Product Stewardship Code Manual

Product Stewardship Code
Responsible Care®
Code of Management Practices
Making progress
toward our vision of
NO ACCIDENTS
&
NO INJURIES
no harm
to the environment
``````````````````````LEGAL NOTICE
This Guide was prepared by Arthur D. Little, Inc. and ICF Kaiser Engineers and ICF Incorporated (ICF) as an
account of work sponsored by the American Chemistry Council. Neither Arthur D. Little, Inc., ICF Kaiser
Engineers and ICF Incorporated, the American Chemistry Council, nor any of their employees, subcontractors,
consultants, or other assigns makes any warranty, expressed or implied, or assumes any liability or
responsibility for any use, or the results of such use, of any information, product, or process disclosed in this
Guide, or represents that its use would not infringe privately owned rights.
The Resource Guide for the Product Stewardship Code of Management Practices has been prepared to
accompany the Product Stewardship Code. It is intended to provide some helpful ideas for planning code
implementation by American Chemistry Council members and Responsible Care Partners. American Chemistry
Council members, Responsible Care partners, and all entities involved in the chain of distribution and sale of
products have an independent obligation to ascertain that their actions and practices represent sound product
stewardship practices. The manual is necessarily general in nature and leaves dealing with product and
site-specific circumstances to American Chemistry Council members and Responsible Care Partners. American
Chemistry Council members and Responsible Care partners may vary their approach with respect to particular
products or locations based on specific factual circumstances, the practicality and effectiveness of particular
actions and economic and technological feasibility. It is also understood that the timing and speed of
implementation by American Chemistry Council members and Responsible Care Partners will vary by
company, location and nature of products.
The manual is not designed or intended to define or create legal rights or obligations. American Chemistry
Council members and Responsible Care Partners are, of course, expected to comply with federal, state, and
local laws and regulations, and should consult with legal counsel concerning such matters.
The American Chemistry Council does not make any warranty or representation, either express or implied, with
respect to the accuracy or completeness of the information contained in this manual; nor does American
Chemistry Council assume any liability of any kind whatsoever resulting from the use of or reliance upon any
information, procedures, conclusion, or opinion contained in this manual.
©American Chemistry Council (1992)
This work is protected by copyright. The American Chemistry Council, which is the owner of the copyright,
hereby grants a nonexclusive royalty-free license to reproduce and distribute this Guide, subject to the following
limitations:
1. The American Chemistry Council assumes no responsibility for the accuracy, completeness, or overall
quality of any alterations, abridgement, revision or other modification of this copyrighted work.
2. All copies of the work must include a cover page bearing the American Chemistry Council’s Notice of
Copyright of the work.
3. Copies of the work may not be sold.
1
Acknowledgments
We appreciate the support given to this project by the American Chemistry Council through the Product
Stewardship Code Drafting Work Group. Their technical insights, experiences, and suggestions were essential
to the development of this Resource Guide. At this Guide's publication, the Work Group had the following
members:
David Alcorn Harry Hunter Larry Rampy

Crompton & Knowles Exxon Chemical Americas Dow Chemical Company
Andy Allen Bernadine Javorek Joan Seff
Ashland Chemical, Inc. BP Chemicals Chevron Corporation
Mark E. Berenson Rod Johnson John Sepesi
SCM Chemicals Unocal Shell Oil Company
Pat Brink Fran Kearney George Simmons
The Dow Chemical Company MonsantoFirst Chemical Corporation
Graham Carpio Kenneth Lee Ladd W. Smith
CHEMCENTRAL Corporation PPG Industries, Inc.Occidental Chemical
Corporation
Eric Coleman Peter Lloyd Dale Strother
ARCO B.F. Goodrich BP Chemical
Billy Cooper George M. Malouf Michele Sullivan
Univar Corporation U.S. Borax Hoechst Celanese
Ralph Feeney Mark McCarthy Mark Swafford
Amoco BP Chemicals, Inc. Burris
Harold Flegenheimer James Mieure Donald R. Theissen
Rhone-Poulenc Monsanto Company 3M Company
Bill Haaf Tony Mortimer Janice Warnquist
E.I. du Pont de Nemours & Co. Union Carbide CorporationCrompton &
Knowles Corp.
Richard Hanlon Charlie Moyer Glenn R. Weckerlin
Hoechst Celanese Rhone-Poulenc, Inc. Chevron Corporation
Fred Hill Tom Parrot
Shell Oil Company Vulcan Chemicals
Development of this Resource Guide was coordinated by Claudette M. Cofta, Mary Beth Preston, Susan Conti
and Don Evans of the American Chemistry Council and was revised and prepared by the following ICF staff:
Helen J. Taylor, H. Casey Cordes, Susan Yovits, Gene Hallinan, Gerry Joy and Betsy Marcotte. The Guide was
based on an original draft prepared by Mary Woodell and Stewart Young of Arthur D. Little, Inc.
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Table of Contents
Introduction 4
Purpose and Scope 5
How to Use this Guide 7
Chapter 1: The Product Stewardship Code 9

Introduction 9
Product Stewardship Code of Management Practices 11
Purpose and Scope 11
Relationship to Responsible Care and Guiding Principles 11
Management Practices 13
Common Questions and Answers 19
Sample Member Self-Evaluation Form 22
Chapter 2: How Product Stewardship Relates to Your Job 29

Introduction ........................................................................................ 29
Senior Management 36
Research and Development ............ 42
Health, Safety and Environmental 50
Purchasing and Supply 60
Manufacturing 63
Marketing and Sales 69
Distribution 79
Product Steward 83
Communications 84
Chapter 3: Responsible Care 91

History of Responsible Care 92
Elements of the Responsible Care Initiative ......................................................... 93
Responsible Cares Codes of Management Practices............................................. 94
Common Themes Emphasized in the Responsible Care Codes 97
Other Activities Related to Responsible Care 98
Chapter 4: Additional Resources 99

Exercises to Help You Implement Product Stewardship 100
Launching the Program 112
Product Stewardship Assessment Review Guideline 118
Appendix A: Contract Manufactures Assessment Guidelines 126
Appendix B: Supplier Survey Guidelines 132
Glossary 182
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Introduction
This Resource Guide was developed to assist American Chemistry Council members and Responsible Care
partner companies with their implementation of the Product Stewardship Code of Management Practices (see
How to Use This Guide on page iv). While each company will have its own unique way of implementing a
Product Stewardship program, this guide may provide some helpful ideas. It is important to note that this
Resource Guide is not a comprehensive listing of ways to implement the Code -these are as many and varied as
the companies using this guide. Nor will the suggestions contained within be right for every company.
American Chemistry Council's development of a product stewardship initiative is a natural outgrowth of various
programs that have developed within the U.S. chemical industry. These programs go by many different names,
including product safety, product integrity, and product responsibility. Many of the more "traditional" health,
safety, and environmental (HSE) programs or practices tended to focus on regulatory compliance issues.
Product stewardship strengthens and broadens the focus to include such concepts as customer interaction and
dialogue on how to foster proper use, handling, recycling and disposal of products. It is a comprehensive
integration of health, safety and environmental considerations into each aspect of a company's operations, from
design and initial manufacture to distribution, sales and ultimate disposal. This code will affect nearly every
segment of a company's operations.
The American Chemistry Council is committed to helping its members expand their view of product safety to
include the concepts of product stewardship. Product stewardship focuses the chemical industry's product safety
concerns from design through use, recycling, and disposal. Successful implementation of the Code, however,
requires the efforts of all parties. Everyone who manufacturers, uses, or handles products throughout the chain
of commerce must follow safe and environmentally sound practices.
Product Stewardship takes into account the need for considering resources and processes employed at the
beginning of the product's life and for proper disposal at its end-and seeks to incorporate critical health, safety,
and environmental priorities throughout all stages of a product's life. This focus requires an increasing emphasis
on formal management systems to ensure the proper identification and management of potential health, safety
and environmental risks throughout the product lifecycle.
To assist its members incorporate product stewardship into their business practices, American Chemistry
Council has developed the Product Stewardship Code, one of six codes in the Responsible Care initiative. The
Product Stewardship Code, described in the following pages and in more detail in Chapter 1, includes 12
management practices to guide members' efforts in improving health, safety, and environmental performance.
These management practices share the common goal of ongoing reduction of risk, and help members develop a
safer product, with confidence in the product's safety when properly used. Continuous improvement of the risk
management process is the cornerstone of product stewardship. Effective implementation relies on the
establishment of management systems that weave product stewardship-like quality or safety-into all aspects of a
company's business operations.
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Purpose and Scope
The purpose of the Product Stewardship Code of Management Practices is to make health, safety and
environmental protection an integral part of designing, manufacturing, marketing, distributing, using, recycling
and disposing of our products. The code provides guidance as well as a means to measure continuous
improvement in the practice of product stewardship:
The scope of the code covers all stages of a product's life. Successful implementation is a shared responsibility.
Everyone involved with the product has responsibilities to address society's interest in a healthy environment
and in products that can be used safely. All employers are responsible for contributing to a safe workplace, and
all who use and handle products must follow safe and environmentally sound practices.
The code recognizes that each company must exercise independent judgment and discretion to successfully
apply the code to its products, customers and business.
Relationship to Responsible Care and Guiding Principles

Implementation of the code promotes achievement of several of the Responsible Care Guiding Principles:
• To provide chemicals that can be manufactured, transported, used and disposed of safely.
• To make health, safety, the environment and resource conservation critical considerations for all
new and existing products and processes.
• To provide information on health or environmental risks and pursue protective measures for
employees, the public and other key stakeholders.
• To work with customers, carriers, suppliers, distributors and contractors to foster the safe use,
transport and disposal of chemicals.
• To operate our facilities in a manner that protects the environment and the health and safety of our
employees and the public.
• To support education and research on the health, safety and environmental effects of our products
and processes.
• To lead in the development of responsible laws, regulations and standards that safeguard the
community, workplace and environment.
To practice Responsible Care® by encouraging and assisting others to adhere to these principles and
practices..
Introduction
Management Practices
Each company shall have an ongoing product stewardship process that:
Management Leadership and Commitment
1. LEADERSHIP: Demonstrates senior management leadership through written policy, active participation
and communication.
2. ACCOUNTABILITY and PERFORMANCE MEASUREMENT: Establishes goals and responsibilities

for implementing product stewardship throughout the organization. Measures performance against these
goals.
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3. RESOURCES: Commits resources necessary to implement and maintain product stewardship practices.
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Information and Characterization
4. HEALTH, SAFETY and ENVIRONMENTAL INFORMATION: Establishes and maintains information

on health, safety and environmental hazards and reasonably foreseeable exposures from new and
existing products.
5. PRODUCT RISK CHARACTERIZATION: Characterizes new and existing products with respect to
their risk using information about health, safety and environmental hazards and reasonably foreseeable
exposures. Establishes a system that initiates re-evaluation.
Risk Management
6. RISK-MANAGEMENT SYSTEM: Establishes a system to identify, document and implement health,

safety and environmental risk-management actions appropriate to the product risk.
7. PRODUCT and PROCESS DESIGN and IMPROVEMENT: Establishes and maintains a system that
makes health, safety and environmental impacts-including the use of energy and natural resources-key
considerations in designing, developing and improving products and processes.
8. EMPLOYEE EDUCATION and PRODUCT USE FEEDBACK: Educates and trains employees, based
on job function, on the proper handling, recycling, use and disposal of products and known product uses.
Implements a system that encourages employees to feed back information on new uses, identified
misuses or adverse effects for use in product risk characterization.
9. CONTRACT MANUFACTURERS: Selects contract manufacturers who employ appropriate practices

for health, safety and environmental protection for the operations under contract, or works with contract
manufacturers to help them implement such practices. Provides information and guidance appropriate to
the product and process risk to foster proper handling, use, recycling and disposal. Periodically reviews
performance of contract manufacturers.
10. SUPPLIERS: Requires suppliers to provide appropriate health, safety and environmental information
and guidance on their products. Factors adherence to sound health, safety and environmental principles,
such as those contained in Responsible Care into procurement decisions.
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11. DISTRIBUTORS: Provides health, safety and environmental information to distributors.
Commensurate with product risk, selects, works with and periodically reviews distributors to
foster proper use, handling, recycling, disposal and transmittal of appropriate information to
downstream users. When a company identifies improper practices involving a product, it
will work with the distributor to improve those practices. If, in the company's independent
judgment, improvement is not evident, then the company should take further —measures-up
to and including termination of the business relationship. This Management Practice should
be implemented in conjunction with the Distribution Code of Management Practices.
12. CUSTOMERS AND OTHER DIRECT PRODUCT RECEIVERS: Provides health,

safety and environmental information to direct product receivers. Commensurate with
product risk, works with them to foster proper use, handling, recycling, disposal and
transmittal of appropriate information to downstream users. When a company identifies
improper practices involving a product, it will work with the product receiver to improve
those practices. If, in the company's independent judgment, improvement is not evident, then
the company should take further measures--up to and including termination of product sale.
Relationship To Other Codes of Management Practices
This code complements, and should be implemented in conjunction with, current and future Codes
of Management Practices.
How To Use This Guide
This Resource Guide is divided into four chapters. Chapter 1 provides background information on
product stewardship and then goes into greater detail in describing the Product Stewardship Code's
12 management practices. In addition, Chapter 1 provides you with a sample self-evaluation form
for determining how effective you have been in meeting the requirements of the Product
Stewardship Code. Because each company is different and will implement its product stewardship
program in a way that meets its own needs, progress is measured through a self-evaluation process.
Chapter 2 is an important resource in illustrating suggestions for product stewardship activities that
could be conducted by various job functions in your company, and describes how different job
functions may interrelate under Product Stewardship. The chapter is divided into job functions that
are likely to be found in a chemical company structure (e.g., senior management, research and
development). Each job function lists the management practices that may apply to a person with that
job, and describes possible activities that could be conducted to implement each management
practice.
Chapter 3 describes the overall program of Responsible Care in more detail. Product stewardship is
currently one of six codes that are part of the Responsible Care initiative. This chapter will help you
understand the make-up of Responsible Care its history, guiding principles, the other five codes, and
other related American Chemistry Council activities.
Chapter 4 provides you with a collection of additional resources to help you implement Product
Stewardship Management Practices. The resources include exercises to help you in organizing and
implementing a product stewardship program; a listing of suggested readings; and a brief product
risk characterization and risk management aid;
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Finally, Appendix A in the back of the Resource Guide provides you with a glossary of key words
and acronyms used throughout the Resource Guide.
Introduction
The Resource Guide, like product stewardship itself, is a work in progress and is intended to be used and
updated, with your own additions and those of others. Each page in this Resource Guide is dated in the lower
inside comer. As new information is developed and materials are updated, American Chemistry Council will
distribute materials to replace or add to the Resource Guide. The dating system will help you keep track of
updated sections.
If you have any questions about this material, or would like to share successes or concerns that develop as you
implement the Product Stewardship Code, please feel free to contact the Responsible Care staff at (703) 741-
5000.
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Chapter 1: The Product Stewardship Code
Introduction
This chapter includes important information on the Product Stewardship Code of Management Practices. Read
this chapter along with the section or sections in Chapter 2 that most closely describes your duties within your
company.
The Product Stewardship Code is an initiative adopted by American Chemistry Council member companies to
make health, safety, and environmental issues a priority in all phases of a chemical product's lifecycle, including
design, manufacture, distribution, use, recycling, and disposal. Product stewardship works to lessen adverse
impacts by managing product risks with sound business practices. The code consists of 12 management
practices. Together, they provide a guide for successfully implementing product stewardship. Each management
practice either lays the foundation for organizing your product stewardship program or focuses on managing
risks in a particular phase of the product's life. Product stewardship begins with research and development when
a product is first conceived and extends through product manufacture, use, and disposal. Therefore, successful
implementation of product stewardship depends not only on the manufacturer but also others who come into
contact with the product, including distributors, customers, and disposers.
As part of the overall Responsible Care initiative, the Product Stewardship Code is one of six Codes of
Management Practices developed and adopted by American Chemistry Council member companies to help
chemical manufacturers improve their human safety, human health, and the environmental performance through
sound business and management practices (refer to Chapter 3 for more information on Responsible Care and the
other five Codes of Management Practices). Each code focuses on a particular area of operations within a
company and taken together, these codes help member companies comprehensively manage health,
environmental, and safety risks of the products they manufacture. To a large extent, the Product Stewardship
Code ties together all the other codes, by addressing potential concerns at every stage in the product's lifecycle.
In addition to immediate, obvious benefits of improved health, safety, and environmental protection, companies
that implement product stewardship will receive additional, less immediately measurable benefits over the long
term, including:
• Goodwill. Product stewardship, like the Responsible Cares Program as a whole, promotes active
involvement with stakeholders: employees, suppliers, customers, shareholders, and others whose
goodwill is essential to your business. These relationships have value in the best of times, but they are
never more critical than when problems arise that challenge your company's reputation.
• Productivity. Employees who see tangible evidence of their company's commitment to their own health
and safety-and that of others-and who are themselves actively involved in product stewardship, are more
productive, more supportive of company-wide goals, and better company "ambassadors" in their
communities.
• Credibility. Regulatory authorities and elected officials are more willing to grant a fair hearing when
they understand the extent of your company's efforts to protect human health, safety, and the
environment.
• Cost savings. Investment in health, safety, and environmental protection early in the product lifecycle
may preempt far greater expenditure for remediation or other corrective measures.
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• Competitive advantages. Product stewardship anticipates and addresses increasing demand for safer,
more environmentally sound products-demands that translate into sales. Product stewardship also
involves strengthening relationships with customers, thus improving the quality and timeliness of
market information.
• Reduced liability. Because of its focus on customer education and involvement, an effective product
stewardship initiative should help to reduce customer misuse of chemical products, prevent accident and
injuries, and reduce your company's exposure to legal claims. Similarly, the active participation of
contract manufacturers, distributors, suppliers and employees should help assure the proper handling of
raw materials and finished products, thus mitigating potential liabilities.
This chapter is divided into three sections. The first section presents the Product Stewardship Code of
Management Practices. It explains the purpose and scope of the Product Stewardship Code and its relationship
to Responsible Careen Each management practice is presented and described in detail. The second section
answers common questions about the Product Stewardship Code. The last section includes a copy of American
Chemistry Council’s self-evaluation form that is issued annually to your company's Responsible Care
Coordinator.
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Product Stewardship Booklet for the Code of Management Practices
The code's management practices are grouped into three categories, described as follows:
Management Leadership and Commitment contains Management Practices 1-3. These practices 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.
Information and Characterization includes Management Practices 4 and 5. These address the need to continually
increase the body of knowledge surrounding chemical products in order to improve hazard identification and
risk characterization at every stage in a product's life.
As the cornerstone of product stewardship, Management Practices 6-12 are categorized as Risk Management
practices, which work together to manage risks at every stage of a product's life. Some of these management
practices are the most challenging in the Code because they extend the risk management process beyond
traditional boundaries to consider risks beyond the point of sale.
Management practices in the first two categories provide the foundation for conducting the risk management
practices in the third category. The ability to implement each management practice, therefore, relies upon the
successful implementation of previous practices, with the successful development and implementation of
product stewardship progressing from a planning and resource allocation to an information collection phase,
and finally to action-oriented, risk management activities.
Purpose and Scope

The purpose of the Product Stewardship Code of Management Practices is to make health, safety and
environmental protection an integral part of designing, manufacturing, marketing, distributing, using, recycling
and disposing of our products. The code provides guidance as well as a means to measure continuous
improvement in the practice of product stewardship.
The scope of the code covers all stages of a product's life. Successful implementation is a shared responsibility.
Everyone involved with the product has responsibilities to address society's interest in a healthy environment
and in products that can be used safely. All employers are responsible for providing a safe workplace, and all
who use and handle products must follow safe and environmentally sound practices.
apply the code to its products, customers and business.
Relationship to Responsible Care and Guiding Principles

Implementation of the code promotes the achievement of several of the Responsible
Care Guiding Principles: -
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and processes.
To practice Responsible Care® by encouraging and assisting others to adhere to these principles and
practices.
This code complements, and should be implemented in conjunction with the other five Codes of Management
Practices and the 1999 enhancements to Responsible Care including performance goal reporting and the
commitments:
• to make continuous progress toward the vision of no accidents, injuries or harm to the environment
and to publicly report our global health, safety and environmental performance, and
• to lead our companies in ethical ways that increasingly benefit society, the economy and the
environment while adhering to the following principles.
Chapter 3 discusses the Product Stewardship Code's relationship to the other existing codes.
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Management Practice 1
LEADERSHIP: Demonstrates senior management leadership through written policy, active participation and
communication.
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 also should be clear that the commitment is an ongoing, long-term part of the
company's operations and business.
Finally, if the new policy represents a change in the way of doing business, it should be clear that a change in
behavior is expected. In some companies, a separate written product stewardship policy may be effective. In
others, a broader health, safety and environmental (H,S&E) policy that incorporates the principles of product
stewardship may be more appropriate.
However, a policy alone is not enough. 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. (Management Practices 2 and 3 focus on some of the
visible signals -- for example, goals, performance measurement and resource allocation).
ACCOUNTABILITY and PERFORMANCE MEASUREMENT: Establishes goals and responsibilities for
implementing product stewardship throughout the organization. Measures performance against these goals.
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.
Similarly, individual responsibilities should be clear and consistent.
RESOURCES: Commits resources necessary to implement and maintain product stewardship practices.
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.
Undoubtedly, resources will vary from company to company. However, in all cases, the commitment of
resources should be consistent with product stewardship implementation plans and sufficient to support
continuous improvement.
HEALTH, SAFETY and ENVIRONMENTAL INFORMATION: Establishes and maintains information on
health, safety and environmental hazards and reasonably foreseeable exposures from new and existing
products.
Just as Management Practice 1 is the driving force for the Product Stewardship Code, Management Practice 4 is
the foundation. The objective of Management Practice 4 is to establish a knowledge base of human and
environmental hazards and reasonably foreseeable exposures and, once established, to maintain it. Under this
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practice, companies gather information to support the system that characterizes a product's risk (Management
Practice 5) and, ultimately, the system that develops the methods to manage that risk (Management Practice 6).
Initially, some companies may establish their knowledge base by developing information; others may do so by
collecting and compiling available information. However, 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. In many cases, exposure information is not directly available but may be estimated with
product use information. 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.
PRODUCT RISK CHARACTERIZATION: Characterizes new and existing products with respect to their risk
using information about health, safety and environmental hazards and reasonably foreseeable exposures
Establishes a system that initiates re-evaluation.
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. The second objective is to establish a system that triggers reevaluation, whether upon receipt of new
information or upon periodic, scheduled review.
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 time frame for re-evaluation may vary from product to product. Triggers for such reevaluations 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.
RISK-MANAGEMENT SYSTEM: Establishes a system to identify, document and implement health, safety and
environmental risk management actions appropriate to the product risk
The objective of Management Practice 6 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
by each company takes the basic information on a product's risk (Management Practice 4), characterizes it
(Management Practice 5) and then implements a series of risk management actions (Management Practice 7
through 12). 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.
The management practices that follow, Management Practices 7 through 12, are specific areas of company
operations that warrant discussion and special emphasis.
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PRODUCT and PROCESS DESIGN and IMPROVEMENT: Establishes and maintains a system that makes
health, safety and environmental impacts-including the use of energy and natural resources-key considerations
in designing, developing and improving products and processes.
Designing products and processes (or redesigning existing products and processes) with a system to identify
health, safety and environmental 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, during the concept and design (or redesign) phases. Re-evaluation should occur on a
periodic basis or whenever changes to the product or process are contemplated.
Insights and contributions from employees in all functional areas that may affect health, safety and the
environment should be incorporated into the review. These functional areas include research and development,
manufacturing, distribution, sales and marketing and regulatory personnel. .
EMPLOYEE EDUCATION and PRODUCT USE FEEDBACK: Educates and trains employees, based on job
function, on the proper handling, recycling, use and disposal of products and known product uses. Implements a
system that encourages employees to feed back information on new uses, identified misuses or adverse effects
for use in product risk characterization.
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 customer's and the public's comments or perceptions.
It is essential that there be timely feedback of this safety, health or environmental information or concerns into
the risk characterization process (Management Practices 4 and 5). This feedback may change the risk
management actions (Management Practice 6).
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CONTRACT MANUFACTURERS: Selects contract manufacturers who employ appropriate practices for
health, safety and environmental protection for the operations under contract, or works with contract
manufacturers to help them implement such practices. Provides information and guidance appropriate to the
product and process risk to foster proper handling, use, recycling and disposal. Periodically reviews
performance of 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 contrail.
