODUCT STEWARDSHIP SPECIALIST
The Lubrizol Corporation
As product stewards, we like to know where there’s room for improvement. Learning best practices from other industries is hugely valuable. This was my second time attending. One thing that I picked
up was the concept of the product stewardship audit. There’s not a
standard procedure, but we are constantly doing audits, but is there
a piece we’re missing? It’s something I brought back to our management team, and we might try to implement.
I also made some new connections and met some new friends.
There’s something for everybody at this conference, no matter what
industry you come from. I would definitely recommend it to any product stewards. I will definitely continue attending.
www.ProductStewards.org
“I WOULD DEFINITELY RECOMMEND IT
TO ANY PRODUCT STEWARDS. I WILL
DEFINITELY CONTINUE ATTENDING.”
17
NANOMATERIALS:
INFORMATION FOR PRODUCT STEWARDS
L
ynn Bergeson, managing partner at Bergeson & Campbell,
started working with nanotechnology a decade ago, when
it was unclear how the U.S. regulatory framework would
approach them. There was tremendous interest in leveraging R&D
and finding appropriate standards that incentivized research. The
goal was to use existing frameworks without having to create
new laws.
The good news is that concerns about potential hazardous elements have subsided, she said. Existing governing frameworks
have aptly managed the risk while optimizing the technology. “We
have stewarded this technology in a way that should all make us
proud,” she said.
That said, the use of nanochemicals and materials does invite
potential legal and stewardship issues, but there is a robust body
of work readily available. Organizations have found ways to identify and manage hazards that nanomaterials might pose. How
governance systems will address concerns as issues evolve is a
question. The good news, said Bergeson, is that the governance
systems globally are elastic enough to adapt.
Product stewards are already suited to dealing with nanomaterials. The processes that
stewards use to asses and manage risk is
the same to assess risk for nanomaterials.
Dell suggested including different physical
properties of the nanomaterials on the SDS,
including particle size, shape and aspect
ratio, and crystallinity, specific surface area
and dispersability. In other words, when you
have information, provide it.
Organizations have found ways
to identify and manage hazards
that nanomaterials might pose.
Linda Dell, senior manager at Ramboll Environ, said that a product
stewardship program is about risk assessment, risk management
and risk communication. There are many promising applications of
nanotechnology. To see some of the ways it’s changing the world,
visit nano.gov.
www.ProductStewards.org
18
METHODS FOR DEALING
WITH REGULATORY NUANCE
Regulations vary from country to country, despite the existence
of overarching frameworks. There is no single, unified way to
meet all the regulations, but there are methods for dealing with
regulatory nuance efficiently and strategically. Kerrie Canavan,
consultant at Environmental Resources Management (ERM),
shared some of those methods with Stewardship 2016 attendees.
F
or example, language barriers can sometimes be a challenge.
For example, some Serbian regulations have no English
translations. In those instances, you need to partner with
local subject matter experts to assist with the registration.
Data requirements will differ from jurisdiction to jurisdiction, so
Canavan suggested starting with the most demanding registration. Then when you seek to register with less demanding jurisdictions, you’ll already be prepared.
If data isn’t collected and
managed properly, the
registration is at risk.
A robust IT system also facilitates registration in multiple jurisdictions. If data isn’t collected and managed properly, the registration
is at risk. In other words, the data quality affects the quality of the
registrations. A good IT system will also be adaptable.
Canavan also encouraged the industry to get involved in rulemaking. It’s in the industry’s best interest to support collaboration
between governments and to make rules and regulations understandable.
www.ProductStewards.org
19
GREEN CHEMISTRY:
A CASE STUDY IN TRANSPARENCY
P
roduct stewardship has an active role in helping AkzoNobel
market green products. The company adopted transparency
and collaboration as guiding principles as it integrated its
product stewardship and marketing functions. Ed Bisinger, the
company’s regional PSRA manager, presented a case study to
illustrate how it works.
As a backdrop to the case study, Bisinger explained that product
stewardship is embedded in the company. Business managers are
responsible for implementing product stewardship, using the company’s continuous improvement tool. The tool is designed to tell
the business leaders where they are currently. They have to explain
how they’ll improve and in what timeline.
The company also reviewed all the substances in its portfolio with
a GHS classification and scored them based on toxicity, ecological concern and public perception. Substances were deleted from
the portfolio when possible. Those that couldn’t be deleted underwent a detailed risk assessment. Based on the risk assessments,
the company prohibited the use of some and restricted the rest to
specific conditions that were shown to be safe.
The company also prioritizes green chemistry initiatives. It participates in the GC3, a group effort to accelerate green chemistry solutions and increase transparency in the value chain, said Bisinger.
The challenge was to identify a phosphatereplacement that worked and was safe from
a human and environmental standpoint. The
company developed a molecule that met the
requirements. Testing showed that it had
an excellent safety profile, said Bisinger. The
company provided its customer with copies of
all the studies and reports. “They came to the
conclusion that this product was safe,” he said.
Unfortunately, there was a glitch. The customer conducted
its own testing and found that the molecule wasn’t biodegradable.
Initial testing showed that it was biodegradable in Europe but not
in the U.S.
After more testing, it was apparent that the microorganisms hadn’t
acclimated to the U.S., but that it would adapt the necessary metabolic pathways. The companies presented the study results at
numerous conferences and shared the full report with the EPA.