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. If contract
manufacturers are unwilling to implement appropriate controls, a company may decide to cease doing business
with them. While companies are committed to working with contract manufacturers to help them improve
performance, improvement to meet appropriate H,S&E 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 H,S and E product information, providing technical assistance
on product handling techniques and waste minimization and management, and possibly visiting the contract
manufacturer's facilities. These actions will vary according to the individual contract manufacturer and
operation. Because of the greater degree of company control, much closer interaction will be appropriate with
contract manufacturers than compared to distributors and customers. All contract manufacturers should be
subject to periodic performance reviews.
Along with Management Practices 10 and 11, 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 -- not just for
AMERICAN CHEMISTRY COUNCIL companies but for the entire chemical industry.
SUPPLIERS: Requires suppliers to provide appropriate health, safety and environmental information and
guidance on their products. Factors adherence to sound health, safety and environmental principles, such as
those contained in Responsible Care into procurement decisions.
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.
Along with Management Practices 9 and 11, 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 -- not just for
the American Chemistry Council companies but also for the entire chemical industry.
17
As with customers, reviews of suppliers will be commensurate with product risk. However, it is appropriate to
expect companies to make a continuous effort to extend the principles of product stewardship beyond the
American Chemistry Council membership and Responsible Care partners.
DISTRIBUTORS: Provides health, safety and environmental information to distributors. Commensurate with
product risk, selects, works with and periodically reviews distributors to foster proper use, handling, recycling,
disposal, and transmittal of appropriate information to downstream users. When a company identifies improper
practices involving a product, it will work with the distributor to improve those practices. If, in the company's
independent judgment, improvement is not evident, then the company should take further measures-up to and
including termination of the business relationship. This Management Practice should be implemented in
conjunction with the Distribution Code of Management Practices.
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. As with customers and other direct product receivers, a company may decide to terminate
the business relationship with those unwilling to implement corrective actions appropriate for limiting risks and
otherwise 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. These reviews
may be used as a forum to share accumulated knowledge that will elevate health, safety and environmental
performance -- and product stewardship practices.
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. The "transmittal of appropriate"
information acknowledges that while we expect distributors to pass along H, S&E information, 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 H, S&E information.
As with customers and suppliers, reviews of distributors will be commensurate with product risk. It is
appropriate to expect companies to make a continuous effort to extend the principles of product stewardship
beyond the American Chemistry Council membership and Responsible Care Partners.
18
CUSTOMERS AND OTHER DIRECT PRODUCT RECEIVERS: Provides health, safety and environmental
information to direct product receivers. Commensurate with product risk, works with them to foster proper use,
handling, recycling, disposal, and transmittal of appropriate information to downstream users. When a
company identifies improper practices involving a product, it will work with the product receiver to improve
those practices. If, in the company's independent judgment, improvement is not evident, then the company
should take further measures-up to and including termination of product sale.
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 judgment, 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.
The "transmittal of appropriate information" acknowledges that while we want customers to pass along H,S&E
information, 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
H,S&E information.
Along with Management Practices 9, 10 and 11, 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 result in improved health, safety and environmental performance - not
just for American Chemistry Council member companies but the entire chemical industry.
As with distributors and suppliers; reviews of customers will be commensurate with product risk. However, it is
appropriate to expect companies to extend the principles of product stewardship beyond the American
Chemistry Council membership and Responsible Care Partners.
19
Common Questions and Answers
The following questions and answers are intended to provide brief explanations of the Product Stewardship
Code of Management Practices.
(1) How is product stewardship different from "traditional" health, safety and environmental practices?
Today's concept of product stewardship is a natural outgrowth of various programs that have developed in the
U.S. chemical industry. These practices and programs go by many different names, including product safety,
product integrity and product responsibility. Many of the more "traditional" health, safety and environmental
(H,S&E) programs or practices tended to focus on regulatory compliance issues. Product stewardship
strengthens and broadens the focus to include such concepts as customer interaction and dialogue on how to
foster proper use, handling, recycling and disposal of products. It is a comprehensive integration of health,
safety and environmental considerations into each aspect of a company's operations, from design and initial
manufacture to distribution, sale and ultimate disposal. This code will affect nearly every segment of a
company's operations.
(2) How do we know when we've achieved an adequate level of implementation or, in other words, how much
improvement is needed?
Either way this question is asked, it implies that there is a clearly defined end point in the implementation
process, which is not the case. The Product Stewardship Code, along with the other codes of Responsible Care
are based on a continuous improvement process. Each company will need to establish a baseline -- where you
are today -- and then determine what steps are necessary to move towards "code-in-place." Once you are at
code-in place," the management practice should be reviewed annually to determine if there are any additional
activities that might contribute to continuous improvement. There will be a number of examples of activities in
the Product Stewardship Resource Guide.
(3) Why are distributors discussed in the Distribution Code and the Product Stewardship Code?
The Distribution Code was developed prior to the Product Stewardship Code and focuses on the "transportation,
storage and handling" of products as they move from manufacturer to end-user. The Product Stewardship Code
goes beyond these activities. it focuses on additional aspects of the distributors' operation, such as transmission
of H,S&E information to downstream users, recycling and disposal practices and how distributors interface with
customers. Together, the two codes provide a comprehensive structure for the manufacturer and distributor
relationship.
(4) Does the Product Stewardship Code apply to international operations? How does it apply to suppliers from
other countries?
The American Chemistry Council Product Stewardship Code "officially" applies only to the member company
operations and locations in the United States. Because their materials are used domestically, foreign suppliers
should be treated the same as U.S. suppliers. However, there are two practical factors that should be kept in
mind. First, major efforts are underway to implement either the Responsible Care initiative or similar programs
worldwide. As of January 2001, forty-six countries have either adopted, or are proposing to adopt the principles
which are the foundation for International Responsible Care. Secondly, many multi-national companies are
implementing the Responsible Care initiative throughout their worldwide operations on a voluntary basis.
20
(5) What type of information should be provided to customers, distributors and other third parties? How can
this information be provided?
Information that would help protect health, safety, and the environment should be provided. In addition to
MSDSs and label information, a company may choose to provide additional information through bulletins,
videos, instructional workshops or seminars, training programs or site visits. The appropriate actions and
communication media will vary with each company and with the product risk.
(6) How does the Product Stewardship Code relate to the other Responsible Care codes?
The Product Stewardship Code is the broadest in scope of all the codes. As with the Distribution Code, Product
Stewardship addresses third parties. A major portion of the code is focused on a company's interactions with
suppliers, distributors, contract manufacturers and customers. Another portion addresses the gathering and
characterization of H,S&E information. These practices overlap with both the Employee Health & Safety and
the Distribution Code. Another practice, Contract Manufacturers, overlaps the Pollution Prevention Code.
(7) Will 1 be required to carry out a customer audit?
Audits of customers are not required. The need for audits or other appropriate risk management actions will be
determined by the company.
(8) What is meant by the term "work with?"
Although responsibility for proper manufacture, handling, use, recycling and disposal rests with each party in
the chain, the concept of product stewardship includes a willingness to assist where requested or where a need is
apparent. "Working with" may include providing detailed health, safety and environmental product information,
or technical assistance on product handling techniques or visiting facilities. The risk associated with a product
will help determine the appropriate response in each individual case. In addition, certain parties may require
more assistance than others. The response remains a judgment call in each individual case by the company
involved.
(9) What is the appropriate unit of measurement for evaluation (i.e., by business unit, product line, plant site)?
The Product Stewardship Code presents a challenge because the code focuses on activities involving a
company's products rather than a company's facilities. The traditional measurement units used by other codes
may not apply. In addition, no uniform measurement is recommended for every company in conducting
self-evaluations against the management practices. Each company will determine what works best for its
particular circumstances. Some companies may choose to evaluate each individual product, while others may
choose product lines or business units. The most important point is that each company must establish some unit
of measurement and remain consistent year-to-year. Since the self-evaluation process aims to measure each
member company's annual progress against the code practices, and since results are not absolute, the scores are
relevant only to the company's progress measured in subsequent years. The focus is on continuous
improvement, regardless of the unit of measurement.
21
(10) How far down the chain of commerce does the code apply? Does it apply through the first point-of-sale or
beyond?
The Product Stewardship Code covers all stages of a product's life. It is intended to cover as much of the chain
of commerce as necessary to help prevent misuse, mishandling or other activities that might result in harm to
people or the environment from our products. The word "help" is key because it acknowledges that to be
successful, product stewardship must be a cooperative effort.
The main focus of the management practices is on distributors, customers and other direct product receivers, or
those with whom there is a close business relationship. Responsibility lies with the next party in the chain to
practice product stewardship and encourage its downstream users to do the same.
22
Sample Member Self-Evaluation Form
The Importance of Self-Evaluation

Evaluation is a very important tool that will help you meet your product stewardship goals. The purpose of any
evaluation is to learn from your actions so that improvements can be made. Evaluating your efforts ultimately
tells you what works, what doesn't, and helps you modify your efforts so your program is effective and efficient.
Self-evaluations are required as part of the Product Stewardship Code, and the results help American Chemistry
Council identify what resources and training programs are needed by member companies to improve
industry-wide performance.
You are not expected to be at the same level of performance as other member companies for each management
practice. That would be an unrealistic expectation since member companies vary so much in size, operations,
and resources. More importantly, you are expected to show continual progress implementing the management
practices of the Product Stewardship Code.
Initially, these evaluation forms will reflect whether or not member companies have product stewardship
systems in place. Eventually, after the industry has had time to incorporate product stewardship into
company-wide practices, the evaluation forms will be revised to reflect how successful product stewardship
activities have been in affecting the chemical industry as a whole.
How to Complete the Form

As part of the Responsible Care initiative, the self-evaluation stages of implementation mark your progress.
Similar to the self-evaluation process for the Distribution for each product stewardship management practice is
recorded in percentages. The percentages that you fill in for each category for each management practice should
add up to 100%.
For example, if all of your company's effort for a management evaluate existing company practices, you would
place 100% under Category “EV” (see footnotes at the bottom of the self-evaluation form for a definition of
each category. If the company has just begun to develop a plan to implement the management practice, you
might record 90% under category “EV” and 10% under category “DP.” Space is provided to comment on
management practices for which you assign a high percentage rating to Category “NA,” No Action. The
documentation will help you keep track of where greater efforts need to be taken to implement product
stewardship activities.
Deciding who will complete the self-evaluation form is up to each company. A company might decide it is
helpful for each job function or business to complete their own self-assessment. No matter who fills out the
form, consistency in reporting will help you track progress. These forms are meant for internal use in evaluation
needs. However, a self-evaluation needs to be completed for the entire company and sent to Heiden Associates
in December of each year. The Responsible Care Coordinator will generally receive the self-evaluation two
months prior to the due date. The Responsible Care Coordinator and executive contact for the company should
sign this form. It is up to the Company to decide how the internal self-assesemnts by each job function or
business will be used or weighted to arrive at an overall company assessment and reported to Heiden
Associates.
Helpful Suggestions
Below are examples of how member companies have conducted self-evaluations for other Responsible Care
Codes. It is important that your company develop its own method of evaluating your progress to suit the
company's size, resources, management structure, etc.
23
• One Company had each job function define what full implementation of each management practice would
mean in their area of expertise. Working backwards, the company defined each category in the self-evaluation
form. Copies of the definitions, along with a sample completed form, were distributed to each company facility.
These definitions help this company keep reporting consistent.
24
• Some companies have project managers complete the forth, since they are in positions which allow them to
assess the "big picture."
• At another company, the business units are responsible for implementing product stewardship. Therefore,
each business unit is responsible for completing the self-evaluation form. The upper management reviews
business unit performance to assess progress.
• It may be helpful to write down what "code implementation" means for your company to serve as a goal
against which you can measure progress.
25
SAMPLE
PRODUCT STEWARDSHIP CODE OF MANAGEMENT PRACTICES
MEMBER SELF-EVALUATION FORM
Member Company
Name:
Responsible Care Coordinator
Name:
Address:
Telephone:
26
SAMPLE
PRODUCT STEWARDSHIP CODE OF MANAGEMENT PRACTICES
Management Practices Categories
NA EV DP IA PP RI
1. LEADERSHIP: Demonstrate senior management leadership

through written policy, active participation and communication.
Comments on Category NA:
2. ACCOUNTABILITY and PERFORMANCE

MEASUREMENT:
Establish goals and responsibilities for implementing product
stewardship throughout the organization. Measures performance
against these goals.
3. RESOURCES: Commit resources necessary to implement and

maintain product stewardship practices.
4. HEALTH, SAFETY, and

ENVIRONMENTALINFORMATION:
Establishes and maintains information on health, safety and
environmental hazards and reasonably foreseeable exposures
from new and existing products.
Category NA No action. If no action taken became the management practice is not applicable, please explain.
Category EV Evaluating casting company practices against the Management Practice.
Category DP Developing plan to implement Management Practice.
Category IA Implementing action plan
Category PP Management Practice in place.
Category RI Reassessing Management Practice implementation.
27
SAMPLE
Categories NA EV DP IA PP RI
5. PRODUCT RISK CHARACTERIZATION: Characterizes
new and existing products with respect to their risk using
information
about health, safety and environmental hazards and reasonably
foreseeable exposures. Establishes a system that initiates
re-evaluation.
6. RISK-MANAGEMENT SYSTEM: Establishes a system to

identify,
document and implement health, safety and environmental
risk-management actions appropriate to the product risk.
7. PRODUCT and PROCESS DESIGN and IMPROVEMENT:

Establishes and maintains a system that makes health, safety
and environmental impacts-including the use of energy and
natural resources-key considerations in designing, developing
and improving products and processes.
8. EMPLOYEE EDUCATION and PRODUCT USE

FEEDBACK:
Educates and trains employees, based on job function, on the
proper handling, recycling, use and disposal of products and
known product uses. Implements a system that encourages
employees to feed back information on new uses, identified
misuses or adverse effects for use in product risk
characterization.
Category NA No action. If no action taken because the management practice is not applicable, please explain.
Category EV Evaluating existing company practices against the Management Practice.
Category PP Management Practice in place.
28
SAMPLE
Categories NA EV DP IA PP RI
9. CONTRACT MANUFACTURERS: Selects contract
manufacturers
who employ appropriate practices for health, safety and
environmental protection for the operations under contract, or
works with contract manufacturers to help them implement
such practices. Provides information and guidance appropriate
to the product and process risk to foster proper handling, use,
recycling and disposal. Periodically reviews performance of
contract manufacturers.
10. SUPPLIERS: Requires suppliers to provide appropriate

health,
safety and environmental information and guidance on their
products. Factors adherence to sound health, safety and
environmental
principles, such as those contained in Responsible
Care, into procurement decisions.
11. DISTRIBUTORS: Provides health, safety and environmental

information to distributors. Commensurate with product risk,
selects, works with and periodically reviews distributors to foster
proper use, handling, recycling, disposal and transmittal of
appropriate information to downstream users. When a company
identifies improper practices involving a product, it will work
with the distributor to improve those practices. If, in the
company's independent judgment, improvement is not evident,
then the company should take further measures--up to and
including termination of the business relationship. This
Management
Practice should be implemented in conjunction with the
Distribution Code of Management Practices.
12. CUSTOMERS AND OTHER DIRECT PRODUCT

RECEIVERS:
Provides health, safety and environmental information to direct
product
receivers. Commensurate with product risk, works with them to
foster
proper use, handling, recycling, disposal and transmittal of
appropriate
information to downstream users. When a company identifies
improper
29
practices involving a product, it will work with the product
receiver to
improve those practices. If, in the company's independent
judgment,
improvement is not evident, then the company should take further
measures--up to and including termination of product sales
Category NA No action. If no action taken because the management practice is not applicable, please explain.
Category EV Evaluating existing company practices against the Management Practice.
Category PP Management Practice is place.
30
Chapter 2: How Product Stewardship Relates To Your Job
Introduction
This chapter illustrates how the activities and responsibilities of product stewardship might apply to different
job functions within your company structure.
The Product Stewardship Code has 12 management practices that each American Chemistry Council member
can strive to implement. This chapter is divided into 8 typical job functions, plus the optional position of
product steward that you might find within your company, and discusses which of the management practices
may involve each job function. Possible activities to meet the requirements of each management practice are
discussed, as well as how these activities and responsibilities may involve working with other job functions in
your company.
Different management practices involve these different job functions in different ways, and where an individual
may have an advisory role for one management practice, he/she may lead the effort for another practice. Always
keep in mind that your product stewardship effort will be unique to your company, its structure, its resources,
and its needs. There is no single "right" way to achieve the objectives of product stewardship. Regardless of
how your company decides to organize the product stewardship initiative, it will be particularly important that
everyone's roles are clearly defined and understood, and that teamwork is encouraged.
The figure on the following page (Figure 2-1) presents 9 typical job functions across the top of the matrix, and
lists the Product Stewardship Management Practices along the left side. The dots in the matrix indicate which
management practices might involve which job functions in your company. Figure 2-2 on the following page is
the same matrix with the body of the matrix blank. You are encouraged to use the blank matrix to customize the
relationship between job functions and management practices to match your own company's structure. Figure
2-3 illustrates the job functions involved in considering product stewardship issues in the product lifecycle.
31
FIGURE 2-1
Management Practices/Sample Job Functions Matrix
Management Senior Research and HSE, Health, Purchasing Manufacturing Marketing Distribution Product Communications
Practices Management Development Safety and and and Sales Steward
Environmnetal Supply
staff
X
1 Leadership X X
2 X X X
Accountability
and
Performance
Measurement
3 Resources X X X X X X X X X
4 Health, X X X X X X
Safety and
Environmental
Information
5 Product Risk X X X X X X
Characterization
6 Risk X X X X X X X
Management
System
7 Product and X X X X X
Process Design
and
Improvement
8 Employee X X X X X X
Education and
Product Use
Feedback
9 Contract X X X X
Manufacturers
10 Suppliers X X X X
11 Distributors X X X X X X X
12 Customers X X X X X
32
and Other
33
FIGURE 2-2
Management Practices/Job Functions Worksheet
Management Senior Research and EH&S Purchasing Manufacturing Marketing Distribution Product Communications
Practices Management Development and and Sales Steward
Supply
1 Leadership
2
Accountability
and
Performance
Measurement
3 Resources
4 Health,
Safety and
Environmental
Information
5 Product Risk
Characterization
6 Risk
Management
System
7 Product and
Process Design
and
Improvement
8 Employee
Education and
Product Use
Feedback
9 Contract
Manufacturers
10 Suppliers
11 Distributors
12 Customers
34
and Other
Fill in this matrix to reflect which job functions in your company will be responsible for each management practice.
35
RE 2-3
ct Stewardship in the Product Lifecycle
ct Conceptualization Product Design Process Design Distribution, Use,

and Disposal
unctions Involved: Job Functions Job Functions Job Functions
D Involved: Involved: Involved:
keting and Sales • R&D
E • HSE • Manufacturing • Manufacturing
al Counsel • Manufacturing • Marketing and
• Marketing end Sales • R&D Sales
ct Stewardship Issues • HSE
nsider: Product Stewardship • Distribution
cipate regulatory, Issues to Consider: Product Stewardship • Communications
safety, environmental, • Review product Issues to • Legal Counsel
ublic expectations composition Consider: - HSE
rporate customer • Consider: - R&D
ements - Packaging • Waste/emissions
- Handling reduction Product Stewardship
- Reuse, recycling Issues to
- Disposal • Natural resource and Consider:
energy use
• Consider customer • Feedback on:
energy/ natural • Safety end health - HSE Information
resources requirements and environmental Impa needs
- Public concerns
• Prepare product risk • Process risk
characterization assessment • Periodic risk
management review
• Consider customer
HSE requirements • Identity/address
misuse
• Risk-related
G1NOC
• Effective delivery of
HSE Information
36
ghout a product's lifecycle, various job functions will have access to, gather, or observe activities and Information that is
product design process. R Is Important that Individuals relay this information to the appropriate job functions to help im
duct design process.
37
Senior Management
The chief executive or chief operating officer takes an active role in promoting the product stewardship
initiative inside and outside the company. Senior management is ultimately accountable for your company's
commitment to product stewardship and for its performance in meeting the spirit and principles that are the
foundation of the management practices. Senior management demonstrates this through written policy, active
participation, and communication.
Senior management leadership is vital for the success of a program as far reaching as product stewardship. This
leadership includes defining product stewardship in understandable terms and articulating standards. Employees
need to have a clear understanding of what the program means and what senior management's expectations are.
Senior management also can oversee and follow up on the implementation of product stewardship, with
sufficient authority to overrule local decision making if necessary. In the course of these efforts, senior
management also may be involved with resolving conflicts that may arise from product stewardship initiatives,
and for establishing checks and balances to minimize such conflicts.
MANAGEMENT PRACTICES
1: Leadership X
2: Accountability and Performance X
Measurement
3: Resources X
4: Health, Safety, and
Environmental
Information
5: Product Risk Characterization
6: Risk-management System
7.- Product and Process Design
and
Improvement
8: Employee Education and
Product Use Feedback
9: Contract Manufacturers
10: Suppliers
11: Distributors
12: Customers and Other Direct
Product Receivers
The first three Product Stewardship Management Practices relate to leadership, accountability, and resources.
These issues represent the three necessary requirements of senior management in making sure product
stewardship is successfully implemented. Possible activities to consider for implementing these three
management practices are included in the following pages. However, it can be helpful if senior management
reviews all the activities outlined for all the job functions in this chapter. This will help senior management gain
a better understanding of how product stewardship applies to different job functions, and will assist senior
management in overseeing the performance of all job functions.
The box above indicates which management practices senior management staff may be involved with. Other job
functions often conduct the activities described on the following pages, depending on the company's
organization.
38
Management Practice #1: Leadership
Possible Activities to Consider:

Designate appropriate senior managers to form a strategic team and establish regular meeting schedules. It can
be helpful if senior management support is visible, with continuing oversight and involvement.
Considerations:
Senior management may distribute a Responsible Care Manual, which describes the company's fundamental
operating principles regarding health, safety, and environmental (HSE) protection. This clearly demonstrates
that Responsible Care is a company wide concern and provides an example of how it operates or could operate.
Decentralized companies recognize the quality of "leadership" at the division, business unit, or plant level. For
more centralized organizations, central spokesperson leadership may be needed to provide high-level visibility.
You might deal with the issue of centralized versus decentralized leadership with a two-stage process. Each
business unit was allowed to develop a separate policy statement; the best features of each were then combined
to create a consistent platform for the company.
Identify potential conflicts between product stewardship goals and existing company practices to
anticipate and resolve potential conflicts (e.g., a call for sustained growth versus concerns over a new
product's environmental impact). If these kinds of issues can be foreseen at the policy level, they can
be dealt with more effectively.•Consideration: Expert input from multiple perspectives may be
helpful in tough decisions and achieves a system of checks and
balances. For example, debate between HSE and marketing and
sales staff on a product risk question can be encouraged to help
achieve this balance, and if can be helpful if managers hear both
sides.
Establish a timetable for product stewardship, with specified benchmarks. Meet periodically to review progress
and to set new goals.
Look at other programs within the company for ideas on how to organize the initiative. If past programs have
failed, look at why they failed. Changes in markets or management, cost control, or crises can easily derail even
the most committed efforts. However, more initiatives fail from lack of follow-through.
Periodically review the company's product stewardship policies and procedures. It would be helpful if the
policies are clear and the company's expectations are articulated.
Consideration: Nothing undermines a new initiative more quickly than the perception that it is nothing more
than a management fad, or executive row's latest hot button. Since product stewardship is by nature a long-term
process, continuity and follow-through are particularly critical at all levels of management and operation.
Incorporate product stewardship functions into company policies, job descriptions, and reporting mechanisms.
The purpose is to encourage product stewardship responsibilities to survive changes in personnel staff.
Establish procedures for incorporating product stewardship considerations in the evaluation of business
decisions.
39
Make it known to employees when product stewardship considerations are included in larger business
decisions. This helps remind employees that senior management is serious about its commitment to product
stewardship.
Review relevant legal issues with legal counsel. It will be important to be aware of what issues and decisions
will require the involvement of your legal counsel.
Lecturing or speaking to local organizations or companies on your product stewardship activities helps your
local community understand your commitment to health, safety and environmental protection.
Articulate the company's expectations for employees and the role they play in incorporating the Product
Stewardship Code.
Understand employee attitudes. It can be helpful if senior management has a clear sense of how the product
stewardship initiative is likely to be received. Since product stewardship relies on the endorsement of virtually
everyone in your company, it can be helpful if employee attitudes are understood. This does not require
statistical surveys. You can meet with representatives of employees to find out: Is the workforce supportive or
cynical? Are there specific obstacles (institutional or individual) to implementation? Who are the "opinion
leaders" - individuals within the company who command particular respect among employees, and whose
viewpoint will shape employees' attitudes?
Establish an awards program. Recognizing employee performance can help show your company's commitment
to product stewardship. Consider ways of rewarding individual or collective contributions to the effort.
Consideration: An employee might be recognized for exceptional

effort in outreach to customers; a sales rep might receive an award
for sensitive handling of product stewardship issues; a
manufacturer might be commended for devising a process
improvement that helps reduce waste.
Communicate regularly and listen. If you want your employees to be committed, it is not enough to talk; it is
also helpful if you listen and are willing to respond to employee feedback and address their concerns.
Develop a plan for internal and external publicity. It is helpful to ask communications staff to make product
stewardship a priority in its communications efforts.
Report your progress regularly. Product stewardship reporting can take many forms, and can reflect the interests
of the target audience. It is important that your reporting is regular, thorough, relevant, and consistent.
Considerations: You might set a goal of periodic reports on your company's product stewardship initiatives,
and try to exceed if as progress--or setbacks--may warrant.
A number of companies regularly report on health, safety, and environmental issues in special mailings to
shareholders and employees. Discussions on goals, expenditures, and performance milestones are helpful.
40
Management Practice #2: Accountability and Performance Measurement

Consider monitoring the implementation of product stewardship activities on a regular basis. This will help you
catch problems early, and help you keep abreast of progress.
Establish product stewardship goals for staff and get involved in developing performance measures, realistic
goats, and incentives at all levels. Review existing incentive systems for consistency or potential conflict with
product stewardship goals. Product stewardship accountability can be both top-to-bottom and bottom up within
your company. Senior managers cannot require accountability from employees unless they in turn hold
themselves accountable for their performance.
Considerations: Some companies decentralize accountability and establish systems to review each
department's performance. Each department's performance is then reviewed by a product stewardship group or
committee.
Be careful that each job function is clearly distinguished to avoid too much overlap or gaps between HSE rules
and other areas.
Inform your employees and other interested parties about product stewardship so that everyone knows what it
means and what is expected of them. Targeted efforts to inform employees and other parties is helpful. When
possible, consider using existing communications networks.
Consideration: Adapt existing communications tools such as newsletters or reports to educate employees or
shareholders.
Review how information on performance is maintained. Consider who maintains this information; who has
authority to update it; what the timetable is for review; how performance is reported; and how performance
information is protected. This is important because senior management is ultimately accountable for the
company's product stewardship performance.
Consider quantitative and qualitative performance measurement. The criteria for measuring your performance
reflects your company's tradition and business focus. Similarly, evaluation criteria differ for different job
functions based on their different roles.
Consideration: (Regardless of your organizational structure, it may be helpful to balance accountability with
responsibility. Assigning responsibility without accountability may lead to product stewardship's receiving low
priority against more visible goals.
41
Management Practice #3: Resources

Consider establishing a policy and boundaries for your company's investment in product stewardship.
Resources will be needed to implement and maintain product stewardship. Management should be sensitive to
legitimate employee concerns about work overload, and receptive to requests for extra help. Conduct a cost
analysis for funding product stewardship, including human resources and training needs. Think creatively about
ways to retrofit or redeploy resources.
Considerations:Product stewardship is an important part of your business, which
can add to the long-term strategic value of your business.
Decisions about resource allocations can involve dialogue. Dialogue
can be helpful both in terms of end results and employee morale.
It can be helpful if senior management is seen as a resource to
managers, not an adversary.
Dialogue can support better decisions regarding strategic question such as the following:
Can existing communications vehicles be adapted to include a
product stewardship component, rather than starting up a new
publication? Can several product categories share the expertise of
a single environmental staff person? Can you build on training
efforts already in place? Can training programs produce qualified
employees from within, rather than adding to the head count?
As you evaluate resource needs, it is important to encourage

openness and honesty, so that in-house capabilities are neither
exaggerated nor understated. Also, keep in mind the difference
between start-up and ongoing work. Product stewardship, if
properly implemented, should become easier over time, not
harder.
Resource allocations will depend on how your company is
organized (e.g., business unit focus, centralized staff functions,
etc.). Some companies fund product stewardship separately as a
special project.
Consider establishing a strategic team to review each area for its
ability to support product stewardship.
Secure resources to implement product stewardship. Allocating resources can demonstrate your commitment to
product stewardship, and can demonstrate that the company is equipped to follow through on its initiatives.
Review available funding structures (e.g., by product, division, facility) so that product stewardship initiatives
can be appropriately evaluated.
Request development of a system to track, report, and estimate product stewardship costs over time.
Consideration: Some companies allocate resources for product stewardship based on performance measures.
Allocate your resources as performance goals are set, and require evaluations of progress towards those goals.
42
Evaluate savings product stewardship brings and include these savings in your budget (e.g., reduced customer
complaints, legal fees, etc.). Product stewardship can be part of your ongoing budget process.
Evaluate your information systems so that your data and communications system is capable of organizing and
disseminating information that is needed to implement product stewardship.
Considerations:
Some companies will use their computerized chemical information system to distribute information locally and
maintain centralized management and quality control. Product steward staff positions could be centralized or
could be based in each product group.
Many technical professionals keep up-to-date on information affecting their own field of interest. However,
product stewardship requires teamwork, and it can be helpful if resources and information systems exist that
enable everyone to have access and share information.
A decentralized business organization may be a barrier for maintaining centralized administration of an

information system. Internal communications might have to circumvent the boundaries of business structures.
Recognize that product stewardship will often be a net value added to your product when considering resource
allocation, in that you will be providing information and/or services connected with your product.
43
Research and Development
Product stewardship begins when the concept for a new product is born; thus, research and development (R&D)
plays a vital role. R&D is by nature forward-thinking, and product stewardship adds a further dimension by
expanding the traditional definition of most R&D activity.
At the strategy level, R&D represents the scientific and technical job functions that drive the early stages of a
product's life. Therefore, its involvement in product manufacturing includes both the development of new
products and processes and ongoing support for existing products and processes, including the re-evaluation of
product risk characterizations. R&D staff should consider information from upstream suppliers, as well as con-
cerns of customers, such as health, safety, and environmental (HSE) impacts.
1: Leadership
2: Accountability and Performance
Measurement
3: Resources X
4: Health, Safety, and X
Environmental
Information
5: Product Risk Characterization X
6: Risk-management System X
7: Product and Process Design X
and
Improvement
8: Employee Education and X
Product Use
Feedback
10: Suppliers
11: Distributors X
12: Customers and Other Direct X
Product
Receivers
The box at the right indicates which management practices R&D staff may be involved with. Although no
suggested activities are included for Management Practice #3: Resources, this management practice is
applicable to all job functions, because all job functions would need to be sure they have adequate resources to
implement product stewardship. Other job functions often conduct the activities described for these
management practices on the following pages, depending on the company's organization.
44
Management Practice #4: Health, Safety and Environmental Information

Maintain information on product hazards, customer use and misuse of products, and reasonably foreseeable
exposures from product use. This will help in characterizing product risks under normal use, and evaluating
potential levels under foreseeable misuse situations.
Considerations:
As technology, use patterns, and regulations change, consider re
evaluating the need for developing additional HSE and potential
exposure information.
Working closely with marketing and sales staff can be helpful so
they know what kind of information is needed. They can help R&D
staff gather information and let R&D staff know if they notice
anything new.
You may wish to conduct a survey of known product uses.
Review how staff in your company stay current in their fields and up-to-date on published and emerging
scientific and medical findings, and devise a means of sharing their resources.
Conduct seminars using outside speakers (e.g., academia) to expand the knowledge base of RED staff and
heighten internal awareness.
Share HSE expertise with distribution and customer support functions.
45
Management Practice #5: Product Risk Characterization
Note: Chapter 4 includes a Risk Characterization and Management Aid, which provides detailed information on
the risk characterization process.

Participate in regular risk characterization reviews. R&D can provide technical input on product hazards, human
exposure potentials, in-house handling practices, and can evaluate feedback from customers on uses and
misuses.
Maintain up-to-date methods of product risk characterization. This includes methods of product hazard
identification, product toxicity assessment, and product exposure assessment. You could maintain a library or
database of materials containing up-to-date information. Networking with other American Chemistry Council
members and partners and attending conferences can help your team of learn about new developments in risk
characterization methods and issues.
Assist in developing better mechanisms to detect and review changes in product applications by customers. it
would be useful to involve marketing and sales staff in the process. They may observe uses not previously
anticipated and help R&D factor this information into the risk evaluation.
Document the product risk characterization clearly so that it can be easily integrated into subsequent risk
management activities, updating, and required disclosures.
Considerations:
Develop procedures to promote consistency in risk characterization methodologies. These efforts include
developing policies and preparing technical manuals. It can be helpful to remain flexible when selecting a risk
characterization methodology.
Some companies have developed different risk characterization protocols for different divisions, or have
required that risk characterization be conducted periodically for all or a defined set of products.
Review the science expertise of staff within and outside your company to learn of new trends in the field of risk
characterization.
Developing a checklist of questions about product stewardship to be answered at each stage of product
development can be helpful.
46
Management Practice #6: Risk-management System
Note: Chapter 4 includes a Risk Characterization and Management Aid which provides detailed information on
the risk management process.

Work with manufacturing and HSE staff to identify measures to reduce product risk. Focus attention on
potential areas of high risk, and challenge staff to seek constant product improvement.
Consideration: Risk management can be a team effort, including R&D and other experts within your company,
such as marketing and sales, distribution, HSE, and legal staff.
Develop a checklist of questions about product stewardship to be answered at each stage of product
development.
Establish technical guidelines for evaluating varying risk levels and selecting risk management actions. Where
possible, attempt to establish a consistent basis for risk related decisions.
Consideration: Maintain documents describing your Company’s Chemical Product Safety Program, which
provides guidelines and or standard operating instructions to those involved in managing product risk (e.g.,
packaging and labeling, communications, emergency procedures, etc.).
Develop a written protocol to evaluate products.
Documenting the analysis of risk management decisions and confirming the satisfactory completion of risk
management actions can be helpful. Document risk analyses in such a way that it protects trade secrets and
other proprietary information.
Consideration: Helpful methods for proper documentation include:

• Providing tools (e.g., computer-prompted recording systems) to minimize the effort required
to carry out this step;
• Limiting documentation requirements to essential information needs; and
• Assessing documentation as part of an audit procedure.
Consider conducting periodic multi-disciplinary product safety reviews.
47
Management Practice #7: Product and Process Design and Improvement

During product development, beginning with product conceptualization, focus on identifying and developing
ideas on how to reduce health, safety, and environmental impacts.
Consider training R&D staff to design products and processes in accordance with a set of general principles to
underscore product stewardship objectives.
Consideration: Some companies have a team that reviews all raw materials and formulations for compliance
with their company's product stewardship guidelines.
Consider convening multi-disciplinary project teams and solicit input from all key staff functions to focus on
potential improvements and to check that product and process improvements are based on a perspective
including all the stages of a product's life.
Considerations:
Meet with marketing and sales staff to keep abreast of health, safety and environmental issues. Marketing and
sales staff can provide information from customers on product design and improvement needs. Information
from suppliers' products might also be considered.
Interact with manufacturing and HSE staff at significant points in product development. For current products,
marketing and sales or distribution staff can provide feedback on customer requirements for handling, use, and
disposal to those staff involved with product modifications.
Document technical issues early in the development of a new product or process.
Consideration: Document technical issues in a new product or process by requiring completion of a Product
Safety Questionnaire. Questions might cover health and physical hazards of materials used in the process,
availability of toxicity data, handling precautions, description of process waste and recycle streams, packaging
and labeling requirements, and applicable regulatory issues.
Developing a checklist of questions about product stewardship to be answered at each stage of product
development can be helpful.
Help purchasing staff develop new criteria or principles for purchasing. For example, R&D staff may be asked
to get involved in developing new company standards for product and container design to attempt to minimize
adverse impacts.
Consider conducting a lifecycle evaluation of products to identify potential risk reduction opportunities.
Develop a written protocol to evaluate products.
Practice product improvement through understanding. Consider the "big picture" rather than treating a product
in a "black box." It will help you avoid reactive solutions by taking an integrated approach to solving product
concerns.
48
Management Practice #8: Employee Education and Product Use Feedback
Activities to Consider:
Review proposed and existing employee training programs for product risk characterization and management
information. Check that the information presented is accurate and thorough and meets regulatory standards.
Offer R&D expertise to trainers to assist in the design of training programs for employees with customer
contact, especially marketing and sales staff. Provide relevant product information to trainers on product risk
management techniques, such as safe use and disposal practices.
Develop mechanisms and opportunities for product feedback from employees who have contact with customers.
Considerations:
Marketing and sales staff need to know what product information is useful to gather from customers so they can
relay it back to the proper staff. If involved with training, solicit customer feedback on product use from
marketing and sales staff. Meet with HSE and marketing and sales staff. Use these meetings as an opportunity
to educate other departments on products, to determine further information needs, and to keep informed about
customer feedback. Employees who have contact with customers may be providing feedback through their own
organizations that you may not be linked to.
Consider documenting information on customers' experiences with your company's products. It may help you
refine your information on product risk characterizations and serve as a focal point for improving the product in
the future.
Consideration: Tthe documentation of product feedback is part of the overall risk management process, in that
it 'closes the loop.'
Provide assistance to marketing and sales staff who are responding to questions from customers about product
uses, safety practices, reasonably foreseeable exposures, and appropriate disposal methods, etc.
Hold special meetings with customers to collect feedback on products. If you visit customer facilities, try
monitoring product use and provide feedback on misuse to your company. Have a set of questions that are
asked with each customer contact. Practice product improvement through understanding. Consider the "big
picture", rather than treating a product in a "black box." It will help you avoid reactive solutions by taking an
integrated approach to solving product concerns.
Assist in efforts to work with distributors to develop use methods that reduce the risk of adverse impacts.
49
Management Practice #11: Distributors
Management Practice #12: Customers and Other Direct Product Receivers
Assist in efforts to work with distributors and customers to develop use methods that reduce the risk of adverse
impacts.
Help marketing and sales staff maintain and promote customer relationships. Working with customers is a good
business practice, and it can occur both at the local level and on a company scale.
Considerations:
Communications with customers has two essential elements: they are ongoing, and they are interactive. Talking
is not enough. Communication is more effective when you listen and incorporate a means for response. This is
also an opportunity to learn of desirable product design improvements that build value and decrease health,
safety, and environmental risks of products
Assist marketing and sales in helping customers understand product stewardship concepts and requirements.
Consider educating customers and other direct product receivers about product stewardship and what it means
to them. Methods vary, and so does the level of detail.
Consider maintaining an ongoing relationship with customers to determine their needs for supplemental safety
information and expertise; to encourage their communication of needs; and to promote the sharing of HSE
knowledge. Work with distribution, HSE, and R&D staff, and others to fill their needs for additional
information and expertise. Customers usually appreciate the expertise of the manufacturer.
Consideration: Product stewardship encourages ongoing exchange and sharing of information between
American Chemistry Council members and the companies that buy, handle, or use their products.
Develop a system with HSE and marketing and sales staff for tracking customer input about emerging trends or
potential product problems.
Troubleshoot and provide early warning of potential problems, either directly or by providing input to others.
Based on your assessment of customers' capabilities and product hazards, consider arranging meetings with
customers requiring special attention. It can be helpful to include HSE and your counterparts within product
receiver companies in the meetings.
Considerations:
Have technical staff assist customers when problems arise with the Company’s product. Commensurate with
risk, take the initiative and contact customers first to troubleshoot and prevent problems before they occur.
!t is helpful to discuss any concerns with legal counsel prior to your meeting. Meetings with customers need not
be seen as negative or confrontational, but rather as an effort to guide your customer toward solving an
identified problem.
50
Commensurate with product risks, work with other job functions to screen customers' expertise and capabilities
in safe handling, use, and disposal of products.
Considerations:
Consider working with customers to determine corrective action requirements, and to develop a corrective
action plan for the customer.
Consider withholding products from those who are unwilling or unable to implement appropriate safety
measures.
Regard customer assistance and education as a risk management technique.
Where potential problem areas have been identified, it would be prudent to discuss your concerns with legal
counsel prior to your offering assistance.
Particular challenges arise in situations where quick decisions may be required to terminate a relationship. The
company's ability to meet these challenges will depend, in large part, on the soundness of a plan jointly
developed by legal counsel with marketing and sales staff at the outset. and their close collaboration thereafter.
Work with marketing and sales in product recall. Product recall is 'a risk management activity that requires
extensive customer relations activities and cooperation from distributors.
Consideration: Develop formal procedures that address the mechanical aspects and analytic procedures
required to make the recall decision. These analyses can include collecting and reviewing customers'
complaints and conducting internal product evaluations.
Monitor the way products are used and communicate feedback on product misuse to HSE, or appropriate staff.
Work with marketing and sales staff to assess customer satisfaction and/or problems with our products, through
direct and/or indirect contact. Marketing and sales staff may notice a new use or misuse of a product while
visiting or speaking with customers. This information may be important to your HSE staff and should be
relayed to them.
51
Health, Safety and Environmental
Effective product stewardship relies on the expertise and active participation of your company's health, safety
and environmental (HSE) staff. Very often, companies will divide these responsibilities into more than one
position. But under product stewardship, these responsibilities are closely related, and involve similar tasks and
activities. Together, job functions with these responsibilities must understand the health, safety, and
environmental risks of every product. This includes understanding not only the intrinsic hazards of the product,
but also the various ways that users can be exposed to these hazards, and understanding the products' effects on
water, air, and ecosystems.
Some companies divide the responsibility for HSE tasks further within specific business divisions or product
categories that house their own dedicated research and development (R&D), HSE, and marketing and sales
functions. The business groups identify and fulfill their own information needs. For specialized information
related to health, safety, and environmental issues, some companies have centralized staff that provide
toxicology, epidemiology, and industrial hygiene information.
The box above indicates which management practices HSE staff may be involved with. Although no suggested
activities are included for Management Practice #3: Resources, this management practice is applicable to all job
functions because all job functions would need to be sure they have adequate resources to implement product
stewardship. Other job functions often conduct the activities described on the following pages, depending on the
company's organization.
1: Leadership
Measurement
3: Resources X
Environmental
Information
and
Improvement
Product Use
Feedback
9: Contract Manufacturers X
10: Suppliers X
11: Distributors X
Product Receivers
52

Identify and gather the information as necessary to adequately characterize and manage health, safety, and
environmental aspects of product risks.
Considerations:
Work with R&D staff and with other job functions in the company to create or compile HSE information. It can
be helpful to delineate staff responsibilities to prevent duplicating effort and creating data gaps. Collect
information on the types of product tests and data that are needed for health, safety and environmental product
review.
Collect information on the types of product tests and data that are needed for HSE product review.
Stay abreast of new developments in the health, safety, and environmental fields by attending conferences and
meetings, reading journals, and talking with peers inside and outside the company.
Review how HSE staff in your company stay current on information related to their field, and devise a means of
organizing and making available the literature they rely on. Help keep staff aware of important trends or
developments. Consider computerized databases for managing HSE information. In some companies, the HSE
department might develop a centralized information resource.
Considerations:
MSDSs can provide the foundation for developing a database that can be easily updated to incorporate
customer and scientific input. If might be necessary to agree upon what information is shared from the
databases for evaluation as well as risk management activities. Some portions of protected databases may be
shared selectively.
Consider adapting your existing system for maintaining product HSE information to meet product stewardship
goals. If there is a single, consistent system already in place that covers the full range of your products, the task
is relatively straightforward. However, a number of companies organize HSE information to reflect a
decentralized structure, maintaining it by division or product category.
Review HSE information for compliance with regulatory reporting, labeling and disclosure requirements (e.g.,
OSHA MSDSs and labels, TSCA Section 8 reports, FIFRA labeling, etc.). Because your company's product
HSE information may be the basis for complying with certain legal requirements, the information that is used
internally needs to be consistent with information distributed outside under OSHA, SARA, and other require-
ments.
Help prepare HSE information to include in product communication materials, such as MSDSs, product
bulletins, product manuals, and safety wall charts.
Considerations:
Communications materials derived from HSE information may be reviewed by communications staff for clarity
and consistency.
53
Update HSE information as necessary. The process for updating information on a specific product may include
informal compilation and distribution of new information, as well as periodic formal product safety reviews, as
warranted by the potential risk associated with the product.
Considerations:
Your company may have a system in place for reviewing and updating product HSE information. If so, look at
this system for ways it could be improved. Special attention might be paid to the following issues:
• Applicability to new products (e.g., is information
assembled early in !he R&D process?);
• Accessibility (e.g., is information readily available and
easily understood?);
• Breadth (e.g., is the full spectrum of end use adequately reflected, and are reasonably
foreseeable misuses treated in sufficient detail?); and
• Confidentiality (e.g., are document control procedures
adequate and followed?).
Consider developing guidance for evaluating the significance of new HSE information. New HSE information
may justify revising an MSDS, preparing a new warning, or even implementing a product recall, and previously
prepared guidance can help instruct when such an activity is needed, and may limit inefficient case-by-case
responses.
54
Possible Activities to Consider

Meet with other job functions to understand their requirements for HSE data for characterizing product risks.
Consideration
Other areas within the company may need support to conduct product risk assessments, such as business units
or divisions, by providing relevant health, safety, and environmental hazards information and exposure data.
Assist in efforts to work with customers to develop use methods that reduce the risk of adverse impacts to users.
Consider establishing processes for product risk characterization and periodic reevaluation. It can be helpful to
develop a system for regularly submitting existing and new information to R&D and manufacturing staff
regarding potential health, safety, and environmental hazards and exposures to the company's products.
Consider developing databases to support your company's growing risk characterization needs.
Review product risk information for consistency with MSDSs. Product risk characterization information may
provide the basis for complying with certain legal requirements, e.g., product MSDS, employee training, etc.
Information that is used internally needs to be consistent with information disseminated outside under OSHA,
SARA, and other requirements.
Evaluate the adequacy of your information to determine whether more testing for new or existing products is
needed.
55
Management Practice #6: Risk-Management System
Note: Chapter 4 includes a Risk Characterization and Management Aid, which provide detailed information on
the risk management process.

Help define your company's risk management process. HSE staff help define risk management and integrate
manufacturing and health, safety, and environmental issues, including industrial hygiene, product safety, and
environmental protection considerations.
Consideration:
Risk management is a team effort, and the skills of these professionals can be combined with yours and with
other experts' within your company, such as R&D, manufacturing, and marketing and sales staff.
Identify, document, and undertake risk management initiatives appropriate to product risks. For example,
consider developing industrial hygiene sampling protocols for measuring exposures to potentially hazardous
agents or conduct agent tracking.
Considerations:
Coordinate with manufacturing staff. Each technical and operations staff person will have a role in developing,
implementing, and documenting risk management procedures. You may want to meet with them to define your
respective roles.
Care should be taken to document risk management procedures as they are important in responding to
information requests from outside the company and in defending lawsuits.
One company maintains a set of loose-leaf binders containing its comprehensive Chemical Product Safety
Policy. Each section outlines company procedures on specific subjects (e.g., packaging and labeling,
communications, emergency procedures, etc.), and provides standard operating instructions to those involved
in managing product risk
Advise and consult with other areas such as marketing and sales, distribution, and purchasing and supply staff
regarding regulatory requirements, and seek their help in gathering helpful HSE information as they conduct
their own job responsibilities.
Consideration:
Brief relevant experts in your organization (e.g., toxicology, medical, etc.) on product stewardship and enlist
their contribution.
Consider establishing task forces with R&D and manufacturing staff to focus on areas of special concern.
Consideration:
Consider establishing exposure limits and guidelines or consistent risk threshold criteria.
56
Determining the legal reporting requirements for a product is important, as well as evaluating compliance with
legislative mandates. Work with legal counsel, manufacturing, and other areas to develop and execute strategies
to address these requirements. Investigate health and safety related incidents and initiate appropriate corrective
actions. This will help identify, evaluate, and control hazards and exposures.
Consider a wide variety of methods for reviewing and reducing product risks. Work with management, R&D,
manufacturing, and legal staff to eliminate product risks that are considered unacceptable or unmanageable.
Discuss risk management techniques with HSE professionals in other organizations.
Develop computer databases to integrate risk management information systems. Microcomputer power and
networking capabilities make it increasingly possible to support growing information needs.
Consideration:
In large production facilities, the ability to share information may require linkages with existing computer
systems.
Consider conducting periodic multidisciplinary product safety reviews.
57

Consider meeting with other job functions to establish a method for incorporating your insights into product
design modifications and improvements.
Consideration:
Some companies document technical issues regarding a new product by requiring completion of a Product
Safety Questionnaire, which covers health, safety, and environmental hazards of materials used in the
production process; availability of toxicity data; handling precautions; description of process waste and
recycling streams; packaging and labeling requirements; and applicable regulatory issues. The questionnaire,
which may be adapted to specific situations, serves as a starting point for later communications.