The EPA voiced a different concern, about a possible hazard. Rather
than conduct a lengthy study, AkzoNobel worked with the agency
to develop a new assessment approach that involved a short-term
study that has been previously validated by the FDA for pharmaceutical use. The molecule was shown to be safe, and the company
presented the methodology at a number of conferences.
The Case Study
When it was tasked with developing a new automatic dish washing liquid, AkzoNobel committed to a transparent and collaborative
process with its customer, the EPA and NGOs.
www.ProductStewards.org
20
WE ENSURE MARKET ACCESS: THE BUSINESS
VALUE OF PRODUCT STEWARDSHIP
Businesses rely on product stewardship for market access. When regulatory
noncompliance delays product shipments, it directly affects the bottom
line. But executives rarely see the business value of product
stewardship. It’s up to product stewards to help them understand,
said Mitch Fonda, global compliance and stewardship at Waters
Corporation. He shared how his company integrates product
stewardship by stressing the function’s business value.
First, product stewards must learn to talk differently about what
they do. Business leaders aren’t interested in conversations about
chemistry and materials. Nor do they care about the nuances of
regulatory compliance. What they care about is getting products
to market seamlessly. After talking to business leaders at Waters,
Fonda and his colleagues had an epiphany. “All of this stuff to them
is an import issue. They don’t care where it comes from. They can’t
care about SDS or RoHs,” he said.
When products are stuck at borders, the company’s reputation and
revenue is at stake. Preventing that scenario is the value proposition of product stewardship. “[Product stewardship] is how we
get our goods unencumbered around the world, and it’s for every
single country that we go in,” said Fonda.
www.ProductStewards.org
To convince executives, Fonda showed them
that a typical order can result in more than
80,000 border crossings, and more than 800,000
data points. He showed a map to illustrate how a
product gets produced. When they asked about the data
points, he showed a list of the regulations, health/safety permits,
documentation, declarations and export controls involved.
Product stewardship at Waters is part of Global Operations as a
reflection of its role in moving products around the world. Over
time, Fonda’s group has become a knowledge center, connecting
disparate groups that don’t typically work with each other, from
engineering to procurement to marketing and sales, to legal. “We
can talk to anyone anywhere about any product and we know as
much or more than they do,” said Fonda.
21
PRODUCT STEWARDSHIP TALENT
MANAGEMENT AT J&J AND BASF
What does a career in product stewardship look like? To explain
how companies hire and retain stewardship talent, three panelists
at Stewardship 2016 discussed what companies can do to enable
product stewards to grow professionally.
R
ob Shimp, program director at the Product Stewardship and
Regulatory Affairs Council (PRSA) opened the discussion
by referencing a PRSA report. The objective was to identify
consistent themes and language that companies can use to describe
the responsibilities of product stewards. Another objective was to
identify best practices for hiring and retaining product stewardship
employees.
Product Stewardship has evolved, so that the function involves
many responsibilities and a growing list of expectations from
customers, NGOs and other stakeholders. One theme links them
all: “We’re ultimately a multi-disciplinary group that has to cross
boundaries and translate what we do into relevant business content,” said Shimp. In other words, incoming product stewards must
be good integrators and collaborators.
Talent management is necessary because product stewards lack a
clear functional identity or obvious academic credentials. Product
www.ProductStewards.org
stewards from outside the organization lack business knowledge, so helping new hires through
the learning curve more quickly can aid in talent management.
The report suggests ‘branding’ the function by linking product stewardship at your
company to its societal role — making sure
products are safe for humans and the environment. Some employees are motivated by
the opportunity to work across functions and
business units, so that’s another approach to
recruiting talent.
How J&J and BASF Manage Talent
At Johnson and Johnson, the talent management process starts
with planning at the beginning of the year. Performance reviews
22
CONTINUED
are conducted mid-year. Succession planning and year-end performance reviews take place at the end of the year, said Al Iannuzzi,
senior director, environment, health, safety, & sustainability.
Iannuzzi also described the career ladders for product stewards at
Johnson and Johnson. To develop skills and experience, stewards
can work on short-term projects, development projects, or stretch
assignments outside of their typical responsibilities. The development process also includes robust succession planning. They identify critical positions on the tem and conduct cross-training so if a
person leaves, the gaps are filled.
At BASF, the product stewardship group is about 75 employees in
North America and 10 to 15 contractors, said Kara Sparks, director of product stewardship & regulatory affairs, North America.
She said there’s an expectation at BASF that employees will need
coaching in order to perform better over time.
To develop skills and experience,
stewards can work on short-term
projects, development projects,
or stretch assignments outside
of their typical responsibilities.
The development process also
includes robust succession
planning.
The development process takes many forms and many possible
pathways, said Sparks. The goal is to put people where they want
to be. For example, there’s an ‘expert’ path, where employees can
rise to the VP level but not be pushed into running a business.
www.ProductStewards.org
23
SEE YOU NEXT YEAR AT
Stewardship
Tampa, Florida | Nov. 2–4, 2017
ProductStewardsConference.org
#Stewardship17
2017
ABOUT THE PRODUCT STEWARDSHIP SOCIETY
The Product Stewardship Society provides resources,
professional development, and networking opportunities
to enable product stewardship practitioners to promote
responsible design, development, and management of
products throughout their lifecycle. Learn more at
www.ProductStewards.org.