Participate in decision-making regarding changes to existing and new products or processes by reviewing and
commenting on modification proposals. This will help decision-making properly reflect your health, safety, and
environmental concerns.
Help R&D and manufacturing staff understand health, safety, and environmental issues. In many cases, it is
only necessary that product designers and manufacturers have a thorough and adequate knowledge of the
requirements. Interaction between R&D, manufacturing, and HSE staff can be helpful at all phases of product
development. R&D and manufacturing staff may ask HSE staff for advice about potential health, safety, and
environmental risks when considering the manufacture, use, and disposal of products.
58

Review proposed and existing employee training programs for product HSE information. Check that the
information presented is accurate and thorough and meets regulatory standards.
Consider offering product HSE expertise to trainers to assist in the design of training programs for employees
with customer contact, especially marketing and sales.
Provide relevant product information to trainers on product risks, use, and disposal that employees may read
when in contact with customers.
Developing and maintaining training materials can be helpful. Training materials can be developed to meet
specific training needs and be adaptable so that they lend themselves to periodic revision. They can be used to
educate a broad range of employees who have direct customer contact and who may come from a variety of
backgrounds.
Consideration: Video, text, and role-playing might all be considered as options, depending on the product and
employee you wish to train.
Participate in employee training, where appropriate. Educate and train employees who have customer contact
about the products they represent.
Consideration: One way that companies deal with this practice is to have the product safety department
provide training in product hazards and regulations to distribution, marketing and sales, and communications
staff.
Recognize that product stewardship may require revising job descriptions, adding new skills, and, therefore,
additional training.
Considerations:
Product stewardship can build on training efforts that are already in place in your company, and you may find
that many of these programs lend themselves to adaptation to include product stewardship information.
Product stewardship calls for two types of training and education. One concentrates on ongoing efforts to
improve marketing and sales employees' understanding of product characteristics and performance, and the
other focuses on educating employees about product stewardship and how to implement it
Develop mechanisms and opportunities for feedback from employees who have contact with customers.
Considerations:
Seek feedback from employees during training programs. Your training sessions should be designed so that
employees have an opportunity to educate you.
Employees, such as marketing or sales people, may have contact with customer associations or organizations
that you are not linked to, and may be able to provide helpful feedback from these groups.
59
Management Practice #9: Contract Manufacturers

Offer expertise in the health and safety aspects of designing and implementing contract manufacturer evaluation
programs.
Consider reviewing proposed and/or existing contract manufacturer evaluation programs to determine if HSE
criteria are present and if they are adequate to assess a contract manufacturer's operations and procedures.
Modify the existing system if necessary.
Participate in the company's selection of contract manufacturers by reviewing its HSE practices related to the
service under contract. Use the results of the review to influence contract manufacturer selection.
Consideration:
Checklists and other survey instruments may be helpful to evaluate potential contract manufacturers. Topics
could include:
• Safety and health procedures
• Compliance with applicable laws and regulations
• Process and operating safety procedures
• Fire safety programs
• Occupational medical programs
• Distribution safety procedures
• Environmental protection
• Spill prevention and control
• Solid and hazardous waste management
• Emergency response procedures
Consider serving as a resource to contract manufacturers needing additional expertise in health, safety, and
environmental matters. Your company may have an outreach program which focuses on quality control/quality
assurance issues, but can easily be modified to include health, safety, and environmental concerns.
Consideration:
A written policy on contractors within a company's Responsible Care initiative may be helpful. Under this
approach, both management and legal counsel review all contracts to address health, safety, and environmental
concerns.
Commensurate with the risk level of products, on-site visits by HSE personnel to monitor adherence to contract
requirements may be appropriate.
60
Management Practice #10: Suppliers

Help evaluate supplier performance in providing MSDSs, labels, and any other useful HSE information.
Suppliers who demonstrate their ability to develop and share HSE information on their products could be
considered preferred suppliers by purchasing staff.
Check that MSDSs are consistent with product risk information. Also, information developed for OSHA,
SARA, and other requirements needs to be consistent with information disseminated to others.
Help prepare HSE information for distributors and customers. HSE information for distributors can take many
forms, including labels and MSDSs. Additional forms of information may include product bulletins, product
manuals, and safety wall charts.
Considerations:
A company may use some or all of these forms of communication depending upon a product's hazards.
Some companies offer supplier workshops or conferences to discuss health, safety, and environmental issues
related to their products.
Commensurate with product risk, consider participating in visits to suppliers, distributors, and customers to
share your expertise in evaluating and adhering to proper HSE practices. These visits will also allow you to
learn from them how they go about adhering to proper HSE practices.
Review the supplier and distributor selection process and establish HSE criteria for use in supplier and
distributor selection. Help employees with customer contact develop information to explain any new criteria
used in selection and subsequent evaluations.
Consideration: You might consider developing guidance materials to help suppliers and distributors meet new
company standards.
61
Purchasing and Supply
Purchasing agents fulfill an important outreach role of product stewardship. They work with suppliers to bring
their company quality products as well as the information needed for safe storage, handling, use, and disposal.
Purchasing agents also may channel this product information to those who need it for process safety, product
design, employee education, and various other purposes. Finally, purchasing agents may promote supplier
responsiveness to your company's health, safety, and environmental (HSE) requirements by urging adoption of
Responsible Care policies and practices. Thus, product stewardship creates an important role for purchasing in
integrating these initiatives into conventional procurement responsibilities.
1: Leadership
Measurement
3: Resources X
Environmental
Information
7: Product and Process Design
and
Improvement
8: Employee Education arms
Product Use
Feedback
10: Suppliers X
11: Distributors
Product
Receivers
The box at the right indicates practices the purchasing and supply staff may be involved with. However,
activities described on the following pages are related only to Management Practice #10. It maybe helpful for
purchasing and supply staff to read the other sections of Chapter 2 that describe activities related to their job
function. Other job functions often conduct the activities on the following pages as well, depending on the
company's organization.
62
Management Practice # 10: Suppliers

Consider developing a procurement policy and educate existing suppliers about product stewardship and
Responsible Care. Work with HSE staff to educate suppliers about any new criteria used in supplier selection
and performance evaluations. Explain the shared benefits that will be derived from their cooperation with
product stewardship goals. Consider providing guidance materials to help suppliers meet the new standards.
Considerations:
New policy criteria may include new standards for product and container design to help minimize product
hazards; new requirements for more detailed HSE information; or changes regarding the quantities to be
ordered and the scheduling of shipments to minimize safety problems during transport and onsite storage.
Some companies have a supplier outreach program which, in the past, may have focused on quality control
quality assurance, but it can easily be modified to deal with health, safety, and environmental concerns.
One company distributes a brochure called "Supplier Quality Improvement Process" that describes commodity
action teams, which are multi-company, multi-disciplinary teams that identify reliable suppliers and encourage
continuous improvement through long-term business alliances. Such a brochure could easily be adapted to
include discussion of product stewardship.
Develop procurement contract provisions with legal counsel that require suppliers to meet regulatory and
company-wide standards and specifications. This will encourage suppliers to provide MSDSs and other HSE
information requested. For example, you may be asked to secure additional safety expertise and services from
suppliers.
Develop procedures to evaluate products shipped to your company to be sure they comply with the contract
terms. A procedure could be developed for refusing to accept products not in compliance and for consultation
with legal counsel in the event of non-compliance. You might consider collecting information on suppliers, and
their products, and procedures for determining if their products meet company specifications and standards.
Considerations:
In addition to traditional product inspections for quality, your company may choose to evaluate supplier
performance in providing MSDSs, labels, and any other useful HSE information.
Establishing a system for periodic review of supplier performance can be helpful. You may prioritize your
review of supplier performance by product hazard, as a way of assuring that suppliers' products, product
handling, and product information meet regulatory and company qualify standards. Manufacturing staff may
play a key role by working with you to qualify vendors.
Be sensitive that suppliers may consider your actions intrusive or that you are "micro-managing" their
operations and distribution of MSDSs and other HSE information.
63
Implementing a system to record and share supplier information with HSE staff, managers, and others who
might need to know. Your company may have a system in place that can be adapted. Consider similar
procedures for products made and used by your own company or its subsidiaries.
Considerations:
Finding out who is in charge of the existing practices at the supply company can be helpful. Your company may
deal with suppliers on an ad hoc or a routine basis, and responsibilities for dealing with these parties may be
dispersed or centralized. Finding out what the existing practices are can help you evaluate and modify the
supplier's system to fulfill the goals of product stewardship.
A useful approach is to construct a matrix to organize information on the people and practices of each product
supplier. Then, gather information for each box in the matrix - e.g., who sets policies for the supply company,
who has contact with the purchasing agent, who conducts quality control.
Forecast problems and put solutions into place before they occur. Dealing with problems after they arise may be
less effective and efficient than taking a preventive approach.
64
Manufacturing
Manufacturing has an important role in product stewardship by helping design the process, providing useful
data on product characteristics and handling methods, and serving as one source for potential exposure data.
Manufacturing often develops information through experiences and regulatory requirements. This information
should be recorded, used, and shared with the rest of the company and with customers, as appropriate.
Manufacturing's role is key toward maintaining quality and product integrity through the manufacturing process
and in training employees to practice safe handling. They will also be critical to determining requirements for
contract manufacturers.
The box at the right indicates which management practices manufacturing staff may be involved with. Although
no suggested activities are included for Management Practice #3: Resources, this management practice is
implement product stewardship. Other job functions often conduct the activities described on the following
pages, depending on the company's organization.
1: Leadership
Measurement
3: Resources X
Environmental
Information
and
Improvement
Product Use
Feedback
10: Suppliers
11: Distributors
Product
Receivers
65

Use your technical experience and knowledge of regulatory requirements to develop health, safety and
environmental (HSE) information.
Consideration: Information should be recorded, used, and shared with the rest of the company and with
customers, as appropriate.
Consider establishing product standards for all measurable parameters, including averages and ranges for
normal process variation.
Initiate discussion with R&D staff to improve your understanding of product risk management practices.
Consideration: Provide support to product stewards and their teams as they develop hazard identification,
product toxicity assessment, exposure assessment, risk management and risk communication programs.
Incorporate your knowledge of current products and processes when conducting periodic product risk
reevaluations. A reevaluation process might be considered whenever a process change is made.
Before adopting product specifications or process changes, consider how they may alter product properties,
utility, or quality.
Record the basis for technical decisions made in process design and provide support in reviewing the basis for
decisions when conducting product reevaluation.
66

Get involved early in product and process design efforts and communicate your concerns based on your
experience of past and ongoing operations to help direct manufacturing efforts. It is helpful if product designers
have a thorough knowledge of manufacturing operations. Interact with R&D and HSE staff at significant points
in the development of a product. Technical solutions can only be found when product-related expectations are
clearly communicated among staff.
Consideration:
Consider product stewardship training for new manufacturing staff. Some companies use a mentor system to
train new employees in the company's design practices. For example, a new employee would be paired with a
more senior manufacturing staff, who would review process designs and modifications in terms of product
stewardship.
Establish a task force to deal with high profile concerns.
Consider potential health, safety, and environmental impacts as important criteria when selecting production
equipment and determining the best practices to manufacture the product.
Consideration:
Inspect and maintain product-manufacturing operations so that production equipment will operate as designed
under original specifications and do not pose health, safety, and environmental risks by the production of
unanticipated by-products or contaminants.
Evaluate the necessity of each by-product and process waste. Look for product or process modifications to
reduce or eliminate by-products and wastes.
Considerations:
Consider establishing a review system for evaluating the net impact of proposed product modifications.
Waste reduction programs might systematically analyze each process waste. For example, a review program
could routinely scrutinize opportunities to reduce energy consumption, recycle byproducts, or reduce
environmental impacts resulting from processing.
Consider the big picture when seeking solutions to product design issues. Treating a module of the production
process may lead to a sub optimal approach for the entire process. If you work from a fundamental
understanding of underlying processes, more substantial improvements may be possible. Encourage insights and
suggestions from co-workers for product changes. Work closely with R&D staff to explore product alternatives.
Consideration: Develop an incentive system for employee suggestions for product improvements. Work with
management to put the system in place.
67
Solicit customer feedback on product use from marketing and sales staff. Channel customer feedback from
marketing and sales staff to those involved in modifying products and manufacturing processes. Marketing and
sales staff can provide feedback on customers' requirements for handling, use, and disposal.
Consideration: Some companies have committees for employees with customer contact, such as quality action
teams, which can be used as a conduit for feedback on product modifications.
Incorporate health, safety, and environmental issues associated with the product in product design reviews, in
evaluation of customer uses, and in development of disposal options.
Consider health, safety, and environmental impacts on your own process and on end product composition
resulting from otherwise "insignificant" changes in processes.
Review specifications to consider whether minor components that could pose health, safety, or environmental
impacts are included in the specifications.
68

Assist in developing and/or conducting ongoing training programs for employees with customer contact,
especially marketing and sales staff. Marketing and sales staff need to know what product information is useful
to gather from customers so they can relay it back to the proper staff. Check that staff receive training in proper
product handling, use, recycling, and disposal.
Considerations:
Training in product hazards and regulations may be given to manufacturing staff. The training could be
developed with help from HSE and communications staff.
This initiative may in some cases require revisiting job descriptions of those with customer contact, and adding
new skills to help staff recognize customer information that is useful to product stewardship.
Two types of training and education come to mind. One concentrates on ongoing efforts to improve employees'
understanding of product characteristics and risk management practices, and the other focuses on educating
employees about product stewardship and how to implement it.
If may be helpful to develop a system for documenting employee education and training efforts. Attempt to make
the efforts consistent within the company for coordination purposes.
Launch an employee-oriented product stewardship communications effort. Although product stewardship is a

new name, and it may represent some broader concepts, its underlying disciplines and goals are hardly news to
manufacturing staff. By stressing what's already in place in your company, you reinforce long-standing commit-
ments and help establish product stewardship as part of your company procedures.
Consideration:
Consider an internal newsletter called "Product Safety Management" as a vehicle for communicating product
stewardship issues throughout the company. Work with communications staff to help adapt existing
communication tools such as employee newsletters to inform employees.
Consider sharing HSE expertise present in manufacturing with customers.
Consideration:
Skills developed in handling, transferring, and packaging, and knowledge about materials used in equipment
are examples of valuable information that could be passed on to customers.
69

Provide helpful manufacturing information to those working with contract manufacturers (e.g., purchasing or
marketing and sales staff). This may help them understand what things to look for when working with contract
manufacturers.
Assist other staff in educating contract manufacturers about your company's product HSE operating
requirements and how they affect your manufacturing operations and the selection of contract manufacturers.
Provide contract manufacturers with HSE standards and procedures developed for particular product processes.
Meet in person with priority contract manufacturers:
Help review existing contract manufacturers' capabilities and performance in terms of their health, safety, and
environmental performance. The results of this review can be helpful in the selection of contract manufacturers.
You may review how they evaluate their operations, procedures, and overall performance, and confer with
contract manufacturers to confirm that they will be cooperative with your company on various health, safety,
and environmental matters for the process or service under contract.
Considerations:
Your company may have a contractor review program, which can easily be modified to include health, safety,
and environmental concerns, if it does not already do so.
Consider including review of procedures and adherence to HSE standards related to the contracted service as a
requirement in contracts with manufacturers.
Meet with contract manufacturers where such a meeting is warranted by product hazard, volume, exposure, and
contractor safety record.
Establish and implement guidelines with legal counsel and marketing and sales staff for new contracts,
managing existing contracts, and contractor selection processes. Responsibility for contract manufacturers may
not reside in a single staff or business area, and implementation may require a team effort.
Provide HSE Information to contract manufacturers and, according to product risk, consider providing
additional expertise.
70
Marketing and Sales
Marketing and sales staff are a critical conduit to the customers whose needs drive your business. As a result of
their position, marketing and sales staff are able to provide information about market forces, industry trends,
and customer concerns and requirements.
Since the scope of product stewardship extends through the product lifecycle, customers and distributors have a
very important role in safe use of our products throughout the chain of use. Marketing and sales staff are the key
interface with these downstream receivers.
1: Leadership
Measurement
3: Resources X
Environmental
Information
7.: Product and Process Design X
and
Improvement
Product Use
Feedback
10: Suppliers
11: Distributors X
Product
Receivers
In addition to their traditional role, marketing and sales will serve as an important link between senior
management and distributors and customers who handle, use, and dispose of your products. Marketing and sales
staff may distribute health, safety, and environmental (HSE) information, collect product feedback, or document
instances of product misuse. In proportion to the risk of the product, they also may work with customers to help
them understand safe handling practices. These relationships with distributors and customers are very important
for successful product stewardship, and marketing and sales staff have a strategic role in achieving them.
The box above indicates which management practices marketing and sales staff may be involved with.
Although no suggested activities are included for Management Practice #3: Resources, this management
practice is applicable to all job functions, because all job functions would need to be sure they have adequate
resources to implement product stewardship. Other job functions often conduct the activities described on the
following pages, depending on the company's organization.
71
Develop positive and interactive relationships with customers and distributors so that the information gathering
system is both systematic and effective.
Consideration:
Promote activities that identify and produce information needed by customers and distributors for proper
handling, use, and disposal of products.
Gather useful HSE information from your customers, distributors, and other sources in the marketplace. This
may involve developing new kinds of relationships with customers and distributors, and educating them about
product stewardship and Responsible Care!
Considerations:
Provide the information to other job functions involved with this management practice. You may participate in
HSE information discussions to promote your customers and distributors needs.
Types of information from customers and distributors that may be useful include safety problems they may have
encountered in handling, use, or disposal of your products, including adverse effects, impacts, actual problems,
and near misses.
Where your products may have many different applications, and different types of reasonably foreseeable
exposures, information-gathering efforts should focus on trying to identify sufficient market information to
adequately characterize the risks associated with known applications and reasonably foreseeable exposures.
Identify areas where additional information would assist customers.
Gather information on potential customer misuse or unsafe practice
72
Management Practice #6: Risk Management System
Note: Chapter 4 includes a Risk Characterization and Management Aid, which provides
detailed information on the risk characterization and management process.

Participate in regular product reviews and provide your insights on customer applications.
Coordinate with research and development (R&D) staff to improve your understanding of
product risk characterization issues, so that you identify and relay useful information to
R&D staff.
Ask customers and distributors for feedback. Your customers are your single most
valuable source of practical information about product performance and product use and
thus about product risk.
Considerations:
While visiting customers, you may discover useful information for R&D staff, such as
new uses for the company's products; misuse; or substantial increases in the volume of
products stored. Information such as this would help R&D reevaluate product risk
characterization for these products.
Consider directly contacting customer HSE staff whose viewpoints may differ from those
of your usual customer contacts and whose insights could be very valuable.
Customer experience with your product may vary, especially if a product has many
different uses and potential exposures.
Reevaluate marketing materials as new HSE information is gathered from customers,

distributors, suppliers and other sources, and as risk management practices are revised.
Have your HSE and legal departments review marketing and communication materials
for accuracy, consistency, and clarity. Communications materials must comply with legal
requirements (e.g., MSDSs, labels, warnings, and use instructions).
71
Ask customers and distributors about their needs for additional information and
guidance on proper product use or handling (e. g., their uncertainties of disposal
methods or their safety expertise, etc.).
Considerations:
Formal or informal methods can be used to gather information, such as interviews,
surveys, polls, focus groups, or informal conversation. Evaluating customer needs for
additional information requires tact, and it may be useful to secure their management's
approval before opening up a discussion. Distributors may benefit from your guidance on
how to provide information to their customers.
Ask customers and distributors about the following:
• Their needs for information (e.g., MSDSs, labels, or other formats), and,
commensurate with product risks, training, special services, or equipment to
improve safety in handling, use, and disposal of products.
• Special knowledge they have independently developed for handling, use,

and disposal of your products that would be helpful to other customers and
distributors, provided that such information is not proprietary and is voluntarily
disclosed.
Assist in tracking products. You can help provide information to HSE staff on product
and hazardous agent tracking. As you work with customers, listen for information that is
useful to other departments in your company.
72

Gather and evaluate feedback on customer's and distributor's suggestions for improvement in product design
relating to handling, use, and disposal and provide it to those involved with future product modifications.
Appropriate improvements can only be made when product related expectations are clearly understood.
Consideration:
It may be helpful to gather information on customers' limitations in technical expertise and safety capability in
product handling, exposure, use, or disposal.
Hold meetings with customers to discuss product improvements under consideration.
Provide R&D staff with information on current and emerging customer concerns, requirements, and suggestions
for improving the product. You may help RED consider customer needs and market trends in making decisions
about product improvements.
Share HSE information with counterparts in other companies. The American Chemistry Council membership
network can provide you with resources for ideas and suggestions.
Identify new marketing opportunities -- and problems - arising from this management practice.
Consider public perceptions. The perceptions of the public are part of the environment in which you do
business; incorporation of public concerns into the design of products and processes may be no less a priority
than legal requirements.
73
Visit customer sites. Marketing and sales staff are the direct interface with customers and usually are the first to
visit the customer. These visits allow marketing and sales to observe customers' product application. Many
companies have developed Quality Partnerships with customers where these applications are discussed.
Request help from HSE and R&D staff to further your understanding of product uses, safety practices,
reasonably foreseeable exposures, and appropriate disposal methods. Gather and help evaluate product feedback
from customers and distributors concerning requirements for handling, use, and disposal, and provide it to those
involved with future product modifications.
Try to observe product use when visiting customer facilities and provide feedback on new uses and possible
product misuse to your company. In addition, inquire whether customers' employees are receiving and
understanding information and recommendations provided by your company with respect to product risks and
handling. Having a set of questions that are asked with each customer contact may be helpful.
Consideration: Commensurate with product risk, hold special meetings with customers to collect feedback on
products.
Consider setting up marketing and sales employee training in health, safety, and environmental concepts of
products as a basic job requirement, as part of new employee orientation. Repeat training at appropriate
intervals.
74
Consider developing a procedure for informing distributors about the Product Stewardship Code and how your
company is implementing the code.
Considerations:
If your program includes a product steward, this may be an opportunity to introduce him/her.
Companies may provide information to distributors but cannot assume responsibility for managing their
activities. Refer requests for technical interpretations to appropriate job functions in the company.
Maintain ongoing dialogue and relationships with distributors to determine their expertise and what additional
HSE information they may need.
Considerations:
Based on an assessment of distributors' capabilities and product hazards, consider meeting in person with
distributors requiring special attention. This could be an opportunity to outline product stewardship goals and
offer assistance.
Consider establishing and maintaining a mechanism for documenting distributor contact. This can help identify
useful information on common uses and potential misuses of products by distributors. A record can be kept of
actions to be taken as a result of distributor or customer feedback and problems identified.
Consider customer assistance and education a risk management technique.
Check that information from distributors is shared and kept current by communicating regularly with
distribution management and product stewardship related staff. Information from the distributor helps assess
customer satisfaction and/or problems with products.
Evaluate your marketing and product information materials given to distributors for clarity of information on
product hazards and procedures for proper handling, use, and disposal of products.
Considerations:
If may be helpful to have policies governing who is to receive which information and how often; who
disseminates information; who is to prepare and review product communications; and how often they are to be
updated.
HSE information for distributors can take many forms, including labels and MSDSs, product bulletins (usually
a short document that gives a general summary of the product, its uses, properties, hazards, and handling and
transportation requirements); product manuals (possibly an expanded form of the MSDS and product bulletin);
or safety wall charts (poster size publications for placement in the work areas where the product is used).
75
Commensurate with product risks, consider distributor's expertise and capabilities for proper handling, use, and
disposing of products. Consider working with distributors to determine corrective actions requirements, if any;
or developing a corrective action plan.
Considerations:
Consider terminating the business relationship with distributors who do not improve improper practices.
Consider sharing HSE information to improve safety in handling, use, and disposal of your products. You may
also develop a procedure for monitoring distributors' efforts to cooperate if warranted byproduct risk.
Involvement with distributors will vary commensurate with product risk and the capabilities of the distributors.
76

In proportion to product risks, consider customer's expertise and capabilities for safe handling, use, and disposal
of products.
Considerations:
Consider working with customers to determine corrective actions requirements for limiting risks and otherwise
achieving the health, safety and environmental objectives of product stewardship.
Consider terminating a business relationship with a distributor who does not make an effort to improve
improper practices that have been identified.
Consider developing a procedure for informing customers about the Product Stewardship Code and how your
company is implementing the code.
Considerations:
If your program includes a product steward, this may be an opportunity to introduce him or her.
Companies may provide information to customers but cannot assume responsibility for managing their
activities. Refer requests for interpretations of technical or risk information, or for judgments on the
appropriateness or risk consequences of their safety practices, to appropriate functions in the company.
It may be useful to schedule product stewardship briefing sessions with customers who may not need assistance
but who may appreciate your taking the time to keep them informed about your company's efforts.
Consider customer assistance and education a risk management technique.
Refer requests for additional information from customers to your product Steward or the appropriate person in
your company who can evaluate the information.
Consideration:
HSE information for customers can take many forms, including labels and MSDSs. Additional forms of
information may include: product bulletins (usually a short document that gives a general summary of the
product, its uses, properties, hazards, and handling and transportation requirements); product manuals
(possibly an expanded form of the MSDS and product bulletin); or safety wall charts (poster size publications
for placement in the work areas where the product is used). A company may use some or all of these forms of
communication.
Evaluate your marketing program and product information materials given to customers, including MSDSs,
labels, warnings, and proper use instructions to check that these contain clear and understandable information
about product hazards and procedures for proper handling, use, and disposal of products.
Consideration:
It may be helpful to have policies governing who is to receive which information and how often; who
disseminates information; who is to prepare and review product communications; and how often they are to be
updated.
77
Consider establishing a means of documenting unusual concerns. A record can be kept of actions to be taken as
a result of feedback collected or problems identified. You may need to determine whether customers are
addressing concerns.
Develop a system with HSE and R&D staff for tracking customer input about emerging trends or potential
product problems.
Assess customer satisfaction and/or problems with your products, through direct and/or indirect contact.
Develop an ongoing dialogue with customers to encourage their communication of needs and to share HSE
information.
Considerations:
Monitor product use and provide prompt feedback on product misuse to HSE staff, or other appropriate staff.
When visiting customer facilities, try to observe product use and provide feedback on new uses and possible
misuse to your company. In addition, inquire whether employees are receiving, understanding, and applying
information and recommendations provided by your company with respect to product risks and handling.
Consider having a set of questions that are asked with each customer contact.
Communications with customers has two essential elements: they are ongoing, and they are interactive. Talking
is not enough. Communications requires that you listen, so consider incorporating a means for response.
This also is an opportunity to learn of desirable product design improvement to build value and decreased HSE
impacts into the product, and relay this information to R&D and HSE staff.
Customers may be sensitive about information on safety experience that may have regulatory or liability
implications for their company; about process safety problems and independently developed safety expertise
that may be proprietary; and about your company soliciting information that may be objectionable to customer
management
Troubleshoot and provide early warning of potential problems, either directly or by providing input to others.
Based on your assessment of customers' capabilities and product hazards, consider arranging meetings with
customers requiring special attention. Where appropriate, include your HSE and R&D staff and their
counterparts within product receiver companies in the meetings.
Consideration:
You may have technical staff go to customers when problems arise, or contact customers first and troubleshoot
problems before they occur.
Get involved with product recall efforts. Product recall is a risk management activity that requires extensive
customer relation activities and cooperation from customers.
Consideration:
Some companies have developed procedures that address the mechanical aspects of recall.
Provide prompt feedback on identified product misuse to HSE staff, or other appropriate staff.
78
Distribution
Distribution staff serves an important function within your company because their job involves the safe
transportation of raw materials and products to, from, and within your company. For example, they may
determine proper product labeling, packaging, and mode of transportation of your company's products. For
more information on transportation safety, refer to American Chemistry Council’s Distribution Code.
Distribution staff may also work with and periodically review distributors. By working with distributors,
distribution staff may provide health, safety, and environmental product information or may visit the facility
and provide technical assistance on product handling. Distribution staff also performs an important function in
outreach to distributors with HSE information and programs.
The box at the right indicates which management practices distribution staff may be involved with. Although
suggested activities are not included for Management Practice #3: Resources, this management practice is
implement product stewardship. Other job functions often conduct the activities described on the following
pages, depending on the company's organization.
1: Leadership
Measurement
3: Resources X
4: Health, Safety, and
Environmental
Information
6: Risk-management System
7.' Product and Process Design
and
Improvement
8: Employee Education and
Product Use
Feedback
10: Suppliers X
11: Distributors X
Product
Receivers
79

Consider providing guidance and handling procedures to marketing and sales, HSE, manufacturing, and legal
staff for addressing and minimizing distribution risks in working with contract manufacturers.
Develop, with those primarily responsible for contract manufacturer relationships, procedures for
communicating and evaluating distribution modes and practices to help contract manufacturers store, package,
label, and transport materials in a manner that is consistent with sound practices.
80
Management Practice # 10: Suppliers

Assist purchasing and supply staff in educating suppliers about product stewardship. Help them understand
product stewardship issues related to safe handling and distribution of supplies, and the shared benefits of a
cooperative relationship with your company.
Reviewing existing supplier relationships with managers, purchasing and supply, and legal counsel can help
encourage compliance with the Responsible Care Distribution Code. This can help foster safe shipment of
materials from suppliers to plant locations.
Consider scheduling meetings with key suppliers to discuss any concerns. Foreseeing problems and putting
solutions in place before they occur can be helpful. Dealing with problems after they arise might be less
effective and efficient than a preventive approach.
Considerations:
Most companies have some sort of supplier outreach program, which can be modified to deal with distribution
concerns.
Involvement with suppliers will vary and depends directly on the product in question and the capabilities of the
suppliers.
Initiate interactions with purchasing and supply staff to help suppliers label, package, and transport materials
according to sound health, safety, and environmental principles.
81
Management Practice # 11: Distributors
Consider working with manufacturing and communications staff to develop and revise procedures and
information materials that address distribution risks. You could work with teammates to apply the procedures
to:
• Selection of transport modes

• Selection of transport routes
• Selection of carriers
• Specification of minimum requirements for containers
• Specification of operating practices and procedures
• Training of personnel
• Alteration of chemicals transported
• Emergency response preparedness
Implementing a quality control and quality assurance program can be helpful so that company products are
safely and promptly transported to distributors. Troubleshoot problems that may arise because of late shipments,
transportation accidents, or other problems.
Consideration:
Provide a list of safety requirements that the distributor is expected to meet.
Schedule meetings with major distributors. Meetings could help you outline product stewardship goals and offer
assistance where potential problem areas have been identified. You might assess the product hazards and
capabilities of the distributors and consider meeting with those requiring special attention.
Consideration:
Many distributors fully share the American Chemistry Council’s concerns about responsible manufacturing,
handling, use, and disposal of chemical products and for many, product stewardship will not necessarily
change relationships with distributors.
Distribution staff can work jointly with manufacturing and legal counsel and with marketing and sales staff to
prepare a procedure for handling product recalls situations. Product recall is a risk management activity that
requires cooperation from all distributors.
Coordinate with staff involved with future product modifications. It may be helpful to these staff persons if you
can provide feedback on distributors' requirements for handling, use, and disposal.
82
Product Steward
Product stewardship affects many employees in your company and requires many different job functions, levels,
divisions, and departments to work together for successful implementation of product stewardship programs.
For these reasons, your company may decide to create the position of "Product Steward" to oversee and
coordinate the implementation of the product stewardship program.
For some companies with a centralized structure, it may be easier to create a single and central product steward
position with the authority to implement Product Stewardship Management Practices. This one person would be
involved with all phases of implementing the initiative, including providing leadership, accountability, and the
ongoing interaction and follow-up that product stewardship demands.
Another option could be to form a centralized product stewardship committee composed of senior managers
from each department within the company, who would be involved with implementing product stewardship
within each of their respective departments. For a more decentralized corporate structure, a company may have
a product steward position at every facility or for each of its products or product lines.
Designating the position of product steward is by no means the only way the Product Stewardship Code may be
implemented. Your company's structure and culture may dictate another approach, although it may be helpful to
clearly define product stewardship responsibilities.
Depending upon the company, both the role and the focus of a product steward will vary greatly from company
to company. Rather than attempt to define this function, which may differ in form for each American Chemistry
Council member, it is suggested that the product steward position or committee read this chapter in full. This
will help a product steward gain a better understanding of how product stewardship might apply to each job
function. An understanding of the wide range of roles and qualifications that are needed for this job, and the
ways the different job functions might interact, will help you determine how best to define the role of product
steward within your own company.
1: Leadership X
2: Accountability and Performance X
Measurement
3: Resources X
4: Health, Safety, and Environmental X
Information
7: Product and Process Design and X
Improvement
8: Employee Education and Product X
Use
Feedback
10: Suppliers X
11: Distributors X
12. Customers and Other Direct X
Product
Receivers
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Communications
Communications staff represent a valuable resource to product stewardship, both in developing informational
materials and clarifying complex information. Communicating the company's commitment to product
stewardship may enhance its image and reputation-both inside the company and with the general public.
Each company organizes its communications activities differently. The topic or target audience may determine
how communications staff is organized. The type of communication (e.g., promotional, educational, evaluative,
etc.) may determine how communications activities are conducted, as well as whether a company conducts its
communications activities from a central headquarters or at the local facility level.
Regardless of your company structure, product stewardship will require extensive communication activities at
all levels for each of the management practices. Product stewardship involves most job functions in the
company to varying degrees. Because communications staff may prepare information materials for other job
functions, communications staff is encouraged to read the other job function sections in this chapter.
The box above indicates the management practices in which communications staff may be involved. Although
suggested activities for Management Practice #3: Resources, are not included in this section, this management
practice is applicable to all job functions because all job functions would need to be sure they have adequate
resources to implement product stewardship. Other job functions often conduct the activities described on the
following pages, depending on the company's organization.
1: Leadership
Measurement
3: Resources X
Environmental
Information
7: Product and Process Design
and
Improvement
Product Use
Feedback
10: Suppliers
11: Distributors X
Product
Receivers
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Provide editorial support as needed for published health, safety, and environmental (HSE) information.
Consideration: Help maintain the consistency of product information developed independently by different job
functions, such as HSE, R&D, and marketing and sales; by business unit; or byproduct lines:
Remain aware of regulatory requirements on format and content for communication tools (e.g., MSDSs).
Developing information for reporting to constituents can be helpful. A wide range of constituencies evaluates
your company’s credibility, all of which are important to your business. These include customers, suppliers,
employees, distributors, shareholders, industry and others. Educate your constituents about product stewardship
and what it means to them. The method will vary, and so will the extent of detail. It is important that reporting
is thorough, relevant, and consistent.
Considerations:
Constituents such as employees and customers who have an active role in product stewardship may require
specific communication programs; for others, such as shareholders, adapting existing communications tools
such as periodic reports may be sufficient. Communications efforts have two elements in common: they are
ongoing, and they are interactive. It is not enough to talk. Communication is most effective if you listen and
incorporate a means for response.
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Management Practice #6: Risk Management System

Distribute product health and safety information on request.
Coaching staff on appropriate responses to challenges from customers and the public can be helpful. Consider
developing difficult questions and answers based on potentially controversial HSE information. Participate in
periodic multi-disciplinary product safety reviews and provide your insights on related communications issues.
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Consider reviewing existing employee communications vehicles (e.g., videos, bulletin boards, newsletters, etc.)
and training programs for their potential use or adaptation to provide product stewardship education to
employees with customer contact.
Considerations:
Two types of training and education may be useful. One concentrates on ongoing efforts to improve employees'
understanding of product characteristics and performance, and the other focuses on educating employees about
product stewardship and how to implement it.
An internal newsletter called "Product Safety Management" may be useful as a vehicle for communicating
product stewardship issues throughout the company.
Review your existing communications system for gathering customer feedback from employees, such as
marketing and sales staff. Adapting the system to meet product stewardship goals could be helpful.
Communications staff can help the company share information better, too.
Consideration:
It might be helpful to keep in mind the following points:
• Consider methods for quick transfer of information to appropriate staff members. The information is
only useful if it is in the right hands. Whether information goes to a person or a committee, it will help to
have a clear-cut means of dissemination.
• Build in a way to short circuit routine reporting in the event that unusual information emerges that
requires fast action.
• Include related company functions (e.g., epidemiology) to

minimize duplication of effort.
• Consider product feedback efforts in a way that protects

confidential information.
Meet as needed with HSE, research and development (R&D), and marketing and sales staff, to determine their
communications support requirements and maintain awareness and understanding of what all the job functions
are doing to meet product stewardship goals.
Consideration:
Use these meetings as an opportunity to advise other departments on internal communications needs and
priorities. This includes acting as an advocate for keeping employees informed and relaying employee feedback.
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Develop an internal communications strategy and plan for announcement and long-term publicity of your
company's product stewardship efforts. Plan ahead and consider how you will follow up and follow through.
Consideration:
Product stewardship is a new name, and it may present some new concepts, but its underlying themes and goals
are hardly news to your employees. By stressing what's already in place in your company, you reinforce long-
standing commitments, and help to avoid the perception that product stewardship will increase individual
workload.
Gather product feedback from employees and develop related communications materials to supply product
information to marketing and sales staff. Those who interact with customers wilt need information about usage
so they can work with customers and understand what constitutes misuse.
Consideration:
Understanding and documenting customers' experience with your company's products not only helps the
company improve products; it provides information for product risk characterizations. This dimension of
product feedback informs the overall risk management process, in that it "closes the loop."
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Assist in notifying distributors of your company's product stewardship efforts. Whether or not specific
distributor follow up is necessary, it is helpful to let them know what your company is doing in terms of product
stewardship. You might assist in developing product stewardship materials for distributors, and you can advise
distribution staff of potential communications and public interest trends, as well.
Considerations:
Many distributors fully share American Chemistry Council’s concerns about responsible manufacture,
handling, and use of chemical products, and for many, product stewardship will not significantly change
relationships with distributors.
Companies might make great efforts to inform and guide distributors but should not assume responsibility for
managing their activities.
Involvement with distributors will vary and depends directly on the product in question and the capabilities of
the distributors.
Consider developing a regular product stewardship newsletter or other update for distributors.
Review of regularly distributed communications for clarity, consistency, and editorial quality can be helpful. It
can help with the consistency of distributor information with other company and/or product communications.
Consideration:
General information about your company may be supplemented with specific items for action or consideration
by individual distributors. Older materials that have not been used in a long time often are supplemented but
rarely edited, and can frequently benefit from an editor's eye.
Help in making communication toots appropriate and convenient for distributors to use with downstream
customers.
89

Maintain dialogue with customers. Communication is most effective when it is an ongoing two-way activity.
You may need regular contact to check that your efforts are effective, and to help you identify what future
communication activities may be needed. This should be coordinated with marketing and sales staff.
Assist in developing product stewardship materials for distribution to customers. Advise marketing and sales
staff on potential communications and public interest trends that may interest customers.
Consideration:
Consider developing a regular product stewardship newsletter or other update for customers.
Consider reviewing regular customer communications for consistency and editorial quality with other company
and/or product communications.
Consideration:
Take a fresh look at communications materials for clarity, particularly in the case of old communications
materials.
Look for opportunities to publicize customer relation successes, such as examples of improved performance
arising from product stewardship partnerships, etc.
Consideration:
If your program includes a product steward, this may be an opportunity to introduce him/her.
Schedule meetings with sales and marketing staff and key customers and product receivers to discuss product
stewardship efforts. You may wish to meet one-on-one, or else it may be useful to include representatives from
relevant job functions within both your company and the customer's company.
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Chapter 3: Responsible Care®
History of Responsible Care

Elements of the Responsible Care Initiative
Responsible Care Codes of Management Practices
Common Themes Emphasized in the Responsible Care Codes
Other Activities Related to Responsible Care
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History of Responsible Care
In 1988, the American Chemistry Council’s Board of Directors adopted an initiative called Responsible Care: A
Public Commitment. But the seeds for Responsible Care were sown several years prior. In the early 1980s a
number of incidents served to solidify the growing negative public perception of the chemical industry. These
incidents called into question the management practices of the industry.
In response to this growing concern, the American Chemistry Council created the original voluntary
Community Awareness and Emergency Response (CAER) initiative, launched in 1985. Its aim was to reduce
the risk of injury to employees and local residents in the event of plant accidents and to help an affected
community cope with the consequences.
Responsible Care was an outgrowth of both the original CAER program and the influence of a Canadian
version of Responsible Care created by the Canadian Chemical Producers' Association. The American
Chemistry Council’s Responsible Care initiative originally established the following goals:
• Improved chemical process

• Enhanced practices and procedures
• Reduction of every kind of waste, accident, incident, and emission
• Reliable communication and dialogue
• Heightened public involvement and input
Responsible Care is an obligation of membership in the American Chemistry Council. A central idea behind
Responsible Care is that it is a continuous improvement process. Responsible Care is a way of doing business. It
is not a program that provides a checklist of activities for member companies to complete though checklists are
effective tools to assist companies in their specific improvement goal selection and implementation. It will be
improved continually in light of new information, new technology, new expectations, and a constant
reassessment of performance and objectives.
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Elements of Responsible Care
Responsible Care is built around a set of Guiding Principles and six Codes of Management Practices that, when
followed, will put the Guiding Principles into action. Other elements of Responsible Care include a Public
Advisory Panel that has been established to critique the development and implementation of Responsible Care
and to provide public feedback; a self-evaluation process designed to determine how well member companies
are applying the codes and to evaluate the performance of the industry as a whole; Executive Leadership
Groups that provide an opportunity for senior management to discuss progress, share information, provide
assistance in implementation, and give feedback to the American Chemistry Council; and finally, a Mutual
Assistance strategy to identify and address the mutual assistance needs of member companies, and develop
networks for members to share information. The Guiding Principles and six Codes of Management Practices are
described in more detail below. Note that even these principles were enhanced as recently as 1999 to reflect the
continuing commitment of the member and partner companies.
Guiding Principles
Our industry creates products and services that make life better for people around the world — both today
and tomorrow. The benefits of our industry are accompanied by enduring commitments to Responsible
Care® in the management of chemicals worldwide. We will make continuous progress toward the vision of
no accidents, injuries or harm to the environment and will publicly report our global health, safety and
environmental performance. We will lead our companies in ethical ways that increasingly benefit society,
the economy and the environment while adhering to the following principles:
• To seek and incorporate public input regarding our products and operations.
and processes.
• To work with others to resolve problems associated with past handling and disposal practices.
• To practice Responsible Care® by encouraging and assisting others to adhere to these principles
and practices.
These principles, taken together, forge a broad agenda for the chemical industry, today and for the future.
Responsible Care’s six Codes of Management Practice translate that agenda into action, by guiding industry
practice toward the goal of continuous improvement throughout all stages of the product's life. Each of these
codes in turn provides guidance in the form of management practices, which are designed to promote the
93
principles of Responsible Care within the scope of each code. Figure 3-1 illustrates how each code fits into the
Responsible Care initiative.
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Responsible Care Codes of Management Practices.
Collectively, the six Responsible Care Codes address all aspects of chemical manufacturing activities,
distribution, and product life cycle stages. The codes have been drafted by more than 180 scientific and
technical experts from 53 companies who served on code drafting committees. Five of the six codes are
described below. The remaining code, Product Stewardship, is described in more detail in Chapter 2.
Community Awareness and Emergency Response Code (CAER):

This code is the focal point for all activities that involve communication with the public and emergency
response following an accident. The CAER Code contains management practices relating to community
outreach and emergency response on the following topics:
• Employee education
• Communications training
• Public education
• Outreach program
• Policy
• Effectiveness evaluation
• Health risk assessment
• Emergency response planning
• Response training
• Emergency exercises
• Facility tours
• Information sharing
CAER's primary emphasis is on communication with the general public and with employees, and calls for
actively initiating ongoing dialogue through outreach programs. Employee communications under CAER
supplement other Responsible Care training and education initiatives that specifically address safety concerns.
In implementing the CAER Code, American Chemistry Council members will be addressing four of the
Responsible Care Guiding Principles (numbers 1, 4, 9, and 10).
Process Safety Code:

The Process Safety Code is designed to prevent fire, explosions, and accidental chemical releases, and help
ensure the overall safety of chemical process facilities. Together with the Employee Health and Safety Code,
these two codes can be regarded as the Safe Plant Operations Code. The management practices encompass the
following areas:
• Management leadership
• Technology
• Facilities
• Personnel
The Process Safety Code focuses on in-plant operations and promotes accident reduction throughout the
manufacturing process. The code's management practices address process safety in terms of both personnel and
equipment, and seek to assure continuous improvement in the manufacturing stage of the product lifecycle.
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Employee Health and Safety Code:
This code addresses traditional worker health and occupational safety issues. It applies to company employees
and contractors inside a member facility. The Employee Health and Safety Code contains management practices
on the following topics:
• Management
• Safety
• Exposure and assessment control
• Medical
• Training and hazard communication
• Personnel/employee relations
• Regulatory compliance
• Long term health monitoring
• Emergency response
The Employee Health and Safety Code also applies to the manufacturing stage, as it relates specifically to the
health and safety of employees and contractors inside a facility. The code addresses both immediate- and
long-term health and safety issues, and calls for ongoing, active employee relations. This code addresses the
need for compliance with applicable regulation governing safety in the workplace, and the ongoing education
and training required for continuous improvement. In addition, the code calls for continuing exposure
assessment and control, as well as long-term health monitoring.
Pollution Prevention Code:

This code addresses the design of (1) processes to minimize wastes and (2) systems to properly handle wastes
that result from process operations. The Pollution Prevention Code contains management practices on the
following topics:
• Commitment
• Reduction measurement
• Waste inventory
• Research and development
• Risk evaluation
• Technology and information
• Risk communication
• Sharing
• Reduction priorities
• Employee and community
• Source reduction
• Dialogue
The Pollution Prevention Code involves both employees and communities in the process of reducing-and
properly handling of waste stream from manufacturing operations. It calls for introducing waste reduction
concepts early in the product lifecycle during research and development, and for assigning a high priority to
proper waste management during and after manufacture. This code also recognizes that plant communities have
a stake in waste management decisions and seeks to assure that residents' concerns are understood and
addressed.
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Distribution Code:
This code seeks to reduce the risk posed to the public, carriers, contractor and company employees, and the
environment posed by the transportation and storage of chemicals. It applies to all aspects of off-site storage,
transfer, repackaging and transportation of chemicals (i.e., pipeline, barge, truck, ship, and rail) between
member companies and their suppliers and customers. The Distribution Code consists of management practices
on the following topics:
• Distribution risk management

• Regulatory compliance and awareness
• Carrier performance
• Chemical handling and storage
• Distribution emergency response and preparedness
The Distribution Code applies to all phases of the product lifecycle during which the product is in transit. In
essence, it picks up where some other codes leave off, at the fence line, by applying risk management
techniques specifically to the distribution and transportation of chemical products. Similarly, this code calls for
developing and maintaining emergency response plans to provide continuity in emergency preparedness once
the product has left the facility.
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Common Themes Emphasized in the Responsible Care® Codes
Several themes are consistently highlighted throughout the six codes that comprise Responsible Care. They are
as follows:
Accountability. Responsible Care not only recognizes the need for accountability but also broadens its
definition. Where traditional product safety and quality programs usually were considered complete at point of
sale, Responsible Care extends members' responsibility for their products' performance through their use,
recycling, and disposal. This expanded focus reflects both market requirements and the underlying public
sentiment that drives them. In making Responsible Care a condition of American Chemistry Council
membership, the industry recognizes these forces and addresses the concerns they represent.
Dialogue. Responsible Care recognizes that the chemical industry does not and cannot do business in a vacuum.
Your business relies on your relationships with suppliers, regulators, lawmakers, employees, industry
counterparts, customers, and shareholders, all of whom have a legitimate stake in the integrity of all aspects of
your operations. When these relationships are adversarial, your business can only suffer; when they are true
partnerships, based on common goals and open dialogue, your business can only improve-in every sense.
Teamwork. Just as Responsible Care calls for engaging with concerned third parties, it also means a team effort
inside-and among-American Chemistry Council member and partner companies. Integrating the Guiding
Principles of Responsible Care into day-to-day operations is a mufti-disciplinary undertaking, requiring the best
efforts, experience, and thinking of an array of specialized professionals and the active involvement of every
employee. No one can do it alone, and everyone has something to offer.
Continuous Improvement. Responsible Care is not a finite activity or a one-time effort. It is an ongoing
process. Similarly, commitment to Responsible Care is a commitment to doing business in a certain way,
towards a certain set of goals: continuous improvement and ongoing reduction of risk. While the goal of zero
risk may never be practically achievable, the goal of reducing risk is essential to your business and the people
you serve.
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Other Activities Related to Responsible Care®
In addition to the Guiding Principles and Codes of Management Practices, described earlier in this chapter, the
American Chemistry Council Board of Directors has developed other activities that complement the
Responsible Care initiative. These are sometimes referred to as the ten elements of Responsible Care and
include the following:
Guiding Principles
Codes Of Management Practices
Dialogue with the Public
Self –Evaluation
Measures of Performance
Performance Goals
Management Systems Verification
Mutual Assistance
Partnership Program
Obligation of Membership
Dialogue with the Public:

In November 1990, the American Chemistry Council’s Executive Committee and Board approved an
accelerated five-year public outreach program for communicating the commitment of Responsible Care,
encouraged by the Public Advisory Panel as well as others, is intended to publicize the commitment and efforts
of the chemical industry and to build momentum for each company and for the industry to improve
performance. The public outreach program targets 10 audiences:
• The general public

• Plant communities
• Employees
• Local interest groups
• Media
• National public interest groups
• Shareholders and financial analysts
• Educators and students
• Federal officials
• State and local officials
International Outreach:
Responsible Care was intended to be global in scope right from the start.
Canada conceived the initiative, and the U.S. picked it up. Then the UK
and Europe, led by the European Chemical Industry Council. Australia,
Japan and New Zealand followed. In 1992 the International Council of
Chemical Associations (ICCA) took Responsible Care under its wing, and the
initiative has since spread as of 2000 to 46 countries on six continents, representing
85 percent of the world’s chemical production.
Though there are differences from country to country, the ICCA requires
eight “fundamental features.” These include checklists or codes to guide
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implementation, indicators to measure progress, public communications
and inter-company sharing
Self –Evaluation
Each member and Partner must annually report their progress toward implementing the Codes to help us
direct our assistance efforts. The self-evaluation is sent to Heiden associates by the Responsible Care
Coordinator in cooperation with the Company’s product Stewardship coordinator and whoever else that the
Company includes in their own self-assessment process.
Measures of Performance
With specific performance measures, the industry and public can readily view the progress of Responsible Care.
This is an industry wide measure for each of the Codes of Management Practices
Performance Goals
To measure individual progress, each member and Partner must establish company-specific goals to be publicly
reported each year.
Management Systems Verification
This process provides members and Partners with an independent review of the of effectiveness of
their systems or implementing
Responsible Care Mutual Assistance.

Company-to-company dialogue at all levels is one of the most effective methods of advancing Responsible
Care®. Networking occurs in organized leadership groups, regional forums and via the Internet.
Partnership Program:
The intent of the partnership program is to make the Responsible Care initiative available beyond the American
Chemistry Council’s member companies to other companies and trade associations, including state chemical
industry councils. Responsible Care Partners are expected to meet the same obligations as American Chemistry
Council member companies. Associations that are Partners must encourage their members to participate directly
in the Responsible Care initiative as Partner companies; facilitate the performance improvement of their
members; provide non-American Chemistry Council member company input on codes and other aspects of the
initiative; and preserve the reputation of Responsible Care" as a performance-improvement initiative.
Obligation of Membership
As Council members and Partners, all companies are required to participate in Responsible Care®
and follow each of these elements.
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Chapter 4: Additional Resources
Exercises to Help You Implement Product Stewardship

Suggested Readings
Risk Characterization and Management Aid
101
Exercises to Help You Implement Product Stewardship
Introduction
As discussed throughout this Resource Guide, product stewardship is very much a team effort, drawing on
multiple talents, backgrounds, and perspectives. This section provides a series of exercises that may help you in
setting priorities and staffing patterns within your company.
Before conducting the exercises, it may be helpful to consider some common features of effective teamwork as
they apply to product stewardship. For some companies, teamwork that brings different job functions or
disciplines together is commonplace. Many companies form task forces to accomplish specific goals, or have
reporting systems that require different departments to share and exchange information. For others, forming and
maintaining such teams may represent a departure from standard operating procedure. In either case, because
the concept of teamwork is central to implementing product stewardship, it may be useful to review some basic
principles.
Although there is no single magic formula for teamwork, successful teams do have some common traits,
including:
Reason for being. Whether they are formed by a management directive or they develop from within, successful
teams exist to address a tangible problem, issue, or opportunity that has tangible consequences for the company.
Leadership. Someone has to break the tie, resolve the conflict, or make the decision, if the team hits a deadlock.
Successful leaders have the team's respect and management's confidence, earned through a combination of
interpersonal skills and decision-making ability.
Empowerment. A team charged with certain responsibilities needs the authority to fulfill them; otherwise,
momentum and commitment are quickly lost.
Relevance. Teams formed to tackle issues that are important to the company bring far more energy to the effort.
The right people. Successful teams usually include a combination of thinkers, doers, and prime movers - all of
whom actively contribute to the effort.
Balance. A truly interdisciplinary team reflects different views, and no one dominates the group by virtue of
numbers or rank.
Shared vision. While different perspectives are a strong asset to an effective team, members should have a
collective sense of purpose and a shared objective for their efforts.
Focus. Effective teams concentrate their energy toward a single goal - even though the goal itself may consist
of many different tasks and issues - and stay on track, both in individual meetings and in their overall group
effort.
Ground Rules. Effective teams quickly devise systems and procedures that work, not to create a bureaucracy
but to provide a structure for their efforts.
Discipline. Committed team members make time for meetings, give opposing viewpoints a fair hearing, sit
through the occasional boring presentation, deliver what they promise, and don't give up easily.
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Flexibility. Successful, long-term team efforts are flexible enough to accommodate, and sometimes invite, shifts
in team membership, leadership, and procedure.
Follow-through. Teamwork requires momentum and continuity to achieve meaningful results, especially in a
long-term initiative.
As you establish or refine your product stewardship initiative, consider the traits described above and consider
your company's culture, resources, and personnel in these terms, to see which may apply and which may require
extra effort.
The following exercises draw on Total Quality Management techniques, adapted to focus discussion on your
company's product stewardship needs and resources. The results of exercises such as these can provide the basis
for determining where your resources are most effectively applied, as well as how your company can best
organize ongoing product stewardship efforts.
Exercises #1 and #2 are essentially the same. Together, they focus on identifying the right product stewardship
skills and roles for different job functions. Exercise #3 helps focus on the gaps between the actual and ideal, and
looks for ways to address them. For continuity, Exercises #1, #2, and #3 should be conducted together. Exercise
#4 helps identify the most effective location for the product steward position in your company structure.
Exercise #5 consists of three worksheets to help you document the activities you have in place and the activities
you plan to perform in order to implement product stewardship. Exercise #5 is a supplement to Chapter 2.
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Exercise #1: Identifying Possible Product Stewardship Roles in Your Company
Purpose:
The purpose of this exercise is to identify the roles each job function should play in your company's product
stewardship program. The roles identified in this exercise can be compared with the actual roles identified in
Exercise #2, to identify areas needing improvement.
Mechanism:
This exercise uses a job function grid. The grid is a matrix that shows job functions across the top, management
practices down the side, and each job function's role in specific management practices. The job function grid
can also be used on a more "micro" level to characterize individual personnel in a job function or department
and their roles and responsibilities. (Note that the job functions indicated are not all-inclusive; rename them
and/or add others to reflect your company.)
Steps:
1. Identify and gather a small group of participants (no more than 7).
2. Give each participant a grid (See Figure 4-1) and ask him or her to indicate independently what they
believe the role of each job function should be as it relates to each management practice, using the
following codes:
AP: Approver - Allocate resources, signs off, can veto. Delegates responsibilities to:
PM: Prime Mover - Has more responsibility than any other staff function to ensure that a management
practice is implemented.
CO: Contributor - Significantly contributes to carrying out the management practices.
CR: Concurrer - Provides review and concurrence in area of expertise.
EX: Expert - Provides expert information or assistance.
3. After all participants have completed their grid, discuss the management practices, one at a time, and the
roles participants have assigned to each job function.
4. You may wish to achieve group consensus or you may choose to use the results
of the exercise as a guidepost in fleshing out the components of your company's
product stewardship program.
Benefits:
• Emphasizes meaningful relationships among job functions.
• Provides a clear picture of what the product stewardship roles and relationships could be for your
company.
• Allows for comparison with actual roles and relationships.
• Allows for addition of other job functions.
• Avoids duplication of efforts and overlaps.
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TIONAL RESOURCES
RE 4-1
heet for Exercises #1 and #2
nctions / Senior Research & EH&S Purchasing Manufacturing Marketing Distribution Product Com
ement Management Development & & Sales Stewardship
es Supplying
ership
ntability
mance
ement
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h. Safety
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uct Risk
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ement
uct and
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oyee
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105
tomers
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Exercise #2: Identifying Actual Product Stewardship Roles in Your Company
Purpose:
This exercise helps to identify the roles each job function currently plays in your company's product
stewardship program. The current actual roles can be compared with the possible roles identified in Exercise #1,
to identify areas in need of improvement.
Mechanism:
This exercise uses the same job function grid used in Exercise #1. The grid is a matrix that shows key functions
across the top, management practices down the side, and each job function's role in specific management
practices. The job function grid also can be used on a more "micro" level to characterize individual personnel in
a job function or department and their roles and responsibilities. (Note that the job functions indicated are not
all-inclusive; rename them and/or add others to reflect your company.)
Steps:
1. Identify and gather a small group of participants (no more than 7).
2. Give each participant a blank grid and ask him or her to independently indicate
the current role of each job function as it relates to each management practice,
using the following codes:
AP: Approver - Allocate resources, signs off, can veto. Delegates responsibilities to:
PM: Prime Mover - Has more responsibility than any other staff function to ensure that a
management practice is implemented.
CO: Contributor - Significantly contributes to carrying out the management practices.
CR: Concurrer - Provides review and concurrence in area of expertise.
EX: Expert - Provides expert information or assistance.
3. After all participants have completed their grids, discuss the management
practices, one at a time, and the roles participants assigned to each job function.
4. You may wish to achieve group consensus, or you may choose to use the results
of the exercise as a guidepost in fleshing out the components of your company's
product stewardship program.
Benefits
• Emphasizes meaningful relationships among job functions.
• Provides a clear picture of what the correct product stewardship roles and responsibilities are for your
company.
• Allows for comparison with possible roles and relationships.
• Allows for inclusion of other job functions.
• Avoids “I thought you were doing that" syndrome.
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Exercise #3: Identifying Gaps and Opportunities for Improvement
Purpose:
This exercise compares the possible product stewardship roles identified in Exercise #1 with the actual roles
identified in Exercise #2 and identifies gaps. Through a process of team evaluation and prioritization, solutions
for the gaps are developed, as are procedures for evaluating the success of these improvements.
Steps:
1. Identify and gather a small group of participants.
2. Give each participant a blank grid (see Figure 4-2). Ask each participant to review the grids completed
in Exercises #1 and #2. Given the current and possible roles identified in the first two exercises, ask each
participant to identify, independently, the gap between each possible and actual staff function. The blank
grid can be used to record where gaps exist. The group should record descriptions of gaps separately.
3. After all participants have identified the gaps in their role grids, rank and order the gaps in terms of their
importance in improving product stewardship.
4. Starting with the most important opportunity for improvement (lowest score), brainstorm solutions and
identify persons responsible for implementation. If mechanisms exist for implementing improvements,
they should also be identified.
5. As a group, discuss how to evaluate the success of implementing the recommended solutions.
6. You may wish to start implementing some solutions as quickly as possible.

Others may have lower priority or may require more groundwork.
Benefits:
• Emphasizes practical relationships among staff functions.
• Provides a clear picture of how product stewardship roles and responsibilities will work in practice in
your company.
• Allows for comparison and integration of current and possible roles and relationships.
• Allows for inclusion of other job functions.
• Provides a mechanism for focusing on solutions that give "the most bang for the buck."
• Avoids "I thought you were doing that" syndrome.
• Provides a concrete basis for management action.
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TIONAL RESOURCES
4-2
heet for Exercise #3
ctions / Senior Research & EH&S Purchasing Manufacturing Marketing Distribution Product Communications
ment Management Development & Supplying & Sales Stewardship
s
rship
untability
formance
ement
rces
h. Safety and
mental
tion
ct Risk
erization
Management
ct and
Design and
ment.
oyee
on and
Use
k
ct
cturers
liers
ibutors
omers and
irect
Receivers
109
Exercise #4: Identifying the Most Effective Location for the Product Steward Position in Your Company
Structure
Purpose:
This exercise is designed to help identify where in your company structure is the most appropriate place for the
product steward position(s).
Mechanism:
The mechanism used in this exercise is called a selection grid. This tool is borrowed from Total Quality
Management programs, and adapted for this exercise.
Using a selection grid involves first choosing appropriate criteria and then applying the criteria to the options at
hand. To keep the process from becoming needlessly complex, a group will usually consider just a few criteria
when making a decision and will use a very simple scoring system (perhaps "yes" or "no" for each criterion).
Typical criteria might be:
Support - will upper management support the organizational structure selected?
Cultural consistency - will the new product steward position be consistent with the current company-wide
culture?
Structural consistency - will the new product steward position be appropriate to the current organizational
structure?
Precedent - is there precedent in the company for the organization for the new product steward position?
Effectiveness - is this organization for the new product steward position likely to be effective?
Steps:
1. Gather a group of up to eight people.
2. Brainstorm a list of options for the most effective location for the product steward position in your
company structure. You may want to first consider potential skills and attributes of such a position, such as
those listed below. Narrow the list of options under consideration to about five or fewer items. Ideally, this may
be accomplished by informally asking which ideas appeal the most to people. If necessary, a more structured
selection process may be used.
Potential Skills and Attributes of a Product Steward should include the following;
• Has full trust of the CEO;

• Has excellent leadership skills;
• Has excellent management skills, can overcome organizational boundaries, can work with people from
all disciplines;
• Is skilled at both internal and external promotion;
• Is a big picture thinker; - Works well with peers in other companies;
:
• Is management systems oriented;

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• Has relevant professional experience;
• Has successfully "carried the torch" for other highly visible initiatives; _ .
• Views government as a partner in product stewardship; and
• Is motivated to accept the product stewardship position. .
3. Choose criteria and a scoring system. Keep the number of criteria as low as you can. At first, use a
simple scoring system like "yes" or "no". (If there is intense disagreement or confusion, you may need to
use a more sophisticated scoring system. For example, you can use a weighing system in which each
participant is allowed to either rank or order the criteria and distribute 10 points among each of the
criteria as he or she sees fit. Then the participants' points can be added up, and the criteria can be ranked
in order of importance.)
4. Make a grid of the criteria versus the options and fill it in to evaluate how well each option satisfies each
criterion. Have each member do this privately first, then tally all the scores on one sheet. This allows the
group to see systematically where there is agreement and disagreement among the participants. The
completed grid might look something like the sample grid in Figure 4-3 for ABC Chemical Company.
5. Select one option. The grid will not tell you what to do, but it will give you information that will help
you come to an informed decision. If no option seems quite right, the group may want to go back to the
brainstorming list to brainstorm some more.
Benefits:
• Makes evaluation criteria, which usually vary from person to person, explicit so the group can discuss
organizational options from a common vantage point.
• Provides a structured way of sharing ideas.
• Helps keep discussion on track.
• Satisfying to participants.
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RE 4-3
f ABC Company
Product Support Cultural Structural Precedent Effectiveness

Stewardship Is… Consistency Consistency
1. CEO Yes=8 Yes=7 Yes=6 Yes=8 Yes=2
No=0 No=1 No=2 No=0 No=6
2. Total Quality Yes=0 Yes=2 Yes=7 Yes=7 Yes=3
Management No=8 No=6 No=1 No=1 No=5
Director
3. HSE Manager of Yes=4 Yes=4 Yes=3 Yes=3 Yes=4
each of the tree No=4 No=4 No=5 No=5 No=4
company divisions
4. Senior VP of Yes=5 Yes=5 Yes=6 Yes=6 Yes=4
Strategic Planning No=3 No=3 No=2 No=2 No=4
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Exercise #5: Worksheets for Chapter 2
The worksheets on the following three pages can be used to supplement Chapter 2 of this Resource Guide.
Consider photocopying these worksheets to use as you read about possible activities for your job function(s).
The first worksheet, titled "What You Do Now to Implement this Management Practice," provides you with
space to record activities you already have in place to implement each management practice.
The second worksheet is titled "What You Could Be Doing." This worksheet provides space to keep track of
ideas or potential activities you could implement to incorporate management practices into your job function(s).
The third worksheet, titled "How You Plan to Do It," can help you develop a plan to implement the activities
you recorded on the second worksheet.
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LAUNCHING THE PROGRAM
Overview of Process
INTRODUCTION
Congratulations! With your help and encouragement, probably the most important step in launching a Product
Stewardship Program already has been taken -- ensuring that Senior Management understands Responsible Care
and Product Stewardship and has expressed a commitment to meeting the goals of the Codes. Most companies
who have started a Product Stewardship Program stress the importance of getting this commitment in writing
and distributing a copy to those individuals in the company who will share responsibility for implementing this
Code.
Now let's look at the specific tasks involved in setting up a Product Stewardship Program for your organization.
This section is, of necessity, relatively general due to the organizational differences between companies. It is
not meant to present the single right way that these tasks can be accomplished, but to provide assistance for
those developing a company program.
Product Stewardship is the most recent of the Responsible Cared Codes to be implemented and, in some
respects, perhaps one of the most difficult. It covers the entire life cycle of a product from inception to disposal,
and it governs all facets of decision-making about the product. It is interrelated to every other code in
Responsible Care®.
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STEP ONE: KNOW THE TERRITORY
Elements of uncertainty and apprehension are part of launching any new venture. This is the time to reduce the
uncertainty by surveying the territory and learning from others who may be starting on the same path or who
already have completed the journey.
The first step in implementation is to understand the scope and character of Product Stewardship. Listed below
are ways to help you gain an understanding:
• Discuss Product Stewardship with companies who already have established a Product Stewardship
program in their organizations or who are in the process of implementing the program. Exchange views.
• Review the many articles on Product Stewardship, i.e.. Chemical Week contains many articles on
Product Stewardship. The first to appear in Chemical Week, Special Issue, 17 June 1992is a good source
for both general articles and articles containing corporate philosophies. Also visit the member exchange
Responsible Care site at memberexchange.americanchemistry.com. where you can find a document
library in addition to other Responsible Care and Code specific information and news.
• Review the introduction to "Implementing Product Stewardship -- A Resource Guide" by the

American Chemistry Council.
Consider drafting or revising current mission statements or policies to include your company's
commitment to product stewardship. You also may wish to select a process owner, or product
stewardship leader, to ensure that there is accountability and leadership for this effort.
STEP TWO: CHOOSE YOUR TEAM WISELY AND IDENTIFY YOUR FINAL DESTINATION
Choose a well-qualified team to help you understand the territory and decide where you want to go with this
venture. Your destination may be very close to, or quite distant from, the goals of other companies.
Consider who needs to be involved in determining the scope and character of your program. The Resource
Guide, cited above, includes as its first exercise a matrix of functions and activities to identify key players in the
company. It can be a good first step. The key individuals in this evaluation may include those from the
following areas of your company:
• Senior Management
• Business Management
• Sales and Marketing
• Health, Safety and Environmental
• Research and Development
This group will be able to provide insight from their current assignments as well as contribute to policy
decisions and development of a Product Stewardship Vision Statement. This is the time to consider what you
want your Product Stewardship program to accomplish. A way to focus the program is to determine how visible
you want the Product Stewardship program to be, inside and outside of your company, and to identify some
preliminary milestones. Resources for this step can include the following sources:
• Other companies' written policies, philosophies and vision statements
• The American Chemistry Council Product Stewardship Resource Guide, Senior Management SectionSTEP
THREE: GET YOUR BEARINGS
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You have Identified where you want to go. Now you must determine where you are! Are there resources or
milestones already In place within your company, which can be used as stepping-stones to the ultimate goal?
Establish benchmarks
Establish your own definition of "practice in place." There are several ways to approach this step and to
determine subsequent action.
One approach is to define "practice in place" by function or department. Decide the responsibilities of each
function or department in implementing product stewardship. Write a description of each activity within each
function or department. Then work from these descriptions to determine what "practice in place" means for each
activity within that function or department.
Another approach is to translate your vision of Product Stewardship into actions by determining what "practice
in place" would be for each management practice. From this you can determine which functions will be
impacted and describe their role in Product Stewardship. The matrix suggested in Step Two, will be helpful in
defining the roles of each function. The American Chemistry Council has collected some definitions used for
"practice in place." These are available from your American Chemistry Council Responsible Care Coordinator
or the member exchange Responsible Care site at memberexchange.americanchemistry.com.
Look at current company practices

Evaluate what you have now and then determine which management practices are addressed by current
company programs. One way to accomplish this is to document your current status by listing all company
activities, programs and policies pertinent to each management practice. Then you can evaluate whether they
meet your definition of "practice in place."
It may be a good idea to appoint subgroups to work on each of the management practices based on their areas of
expertise and work focus. For example, Management Practices 4 and 5 are areas where those individuals who
have been writing your Material Safety Data Sheets will have much to contribute. Product and Process Design
may be best addressed by your engineering, manufacturing or the research and development department. Every
company's management structure is a little different.
Taking inventory of your current company practices is a very important step. Build on these practices. Try not
to create redundant systems or systems that have the potential to create conflicting information.
STEP FOUR: PLAN THE JOURNEY

Now that you know your destination and your starting point, it is time to plan the trip. Identify milestones along
the way and select the best route to travel.
At this stage you should consider prioritizing the activities needed to accomplish "practice in place" for each
management practice. Setting priorities takes into account the impact of one practice on another. Some practices
build from others. For example, management practices 1, 2 and 3 should be in process before 4 through 12 can
be implemented. In addition there must be something in place for practice 4 and 5 before practices 6 through 12
can be established effectively.
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Use your teammates to establish or coordinate the operating practices that should be addressed by each
functional area (i.e., marketing/sales) to participate in the program. It is important to review each practice with
those who will be impacted in order to obtain their input, secure their buy-in and achieve better participation in
the day-to-day operation of Product Stewardship.
STEP FIVE: SEND ADVANCE SCOUTS

Determine if the trip has been planned adequately. You may wish to use some of your planning team to check
for obstacles or unanticipated problems along the route.
Consider establishing a system to monitor progress and determine stumbling blocks for successful
implementation of the program. A pilot program can be very useful in determining which mechanisms are in
place and where gaps exist. A pilot program also can be established in a key product or business unit or in
selected products from a variety of product areas. The pilot program will help you determine your resource and
manpower needs. It may be best to use several products or product lines in the pilot to ensure that you have a
balanced representation of the product issues to be addressed by Product Stewardship.
It should be recognized that while a pilot may be useful, it could delay the overall introduction of the full
program. It may be equally effective, and perhaps quicker, to meet with companies who have established
Product Stewardship programs to learn from them. In the spirit of Responsible Care, other companies generally
are willing to assist in these evaluations. Regional responsible Care mutual assistance networks have been set
up which regularly host meeting organized for and by members and partners to share information regarding
opportunities and solutions to common implementation challenges. You can find out about the many regional
network activities at the member exchange Responsible Care site at.memberexchange.americanchemistry.com
STEP SIX: TRAIN ALL PARTICIPANTS

Now the trip has been planned. All guides, as well as members of the expedition, must be told how to get to the
destination and what their functions will be in this unfamiliar territory. There will be new skills to learn and
elements of a new language.
Since Product Stewardship involves so many employees, your introduction of the program should be made in
broad, general terms. The commitment of senior management to Responsible Care®, including Product
Stewardship, should be stressed. You may wish to make senior management visible in this introduction so that
there is no question of the priority that Product Stewardship should be given. Then describe the importance of
each individual employee's role in this program.
The training could include an overview for senior management and all employees. Specific programs and/or
workshops could be held for the Product Stewardship leaders. Other training could be directed to specific
functions such as sales and marketing. It is important that each department and individual employee understand
the importance of Product Stewardship and his or her role in the success of the company program. At this point
you may want to think about developing publicity and awards for individual and business Product Stewardship
activities.
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The following materials may be useful and are among those items that can be found at the membersxchange
site under products and services:
The American Chemistry Council Product Stewardship video, "Beyond the Fenceline," a general introduction to
Product Stewardship;
The American Chemistry Council short pamphlet, "Product Stewardship for the Sales and Marketing
Professional," which introduces the importance of the Sales and Marketing staff in reaching the organization's
objectives;
"The Power of Product Stewardship" video for sales and marketing professionals;
"Product Stewardship Supply Chain Protocols
Your individual company's pledge to Responsible Care, Product Stewardship vision statements, and other
related policies.
STEP SEVEN: BEGIN YOUR JOURNEY

It is probably going to be a long journey so get on your way! Keep your destination in mind at all times. You
undoubtedly will learn many new things along the way and profit from each new experience.
It may be advisable to implement the plan in phases. Many companies have elected to prioritize products by
defined criteria -- by hazard, volume, application, and potential exposure or regulatory issues -- and focus on the
highest priority products first. This is a company decision and may be governed, in part, by the availability of
resources and expertise.
STEP EIGHT: KEEP FOCUSED; STAY ON THE HIGH ROAD

Keep track of where you are going by plotting your progress on the map. Always look for better paths but
beware of easy shortcuts.
Continuous improvement can be measured by the annual self-evaluations for the American Chemistry Council.
You may wish to establish intermediate goals. Consider establishing company or business unit goals or
milestones to use as guides to measure your progress. You may wish to build accountability in various ways
such as individual performance ratings or business unit performance.
It may be effective to establish incentive programs such as variable pay initiatives, prizes, rewards or
recognition for a job well done.
The American Chemistry Council is continually working to develop additional resources for your use in
implementing Product Stewardship. Additional resources may be obtained from your American Chemistry
Council Responsible Care Coordinator or the member exchange Responsible Care site at
memberexchange.americanchemistry.com.
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Product Stewardship Assessment Review Guidelines for Contract Manufacturers Suppliers, Distributors
and Customers
An Implementation Aid for the Responsible Care Product Stewardship Code of Management Practices
PRODUCT STEWARDSHIP ASSESSMENT REVIEW GUIDELINES
LEGAL NOTICE
This Product Stewardship Assessment Review Guidelines document has been prepared to assist members of the
American Chemistry Council and Responsible Care Partners in implementing the Product Stewardship Code of
Management Practices. It is intended to provide some helpful ideas to American Chemistry Council members
and Responsible Care Partners, but it is not meant to define any particular steps that should be taken in the
implementation process.
American Chemistry Council members, Responsible Care Partners, and all entities involved in the chain of
distribution and sale of products have an independent obligation to ascertain that their actions and practices
represent sound product stewardship.
The Guidelines document is necessarily general in nature and leaves dealing with product and site-specific
circumstances to American Chemistry Council members and Responsible Care Partners. American Chemistry
Council members and Responsible Care Partners may vary their approach with respect to particular products or
locations based on specific factual circumstances, the practicality and effectiveness of particular actions and
economic and technological feasibility. It is also understood that the timing and speed of implementation by
American Chemistry Council members and Responsible Care Partners will vary by company, location and
nature of products.
The Guidelines document is not designed or intended to define or create legal rights or obligations. American
Chemistry Council members and Responsible Care Partners are, of course, expected to comply with federal,
state and local laws and regulations, and should consult with legal counsel concerning such matters. While the
Guidelines may refer to federal regulations, it is not intended and should not be used to assess regulatory
compliance.
respect to the accuracy or completeness of the information contained in the Guidelines; nor does the American
information, procedures, conclusion, or opinion in this Guidelines document.
COPYRIGHT NOTICE
American Chemistry Council (1993)
hereby grants a non-exclusive royalty-free license to reproduce and distribute this work, subject to the following
limitations:
1. The work must be reproduced in its entirety, without alterations;

2. All copies of the work must include a cover page bearing the American Chemistry Council’s notice of
copyright and Legal Notice; and
119
TABLE OF CONTENTS
LEGAL NOTICE
COPYRIGHT NOTICE
INTRODUCTION
A. Scope
B. Responsible Care: A Public Commitment 4-35
C. The Product Stewardship Code 4-36
D. Management Practices for:

Contract Manufacturers
Suppliers
Distributors
Customers
II. REVIEW GUIDELINES
A. Responsibility for Initiating Assessments
B. Responsibility for Performing Assessments
C. Documentation Required and Report Format
D. Assessment Guidelines
E. Assessment Timing and Depth
F. Assessment Follow-up and Feedback Procedures
III. APPENDICES
A. Contract Manufacturer Assessment Guidelines
B. Suppliers Survey - Examples 1 and 2
C. Distributors
D. Customer Survey - Examples 1 and 2
D. Customer Checklist
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I. INTRODUCTION
A. Scope
This Guidelines document was developed to assist American Chemistry Council members and Responsible
Care Partner companies with their implementation of the Product Stewardship Code of Management Practice.
While each company will have its own unique way of implementing the Code, the Guidelines is intended to
provide some helpful ideas on issues to consider when conducting assessments of contract manufacturers,
suppliers, distributors, customers and other direct product receivers.
The Guidelines is not intended to provide a checklist that is applicable to all companies, products or situations,
but is intended to help identify some of the factors that might be considered in assessing contract manufacturers,
suppliers, distributors and/or customers. The goal, as with all Responsible Care activities, is to identify areas
where continuous improvement is possible.
B. Responsible Care: A Public Commitment
Responsible Care is an initiative of the American Chemistry Council to help its member companies improve
their human health, human safety, and environmental (HSE) performance through sound business and
management practices.
Responsible Care is built around a set of guiding principles, several of guiding principles, which are particularly
relevant to the Product Stewardship Code:
and processes.
To practice Responsible Care® by encouraging and assisting others to adhere to these principles
and practices.
In order to put the Guiding Principles into action, six codes of management practice provide guidance to
member companies in the areas of (1) Community Awareness and Emergency Response, (2) Process Safety, (3)
Employee Health and Safety, (4) Pollution Prevention, (5) Distribution and (6) Product Stewardship.
Collectively, the Codes address all aspects of chemical manufacturing activities and are designed to guide
American Chemistry Council members to continuously improve their performance.
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C. The Product Stewardship Code
The purpose of the Product Stewardship Code is to make HSE protection considerations an integral part of
designing, manufacturing, marketing, distributing, using, recycling and disposing of products. The code covers
all stages of a product's life. As a result, successful implementation is a shared responsibility. All parties
involved with a product-manufacturers, suppliers, contract manufacturers, distributors and customers have
responsibilities to help insure that products are made, used and disposed of safely and in an environmentally
sound manner.
Therefore, four of the twelve specific management practices that make up the Product Stewardship Code
include outreach activities among members and their supply chain partners. The long-term result of
implementing Management Practice 9, 10, 11 and 12 should be better health, safety and environmental
performance for the entire chemical industry and consumers as well as for the members and partners of the
American Chemistry Council.
Any review of a contractor, supplier, distributor or customer should be commensurate with product risk.
However, it is appropriate to expect companies to make a continuous effort to extend the principles of product
stewardship beyond the American Chemistry Council membership and Responsible Care Partners.
D. Management Practices
The following are Specific Management Practices for which Assessment Guidelines have been developed:
Management Practice 9 - Contract Manufacturers
The Product Stewardship Code states that the American Chemistry Council member:
Selects contract manufacturers who employ appropriate practices for health, safety and environmental
protection for the operations under contract, or works with contract manufacturers to help them implement such
practices. Provides information and guidance appropriate to the product and process risk to foster proper
handling, use, recycling and disposal. Periodically reviews performance of contract manufacturers.
The objective of this Management Practice is to encourage the use of contract manufacturers who have sound
HSE 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. If contract manufacturers are unwilling to implement
appropriate controls, a company may decide to cease doing business with them. While companies are
committed to working with contract manufacturers to help them improve performance, the achievement of
appropriate HSE standards should occur within a reasonable time frame.
The level of a company's involvement and review will vary according to the degree of product risk. "Working
with" may include:
• Providing detailed HSE product information;

• Providing technical assistance on product handling techniques and waste minimization and
management; and
• Visiting the contract manufacturer's facilities to assess and evaluate, as well as to perform periodic HSE
assessments.These actions will vary according to the individual contract manufacturer and operations. Because
of the greater degree of company control, much closer interaction will be appropriate with contract
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manufacturers than with distributors and customers. All contract manufacturers should be subject to periodic
performance reviews.
Management Practice 10 - Suppliers
Requires suppliers to provide appropriate health, safety and environmental information and guidance on their
products. Factors adherence to sound health, safety and environmental principles, such as those contained in
Responsible Care, into procurement decisions.
The objective of this management practice is to extend product stewardship practices to suppliers. Where
appropriate, HSE 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,
and health and loss prevention functions to determine how the supplier can contribute to a safer environment.
Other companies may opt to make these HSE considerations part of their supplier quality reviews or to factor
them into contractual decisions. Suppliers should describe and document. wherever possible, their HSE
programs and goals.
Management Practice 11 - Distributors

The Produce Stewardship Code states that the American Chemistry Council member:
Provides health, safety and environmental information to distributors. Commensurate with product risk, selects,
works with and periodically reviews distributors to foster proper use, handling, recycling, disposal and
transmittal of appropriate information to downstream users. When a company identifies improper practices
involving a product, it will work with the distributor to improve those practices. If, in the company's
independent judgment, improvement is not evident, then the company should take further measures-up to and
including termination of the business relationship. This Management Practice should be implemented in
conjunction with the Distribution Code of Management Practices.
The objective of this management practice is to encourage distributors to establish and implement proper HSE
practices involving products produced or processed by members or partners. It should be implemented in
conjunction with Management Practice 4.6 of the Distribution Code, available from the American Chemistry
Council Responsible Care coordinator, which focuses on distributor operations.
The emphasis in the Product Stewardship Code is on working with distributors to help them achieve appropriate
levels 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. As with
customers and other direct product receivers, a company may decide to terminate the business relationship with
those distributors unwilling to implement corrective actions appropriate for limiting risks and otherwise
achieving the HSE objectives of product stewardship.
The level of involvement with a distributor will vary according to the product's risk. That risk also should
determine the frequency of the periodic performance reviews mandated in the Distribution Code. These reviews
may be used as a forum to share accumulated knowledge that will elevate HSE performance and product
stewardship practices.
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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 HSE characteristics. The "transmittal of appropriate information"
acknowledges that while members and partners expect distributors to provide HSE information, 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 HSE information.
Management Practice 12 - Customers and other Direct Product Receivers
Provides health, safety and environmental information to direct product receivers. Commensurate with
product risk, works with them to foster proper use, handling, recycling, disposal, and transmittal of
appropriate information to downstream users. When a company identifies improper practices involving
a product, it will work with the product receiver to improve those practices. If, in the company's
independent judgement ,improvement is not evident, then the company should take further measures - up
to and including termination of product sale.
The objective of this management practice is to encourage customers to "foster" proper HSE practices involving
member and partner products. While the emphasis is on providing information to customers, other assistance
may be appropriate where the product risk indicates. This management practice recognizes that if those efforts
are unsuccessful, a company has a range of actions that are available, including refusal to sell 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 HSE information, additional training, etc. At a minimum, both parties should share any
accumulated knowledge that would enhance HSE protection.
The "transmittal of appropriate information" acknowledges that while we want customers to pass along HSE
information, 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 HSE
information.
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II. REVIEW GUIDELINES
Remember that the purpose of the Product Stewardship Code of Management Practices is to make HSE
protection an integral part of designing, manufacturing, marketing, distributing, using, recycling and disposing
of chemical products. The code provides guidance as well as a means to measure continuous improvement in
the practice of product stewardship.
apply the code to its products, customers and business. However, it is suggested that a formalized written
procedure be established and used, both for the initial screening as well as performance assessments of contract
manufacturers, suppliers, distributors and customers. This procedure can include consideration of
company-specific items such as responsibility for initiating assessments, types of assessment, responsibility for
performing assessments, types of documentation required and format of assessment reports, the specific
procedure and/or checklist to be used, and follow-up or feedback procedures.
All member companies and Responsible Care Partners are reminded that company counsel should be consulted
prior to conducting any types of assessments or evaluations of contract manufacturers, suppliers, distributors
and customers. The American Chemistry Council offers these materials only to assist companies with their
implementation of the Product Stewardship Code of Management Practices.
Below are procedural items to consider:
A. Responsibility for Initiating Assessments

Business units or other company groups that are most knowledgeable about the contract manufacturers,
suppliers, distributors, and customers should be identified and a procedure developed to initiate reviews.
B. Responsibility for Performing Assessments

Qualifications for assessors should be outlined prior to initiating the program. The depth of reviews to
be done and detail in the assessment tools, such as checklists, will help determine who may adequately
perform the reviews. If the assessment protocols or checklist used are very detailed, and training in their
use is provided, then a larger number of people may be able to perform the assessments. Many
companies have successfully used non-HSE professionals to perform assessments.
C. Documentation Required and Report Format

The American Chemistry Council member or Partner should determine in advance the degree and
specifics of documentation required from the facility being reviewed. This may include only regulatory
requirements or publicly available information such as SARA Title III Reports and environmental
permits. It also might include company documents such as OSHA Form 200's, Emergency Plans or
Hazard Communication programs. The format and distribution of the assessment reports also should be
determined beforehand. Detailed reports with completed checklists might be used. For other facilities,
perhaps only summary findings and identification of significant areas of concern would suffice.
Consideration should be given to providing response confidentiality.
125
D. Assessment Guidelines
The type and design of any assessment program has to be tailored to meet each individual company's
policies and needs. The assessment program will vary from company to company and product to
product, as well as between third parties. It will vary with risk and the results of any initial screening
process. It can be as simple as placing a telephone call to ask a few questions, or as formalized as
preparing a survey, questionnaire or protocol document.
The American Chemistry Council worked jointly with the other appropriate industry associations to
develop and revise supply chain protocols to be used to survey supply chain partners including
protocols for terminals, warehouses, contract manufacturers, container, customers and suppliers,
motor carriers, and rail carriers. The protocols are intended to help member and Partner companies
fulfill their Responsible Care commitment, and to provide companies with a mechanism to gather
EHS information from companies.
The American Chemistry Council makes two suggestions for most efficient use of the Assessment
Protocols. First, companies using the protocols should feel free to add any necessary appendices to
the protocols to cover additional information needs not covered by the protocols. Second, please
provide any comments or suggestions for improvement in future revisions of the protocols to the
Council's Responsible Care® Team at (703) 741-5000. See supply chain protocols at the
Responsible member exchange site to download these surveys.
Some examples of formal assessment protocols/surveys/checklists are provided in the following

Appendix Section of this document (beginning on page a-1). These examples can be used to develop
company-specific documents. Examples follow for assessing contract manufacturers, suppliers and
customers. Examples for distributors are not included in this document since the American Chemistry
Council has developed a separate "Chemical Distributors Assessment Protocol for Chemical
Distributors." which can be found in the books section of product and services at the members exchange
website.
Other organizations have generated their own sample documents, which also could assist in the
development of company-specific documents. Some of the organizations that have their own documents
are the Canadian Chemical Producers Association (CCPA), the National Association of Chemical
Distributors (NACD) and The Society of the Plastics Industry, Inc. (SPI). Additionally, the American
Chemistry Council and the National Tank Truck Carriers, Inc. (NTTC) have jointly developed and
issued an Inter-Industry Bulk Chemical Highway Safety Task Force Manual of Recommendations,
which also may assist in the development of company-specific documents.
If your contract manufacturer, supplier, distributor or customer has completed a document for another
company, consideration can be given as to whether a copy is acceptable for your company's needs.
E. Assessment Timing and Depth

The priority, frequency and depth of performing assessments should be commensurate with the level of
risk, including:
• Physical and chemical hazards involved in products or chemicals involved;
• Volume of product processed or used;
• Scope of regulations impacting operation of those being assessed;
• Risk of operation being performed (i.e. blending vs. reaction);

126
• Knowledge of third party's past record; and
• Results from initial screening.
These factors also would be used to determine if an on-site audit is desirable or if a survey or another
assessment could be used. The scope of the assessment also must be determined. For example, the
assessment may be specific to the product and/or process related to the product received from the
supplier, or that shipped to a contract manufacturer, customer or distributor? It may include general
information relative to the entire operation at the facility being reviewed?
127
F. Assessment Follow-up and Feedback Procedures
Consider how the results of the assessment will be communicated and used.
"Survey type" assessments may be used to prioritize site visits, with minimal feedback to the third party
being assessed. Site visit reports may include more detailed feedback regarding areas of concern or
needed improvement. The degree of needed improvement may direct the timing and type of
communication used.
It is important to remember that the intent of the assessment is to "work with" supply chain partners to
foster proper handling, use, recycling and disposal of chemical products.
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APPENDIX A
CONTRACT MANUFACTURER ASSESSMENT GUIDELINES

The following information is provided to assist companies in developing specific survey or site visit protocols
for the operation under contract or being considered for a contract. The specific questions or items below are
provided as examples that could be used in the contract manufacturer assessment process. All member
companies and Responsible Care Partners are reminded that company counsel should be consulted prior to
conducting contract manufacturer assessments. Companies may have an internal checklist for manufacturing
operations which could be acceptable.
The detail or depth of any company-specific program or individual assessment will be determined by many
factors including:
In general, the surveys or protocols used could contain information regarding the following areas:
1. General administrative site information;

2. Regulatory compliance issues in environmental, safety, health and transportation;
3. General management issues such as waste minimization, housekeeping and community outreach;
4. Specific document requests or reviews; and
5. Items or issues specific to the contract or potential contract.
The items below could be considered under general areas of assessment.
1. General Administrative Site Information
A. Company name/mailing address;
B. Name, title and telephone number of person completing survey or accompanying site assessors;
C. Names of assessors;
D. Type of operation being conducted;
E. Types or names of other operations at the facility;
F. Site history/profile;
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G. Current organization structure;
Number of employees at the site; and whether the company is a member of the American Chemistry Council
and committed to the Responsible Care initiative; or, if not, committed to a similar process A copy of the this
process may be desired.
(NOTE: If committed to the Responsible Care or a similar process, commensurate with risk, the option
of not requiring any additional information might be considered. Assessors also might consider
requesting a copy of the company's last Self-Evaluation.)
1. .
2. Regulatory Compliance Issues
A. Environmental - Air Emissions
1. Is the site required to submit SARA 313 reports? If so, have they been submitted?
2. Has an emissions inventory been conducted at the site?
3. Does the site utilize any of the following control devices:
a. flares?
b. stacks and vents?
c. incinerators?
d. adsorption devices?
e. scrubbers?
4. What is the permit status of the site?

5. Have any permit exceedances occurred in the past years?
6. Has air modeling been done to assess the off-site impact of emissions?
7. Have any complaints been received from surrounding neighborhoods or citizens?
8. Does the company monitor air quality?
9. If so, how does the company monitor air quality? How often?
10. What issues exist specific to the production or potential production of the product?
11. What follow-up actions are required before a contract is continued or executed?
B. Environmental - Wastewater
1. Does the facility discharge directly to a water body or to a POTW?

2. Does the facility have a NPDES permit? If so, what is its status?
3. Does the facility have a storm water permit? If so, what is its status?
4. Does the facility have on-site wastewater treatment? If so, describe the system.
5. How does the plant monitor the wastewater quality?
6. Have there been any permit violations in the past years?
7. Is plant process wastewater segregated from storm water?
8. Are new plant projects reviewed for impact on the wastewater?
Is documentation available?
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C. Environmental - Groundwater
1. Does the plant have groundwater monitoring wells?
2. Has groundwater contamination been detected at or near the site in the past years?
3. Does the plant have groundwater protection measures in place such as:
a. Leak detection on tanks?

b. Secondary containment?
c. Spill clean-up procedures?
d. Other? Describe.
D. Environmental - Hazardous and Solid Waste
1. Does the facility generate hazardous wastes? If so, what are they?
2. Does the facility have a documented waste analysis plan?
3. Does the facility hold any RCRA permits? What is the permit status?
4. Where is hazardous waste stored on-site?
5. Where does the facility dispose of hazardous waste?
6. Have the disposal facilities used by the facility been evaluated?
7. How does the company insure that all hazardous waste shipments are properly manifested?
8. How does the company monitor the return of completed manifests from the receiving site?
9. Does the company have a documented training program for employees handling hazardous
waste?
10. Are waste storage sites appropriately labeled and/or marked?
11. Is the company's waste segregated from other wastes at the site?
12. Have the waste haulers used been evaluated and approved?
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E. Environmental - Spill Prevention and Control Plan
1. Does the plant have a documented SPCC plan?

2. Has the SPCC plan (or state equivalent) been reviewed and recertified by a professional engineer
within the past 2 years?
3. When was the last time the facility had a spill that required implementation of the plan?
4. Is secondary containment provided for all bulk oil or hazardous substance storage tanks?
5. Does the facility have regular drills to test the adequacy of the plan?
6. Does the facility have chemical control procedures?
7. Is there documentation available to demonstrate employee training on the plan?
8. Is the equipment specified in the plan for spill response stored in an accessible and workable
fashion?
9. Has a spill response contractor been identified in the event of a failure of plant equipment or
plans?
10. What issues exist specific to the production or potential production of the company's product?
F. Safety and Health - Emergency Response
1. Does the facility have a written emergency response plan?

2. Have employees been trained in the implementation of this plan? Is training documentation
available?
3. Have drills been held to test the adequacy of the plan and employee training? If so, how often are
they conducted?
4. Has an emergency coordinator been appointed and trained?
5. Have procedures been identified to instruct personnel and notify local response agencies in the
event of an emergency?
6. Are there procedures in place to ensure that all appropriate governmental agencies are notified?
7. Are there procedures in place to notify the surrounding population?
8. Have local emergency response personnel been given a tour of the facility?
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G. Safety and Health - Occupational Exposures
1. Has the plant monitored employee exposures to chemical and physical hazards?
2. Does the plant have a written program for:
a. Hazard communication?
b. Respiratory protection?
c. Confined space entry?
d. Medical surveillance?
e. Other? Specify
3. Are there documented training programs for health hazards encountered at the site?
4. To what extent are engineering controls utilized for employee exposure control?
5. Are ventilation and/or exhaust systems adequate to control dusts and/or processing vapors?
H. Safety and Health - General Safety
1. Does the plant have documented safety rules and procedures?

2. Are there documented safety training programs?
3. How many lost-time and/or OSHA recordable injuries did the facility have the past years?
4. Does the plant have a documented accident investigation procedure?
7. Does the plant have TSCA 8(c) and 8(e) recording and reporting procedure?
3. Unloading/Loading/Storage
A. Are construction materials compatible with product unloading, loading and storage?
B. Are there written procedures for unloading, loading and storage of chemicals?
C. Are there written procedures for truck drivers making bulk shipments in or out of the facility?
D. Is there a written hazard communication program to insure that the unloading, loading and
storage workers understand the hazards of the products they handle?
E. Is the unloading/loading/storage area well lighted during all work hours?
F. Does a preventative maintenance system or process exist for the unloading, loading and storage
of equipment?
G. Are unloading/loading/storage workers trained in the use of safety equipment?
H. Are there written procedures for emergencies?
4. General Management Issues

A. Does someone at the facility have specific responsibility for safety and health?
B. Does someone at the facility have specific responsibility for environmental matters?
C. Does the facility have a waste minimization plan?
D. Does the plant have 24-hour security or physical security to prevent unauthorized entry?
E. Does the facility have liability insurance coverage? If so, to what level of coverage?
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5. Specific Documents That May Be Requested
A. OSHA Form 200 (names deleted)
B. SARA 304/311/312/313 reports
C. Copies of permits
D. Safety and health programs (e.g., HAZCOM)
E. Waste manifests for company specific wastes
F. Bill of ladings for company specific shipments
G. Certificates of insurance
134
APPENDIX B
SUPPLIER SURVEY GUIDELINES
Examples 1 and 2
The following pages contain two (2) examples of supplier evaluation documents and are provided to assist
companies in developing specific surveys or site visit protocols of their suppliers. The specific questions or
items are provided as examples of questions that could be used in the supplier evaluation process. All member
companies are reminded that company counsel should be consulted prior to using supplier evaluations.
factors including:
1. Physical and chemical hazards involved in products or chemicals supplied;

2. Volume of product supplied;
3. Scope of regulations impacting operation of those being assessed;
4. Risk of operation being performed (i.e. blending vs. reaction);
5. Knowledge of parties past record; and
6. Results from initial screening.

2. Regulatory compliance issues in environmental, safety, health, handling and transportation;
4. Specific document requests or reviews;
5. Hazard communication; and
6. Energy and natural resource efficiency.
If the supplier has completed a document generated by another company, this document may be acceptable for
another member company's needs.
A review and follow-up procedure should be considered when the survey documents are completed.
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SUPPLIER EVALUATION FORM - EXAMPLE 1
Company Name
Date
Address
Contact
Telephone
Title
Conducted By
Telephone
Title
Product(s)
Use Location Address
General
Answer Yes or No
Is your company a member or Partner of the American Chemistry Council and committed to the Responsible
Care initiative? If yes, please sign the evaluation form and return.
Is your company committed to a similar process for continuous improvement? If yes, which one? Return a copy
of the process and sign and return the evaluation form.
If the response to the previous two questions is no, is the company now willing to commit to the American
Chemistry Council Responsible Care Guiding Principles and Management Practices (copies attached) or a
similar process for continuous improvement?
If no, please explain
Is there anything the American Chemistry Council member or partner conducting this survey can do to assist
you with Responsible Care for the products you supply?
Name of person completing evaluation form (optional)

Title
Date
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SUPPLIER EVALUATION FORM - EXAMPLE 2
Company Name
Date
Address
Contact
Telephone
Title
Conducted By
Telephone
Title
Product(s)
General: Answer Yes or No
Is your company committed to a similar process for continuous improvement? If yes, please identify which one,
return a copy of the process, sign and return the evaluation form.
If the response to the previous two questions was no, is your company now willing to commit to the American
similar process for continuous improvement?
If not, please explain
Does your company have a written safety program?
Do you abide by the Responsible Care Process Safety Code? If so, what is the overall status of your
implementation of that Code?
Does you safety program include:

job observations?
employee safety meetings? If so, how often?
safety inspections and/or audits?
key equipment checks?
standard operating procedures?
safety manual(s)?
If so, do all employees have access to the manual?
Is the manual reviewed and updated? How often?
formal safety indoctrination program?
safety training, including:
CPR?
First Aid?
Fire extinguisher?
Other?
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Material Safety Data Sheets (MSDSs)
Are current MSDSs available for all hazardous chemicals used in your facility?
How are MSDSs made available to your employees?
How are employees trained on the availability and use of MSDSs?
Do you comply with all applicable OSHA regulations?
What OSHA inspections have state or federal agencies conducted in the last 3 years, and were any
noncompliance situations noted?
What is your OSHA recordable incident rate?
Your OSHA lost workday incident rate?
What is your Worker's Compensation Experience Modification Factor?
Do you have a formal incident investigation program in place?
Do you have programs, standards, or procedures to identify and reduce potential health and safety hazards in the
workplace?
Environmental
Is your company implementing the Responsible Care Pollution Prevention Code?
What is the overall status of your implementation of that Code?
Does your company have waste minimization and recycling programs?
What specific plans are in place?
Spill Control and Reporting

What spill control measures do you employ?
Do they meet or exceed regulatory requirements?
Do you have a written spill reporting procedure?
How many episodic releases have you reported to the National Response Center in the past 12 months?
Emissions and Discharges

Do you file a SARA Tier I or II report?
Do you file SARA Section 312 reports?
Do you file SARA Section 313 reports?
What chemicals do you report?
What has been the trend in reporting?
What wastewater discharges do you have?
What permits do you have to cover them?
Describe your air emissions
What permits do you have to cover such emissions?
What inspections have been conducted by regulatory agencies in the past three years?
What violations, if any, were found?
Do you have written policies and procedures describing the proper methods and procedures for waste disposal?
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Emergency Response
Does your company have a written emergency response plan?
Is the plan updated on a regular basis?
How often?
Are drills conducted on a regular basis?
Do they include outside agencies?
Are MSDSs for all hazardous chemicals used at your facility available to emergency response groups in your
community?
Does the local fire department or emergency response team visit your facility and does it have drawings of
material location?
Do you provide emergency response training materials to your customers?
Handling - Receiving. Storage. Shipping

Loading, Unloading and Storage
Do you have written procedures for unloading, loading storing chemical products?
Are construction materials for loading and storage equipment compatible with the chemicals being handled?
Are unloading/loading/storage areas well lighted during all work hours?
Are workers in the load in g/unloading/storage areas trained in the use of safety equipment, standard operating
and safety procedures and emergency procedures?
Do you have a preventative maintenance program for your loading, unloading and storage equipment?
Are drivers instructed to unload only in safe and well-marked facilities?
Shipments of products:
Do you have written procedures for truck drivers delivering or accepting shipments?
Are containers/tankers provided by contract carriers or customers inspected prior to loading to insure they meet
your requirements?
Are procedures in place to insure shipments are properly marked/labeled/placarded?
Are loaded containers inspected by your personnel prior to release from your site?
Are segregation requirements for products during shipment and storage clearly defined and communicated?
Are shipping documents regularly reviewed for accuracy, completion and regulatory compliance?
Are carriers assessed for their ability to transport your products in a safe and secure manner?
Are your loading, unloading and storage facilities built and maintained to minimize releases of chemicals to the
environment or exposure of people?
Do you have diking, grading or other collection systems so any spills do not reach the environment?
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Hazard Communication and Customer Support
Do you have adequate information to assess the risks and hazards of your products on people and the
environment?
What procedures do you have in place to generate up-to-date MSDSs for your products?
What is the procedure for revising MSDSs?
What events trigger changes?
Do you supply product hazard information and safe use instructions in the form of:
MSDSs?
Product labeling?
Information on your product-specific recommended practices and equipment for safe handling, use and
disposal?
Supplementary information, vital to the health and safety of end users?
Describe the procedure your company uses to manage customer generated TSCA 8(c) allegations.
Describe your procedure for communicating TSCA 8(e) significant risk information to your customers.
Describe your procedure for communicating significant new health, safety and environmental risk information
to your customers.
Do you include SARA 313 notification to your customers on your MSDSs?
Are you willing to participate as a partner in Life Cycle Analysis and share data? If so, explain.
Do you offer your products in recyclable/returnable or reusable packaging?
Do you respond to requests for information and assistance for your products on a 24-hour basis, including
emergency support from any point in the supply chain?
Do you ask distributors, carriers and customers to immediately report incidents (e.g., spills, injuries) associated
with the handling or use of your products? If so, what procedures are in place to take corrective action?
Are your distributors and customers assessed on their ability to manage health, safety and environmental risks,
based on your products' chemical and physical properties?
Is there anything that (requestor) can assist you with Responsible Care for the products you supply us? If so,
please specify.
DISTRIBUTORS
Examples for distributors are not included in this document since the American Chemistry Council has
developed a separate "Chemical Distributors' Self-Assessment Protocol."
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APPENDIX C: CUSTOMER SURVEY GUIDELINES
Examples I and 2
The following pages contain two (2) examples of customer survey documents and are provided to assist
companies in developing specific survey or site visit protocols for their customers. The specific questions or
items are provided as examples of questions that could be used in the customer assessment process. All
members companies are reminded that company counsel should be consulted prior to using customer surveys.
factors including:
• Knowledge of parties past record; and
5. Hazard communication.
If your customer has completed a document generated by another company, consideration can be given as to
whether a copy is acceptable for your company's needs.
A review and follow-up procedure should be considered when the survey documents are completed.
To gain more insight as to how your customers' products are being used, consideration could be given to adding
use/exposure data, such as call reports, to existing documents.
141
CUSTOMER SURVEY- EXAMPLE 1
Company Name
Date
Address
Contact
Telephone
(requestor)
Prepared By
Telephone
Title
Signature
Product(s)
Use and Disposal
(completed by requestor)
Overall: Answer Yes or No

Is your company committed to a similar process for continuous improvement? If yes, please identify which one,
return a copy of the process, sign and return the evaluation form.
similar process for continuous improvement? If not, please explain
Hazard Communications
Are MSDSs being received for all hazardous chemicals used in your facility? If not, do you know who to
contact?
What concerns do you have that are not covered by the MSDS?
Is there anything that The American Chemistry Council member or partner requesting this survey can do to
assist you with your Responsible Care of the products?
142
CUSTOMER SURVEY - EXAMPLE 2
Company Name
Date
Address
Contact
Telephone
(requestor)
Prepared By
Telephone
Title
Signature
Products(s)
Use and Disposal
Overall: Answer Yes or No

Care initiative?
Is your company committed to a similar process for continuous improvement?
Note: If the answer to either of the previous questions is yes, commensurate with risk, you may elect to have the
survey signed and returned without continuing.
Chemistry Council Responsible Care Guiding Principles and Management Practices (copies attached) and to
continuous improvement?
Unloading/Loading/Storage
Are construction materials compatible for product unloading/loading/storage?
Do you have written procedures for unloading/loading/storing of chemicals?
Do you have procedures for truck drivers making bulk shipments in or out of your plant?
Do you have a written hazard communication program to ensure that the unloading/loading/storage workers
understand the hazards of the products they handle?
Do you have diking, grading or other collection system to ensure that any spills do not reach the environment?
Is the unloading, loading, and storage area well lighted during all work hours?
Do you have a preventive maintenance program for your unloading/loading/storage equipment?
Are unloading, loading, and storage workers trained in the use of safety equipment?
Do you have written procedures for emergencies?
143
Safety and Environmental
Does the facility have a full-time safety supervisor?
Does the facility have a safety program that oversees:
job observations?
employee safety meetings?
safety inspections?
key equipment checks?
procedures and manuals?
process safety?
management of change?
Do you have a housekeeping inspection program?
Are you implementing the Responsible Care Process Safety Code?
Are you implementing the Pollution Prevention Code?
Does the facility have spill controls meeting regulatory requirements?
Does the facility have a written safety program?
Does it have a written Emergency Response plan?
Does it have up-to-date written standard operating procedures?
Are MSDSs procedures followed for each product?
Are MSDSs reviewed with employees?
Does your company have waste minimization and recycling programs?
Emergency Response Plans

Is the Emergency Response plan reviewed annually?
Are drills conducted on a regular basis?
Do they include outside agencies?
Is fire protection training performed for our chemicals?
144
Hazard Communications: Answer Yes or No

Are MSDSs being received for all hazardous chemicals used in your facility?
If not, do you know who to contact?
What concerns do you have that are not covered by the MSDS?
How are MSDSs made available to your employees?
Are the MSDSs available to emergency response groups in your community?
How are employees trained on the availability and use of MSDSs?
Regulatory
(NOTE: The types of Regulatory Questions could be influenced by product use.)
Do you have written procedures in place to ensure compliance with:

all OSHA regulations?
all TSCA regulations?
(Depending on use, other Regulations/ACTS, may apply i.e. FFDCA, FIFRA)
Do you file SARA Tier II reports?
Do you file SARA 313 reports?
May we have copies of the previous two reports?
Do you have a written spill reporting procedure?
Do you have a water discharge permit?
Do you have an air permit?
Do you have current waste disposal procedures?
Do you have a recycle plan?
Is there anything that (requestor) can do to assist you with Responsible Care for our products?
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APPENDIX D
CUSTOMER CHECKLIST
Rather than having their customers complete a survey, some companies may elect to have their sales
representative or other company employees complete a checklist, either independently or in conjunction with
their customers. All members companies are reminded that company counsel should be consulted prior to using
customer checklists. A formal training program for the individuals who complete these checklists may be
desirable.
The following two pages provide an example of a customer checklist document to assist companies in
developing their own customer checklists.
The detail or depth of any company specific program or individual assessment will be determined by many
factors including:

.
In general, the checklists used could contain information regarding the following areas:

5. Hazard communication.
A review and follow-up procedure needs to be considered when the checklists are completed.
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CUSTOMER CHECKLIST
(EXAMPLE)
1. Product Information
A. What are the principal Environmental, Health, and Safety (HSE) hazards?
B. What competitive products may be substituted for ours?
C. What are the HSE hazards of the competitive products?
What advantages do we have?
D. Does the customer have our MSDS and product information?
2. Product and Packaging Use

A. How does the customer use the product? Are there uses that are unique or new?
B. Do any uses or handling raise potential HSE concerns?
C. Do the customer's employees have access to product information?
D. Are the customer's employees using recommended personal protective equipment?
E. Are recommended protective systems, including local ventilation, in place?
F. Has the customer done workplace monitoring? Should this be done?
G. Is the product stored properly? Storage tanks labeled? Spill containment facilities
(e.g., dikes, curbs)?
H. Does the customer have emergency response procedures in place?
I. What happens to product packaging? Is it reduced, reused, recycled?
3. Product Issues
A. Have there been any incidents involving our product? What was learned?
B. Have any allegations been made regarding the health effects of the product?
C. Environmental effects?
D. Any other issues associated with the product?
4. Product Emissions and Disposal

A. Does any of the product become solid waste or regulated hazardous waste? How is it disposed?
B. Is any of the product discharged to a wastewater treatment system? What becomes of it?
C. Are there any air emissions from the product's use or disposal? What becomes of it?
D. How do the discharges/emissions affect customer permits, compliance?
E. How can we continuously reduce all emissions and waste?
5. Other
A. Can we help in HSE?
(Waste management and minimization; process hazard training; HSE training)
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PRODUCT STEWARDSHIP GUIDELINES FOR
PRODUCT AND PROCESS DESIGN AND MODIFICATION
LEGAL NOTICE
These Product Stewardship Guidelines for Product and Process Design and Modification (Guidelines) have
been prepared to assist members of the American Chemistry Council and Responsible Care Partners in
implementing the Product Stewardship Code of Management Practices. They are intended to provide some
helpful ideas to American Chemistry Council members and Responsible Care Partners, but are not meant to
define any particular steps that should be taken in the implementation process. American Chemistry Council
members, Responsible Care Partners, and all entities involved in the chain of distribution and sale of products
have an independent obligation to ascertain that their actions and practices represent sound product stewardship.
These Guidelines are necessarily general in nature and leave dealing with product and site-specific
circumstances to American Chemistry Council members and Responsible Care Partners. American Chemistry
Council members and Responsible Care Partners may vary their approaches with respect to particular products
or locations based on specific factual circumstances, the practicality and effectiveness of particular actions, and
economic and technological feasibility. It is also understood that the timing and speed of implementation by
American Chemistry Council members and Responsible Care Partners will vary by company, location and
nature of products.
These Guidelines are not designed or intended to define or create legal rights or obligations. American
Chemistry Council members and Responsible Care Partners are, of course, expected to comply with federal,
state and local laws and regulations, and should consult with legal counsel concerning such matters. While these
Guidelines may refer to federal regulations, they are not intended and should not be used to assess regulatory
compliance.
American Chemistry Council does not make any warranty or representation, either expressed or implied, with
respect to the accuracy or completeness of the information contained in these Guidelines; nor does American
information, procedures, conclusion, or opinion in these Guidelines.
COPYRIGHT NOTICE
American Chemistry Council (©1994)
limitations:

2. All copies of the work must include a cover page bearing the American Chemistry Council’s right and
Legal Notice; and
145
OUTLINE
Introduction
Scope
Responsible Care' A Public Commitment
The Product Stewardship Code
Management Practice 7: Product and Process Design

Overview
Suggested Process
Product Conception
Product & Process Development
Commercialization
Post-Commercialization
List of Acronyms
References
146
Introduction
Scope
These Guidelines were developed to assist American Chemistry Council members and Responsible Care
Partner companies with their implementation of the Product Stewardship Code of Management Practices. These
Guidelines are not intended to provide a template that is applicable to all companies, products, or situations.
While each company will have its own unique way of implementing the Code, these Guidelines are intended to
suggest issues to consider in Product and Process Design and Modification. The goal, as with all Responsible
Care activities, is to identify areas where continuous improvement is possible.
Responsible Cared A Public Commitment

Responsible Care is an initiative of the American Chemistry Council to help its member companies improve
their human health, safety and environmental (HSE) performance through sound business and management
practices.
Responsible Care is built around a set of guiding principles, several of which are particularly relevant to the
Product Stewardship Code:
and processes.
• To lead in the development of responsible laws, regulations and standards that safeguard the community,
workplace and environment.
• To practice Responsible Care® by encouraging and assisting others to adhere to these principles and
practices
In order to put the Guiding Principles into action, six Codes of Management Practice provide guidance to
member companies in the areas of (1) Community Awareness and Emergency Response, (2) Process Safety, (3)
Employee Health and Safety, (4) Pollution Prevention, (5) Distribution, and (6) Product Stewardship.
Collectively, the codes address all aspects of chemical manufacturing activities and are designed to guide
American Chemistry Council members in continuously improving their performance.
The Product Stewardship Code

The purpose of the Product Stewardship Code is to make HSE protection considerations integral parts of
designing, manufacturing, marketing, distributing, using, recycling, and disposing of products. The Code covers
147
all stages of a product's life. As a result, successful implementation is a shared responsibility. All parties
involved with a product; manufacturers, suppliers, contract manufacturers, distributors and customers, have
responsibilities to help ensure that products are made, used, and disposed of safely and in an environmentally
sound manner. The specific language of Management Practice #7, as stated in the Product Stewardship Code, is:
148
PRODUCT and PROCESS DESIGN and IMPROVEMENT: Establishes and maintains a system that makes
health, safety and environmental impacts, including the use of energy and natural resources, key considerations
in designing, developing and improving products and processes.
Management Practice #7 is one of the twelve specific management practices that make up the Product
Stewardship Code. It deals with key considerations in designing, developing, and improving products and
processes. It focuses on HSE issues and their impacts, including the use of energy and natural resources.
Through the implementation of Management Practice #7, effective management of product or process risks
should occur and HSE performance should improve.
149
Management Practice #7: Product and Process Design and Modification
Overview
This document provides guidance for establishing and maintaining a system to anticipate or identify HSE
impacts during design, development or modification of products and/or processes. Regulatory compliance and
HSE issues are an integral part of the overall development process. This document is not intended to impair
creativity and innovation or discourage the use of regulated chemicals. Rather, the intent is to encourage
businesses to make prudent choices in developing or modifying products and/or processes. A focus of Product
and Process Design (Management Practice #7) is to consider the environmental management hierarchy':
prevention, recycling (or other reduction methods such as waste to energy), treatment, and disposal.
One of the most effective ways of managing the product risks identified in Product Risk Characterization
(Management Practice #5), whether designing new products or processes or modifying existing ones, is to
consider HSE impacts throughout the product life cycle.
Management Practice #7 emphasizes efficient energy and resource utilization. –These are important
considerations for reducing potential adverse environmental impacts and for conservation of natural resources.
Ways to achieve this may include:
• equipment or technology modifications;

• process or procedure modifications;
• product reformulation or design;
• substitution of raw materials; and
• improvements in housekeeping, maintenance, training, or inventory control.
The HSE attributes of the product throughout its entire life cycle should be considered. Re-evaluation should be
considered on a periodic basis, or whenever changes to the product or process are contemplated.
Representatives from functional areas having expertise that may impact risk reduction should be included in the
review. Examples of some functional areas that could be included are: Research and Development, HSE,
Purchasing and Supply, Manufacturing, Engineering, Marketing and Sales, and Distribution.
1
May 28, 1992, Memorandum from F. Henry Habicht II to all EPA Personnel on EPA Definition of Pollution
Prevention.
150
These Guidelines encourage the consideration of HSE issues associated with the product or design early in the
process or conception phase, thereby avoiding potential delays caused by reformulation or redesign later.
Regulatory or design requirements are identified early so that any testing can be built into the product or design
time lines.
Although each company may divide the tasks differently, conceptually it can be viewed as four basic stages,
shown in Figure 1. A company should establish decision criteria and scope of the activities to be conducted at
each stage, as well as the approval criteria necessary to move the project to the next stage.
The depth of the review increases through the various stages of the process. At the end of each stage, the
company can determine whether it is ready to proceed to the next stage, modify the product or process and
repeat current stage, or terminate further activity with respect to the product or process change. For the purposes
of this resource guide, the decision to move to the next stage is referred to as "stage gate approval."
Product Stewardship
Product and Process Development/Risk Management Process
Figure 1 - Four Basic Stages of Product Development where Product Stewardship

Concepts can be incorporated.
Within these stages are various activities necessary to proceed to the next stage, as shown in Figures 2 - 5. This
process should assist the company in considering the following activities:
Consideration of designs for products that can be manufactured, distributed, used, and disposed of properly;
Selection of less hazardous and more environmentally responsible options among product materials,
components, and processes; Identification of means for more efficient use of energy and natural resources;
Emphasis on the preferred environmental management hierarchy, i.e. prevention (source reduction), reuse,
recycling, and safe disposal; and Management of the impact of regulatory compliance on a company and its
customers.
The process is interactive. All factors are interrelated and should be considered during each of the phases of a
product life cycle. These Guidelines are offered to stimulate awareness and planning, not as an all-inclusive
checklist.
Source reductions include equipment or technology modifications, processor procedure changes, product
reformulation or design, substitution of raw materials, and improvements in housekeeping, maintenance,
training, or inventory control. For example, changing waste to energy that can be used to generate steam or
electricity that is consumed within a facility could be considered source reduction.
151
Suggested Process
Companies should establish and document a process to review and evaluate Product and Process Design at key
stages of development. This review may be accomplished by building a team with appropriate staff, divisional
experts, and business representatives. The team should consider HSE issues and concerns associated with each
life cycle stage and develop options for addressing these issues and concerns. Each option can then be evaluated
for its benefits, as well as any new issue and concerns it raises. This is a continuous process, with each
progressive stage increasing in level of detail and scrutiny.
It is important to recognize that this process is not necessarily simple or easy. Through repeated evaluations, the
objective is to decide which option provides the appropriate balance of product performance, benefits, risks, and
risk management.
If the product is introduced to the market, the risk management plan should provide for an on-going procedure
to monitor the use of the product and report information on new uses, misuse or adverse effects. This
information would trigger risk re-evaluations and potential re-design of the product or process.
STAGE 1: PRODUCT CONCEPTION

This is the first stage in the process and involves input from technical, manufacturing and regulatory areas.
Some issues and considerations are described in Figure 2 below that may be applicable to the conception of a
product or process. The list is not intended to be all-inclusive, but rather a starting point for data collection
activities. Other considerations can be included as appropriate for the product or process or as required by your
company or business unit.
Figure 2 - Issues and Considerations of Product Conception Stage

Stage 1: Product Conception
1. Health Information
2. Physical Characteristics
3. Environmental Information
4. Intended Use/Users
5. Preliminary Regulatory Assessment
6. Other Considerations
Stage 2: Product Process Development
Stage 3: Commercialization
Stage 4: Post Commercialization
The following issues and considerations may be addressed in Stage 1, Product Conception:
1. Health Information
• General health and safety design factors based on an initial assessment of intended uses and
markets to be targeted with the new product or chemistry.
• Initial assessment of health and safety information from relevant references including MSDSs,
industrial hygiene manuals, RTECS, NIOSH Criteria Documents, OSHA Standards, ACGIH
TLV documentation, and other readily-available documents focusing on product components.
2. Physical Characteristics
• Initial physical characteristics required by the intended product uses or chemistry to enable
evaluation of HSE impacts.
152
• Specific physical characteristics to avoid in either raw materials, intermediates, or the product in
order to minimize HSE risks.
3. Environmental Information
• General environmental design factors based on an initial assessment of intended uses and markets to
be targeted with the new product or chemistry.
• Initial assessment of environmental information from relevant references including MSDSs, RTECS,
EPA standards and guidance documents, Environmental Effects of Organic Chemicals, and other
readily-available documents.
• Potential emissions expected. Likely media for those emissions, i.e. air, wastewater, etc.
153
4. Intended Use/Users
• Customer design requirements, product performance expectations and limitations.
• Company's policies on chemical use. Intended area of intended usage, i.e. whether widespread or
geographically localized.
• Anticipated product use, i.e. solely as an intermediate that is chemically converted to other materials,
or widely used in consumer or industrial applications.
• User's capable of handling chemicals safely, i.e. experienced or relatively unsophisticated.
• Numbers and types of users,. i.e., age, occupation, gender, etc.
• Likely customer requirements for handling, use and disposal.
• Health, safety, societal, regulatory, and environmental concerns associated with the new product
throughout the product's life cycle and effect on customers.
5. Preliminary Regulatory Assessment

• Regulatory requirements pertaining to product composition or use.
• Timing required for global regulatory submissions and/or toxicity and environmental permits
associated with market introduction.
• Training of R&D, manufacture, and marketing staff to design products and processes to underscore
product stewardship objectives.
• Customer, public, and company perception regarding product use and disposal.
• Type of process, i.e. continuous/batch, open/closed, etc.
• Potential production volumes.
• Appropriate review system to evaluate the impact of proposed product and process changes.
• Employee or customer suggestions for product improvements.
• Potential methods of disposal.
STAGE GATE APPROVAL

At the end of this stage, the company can determine whether to continue to Stage 2, modify the product or
process and repeat Stage 1, or terminate further activity relative to the product or process change.
STAGE 2: PRODUCT and PROCESS DEVELOPMENT

This stage further expands the Stage 1 activities to build toward commercialization. The major difference
between Stages 1 and 2 is the increased level of detail and depth of review in Stage 2. Figure 3 below describes
some of the activities that may be included in this stage. This list is not intended to be all-inclusive, but rather to
be a starting point for data collection activities. Other considerations can be included as appropriate for the
product or process or as required by your company or business unit.
Figure 3 - Issues and Considerations of Product and Process Development Stage

Stage 2: Product Process Development
1. Physical/Chemical Data
2. Initial Exposure Assessment
3. Basic Toxicological Data
4. Basic Ecotoxicological Data
5. Regulatory Data end Requirements
6. Pollution Prevention/Waste Minimization
154
7. Distribution
8. Life Cycle Principles
9. Manufacture and Storage
155
The following issues and considerations may be addressed in Stage 2, Product and Process Development:
1. Physical/Chemical Data
• Alternative chemistries that will result in lower HSE risks, i.e., potential harm to health or the
environment, risk of regulatory liability or an adverse public reaction.
• Physical/chemical properties and hazards of the product.
• Relative hazards associated with different materials which might impact workers, the
environment and the community.
• Characterization of product's chemical identity.
• Identification of significant impurities or components. Has the information upon which the
characterization is based been obtained on a sample that is representative of the product to be
commercialized?
• Similarities to other well-characterized substances and/or mixtures.
2. Initial Exposure Assessment

• Likely routes of exposure.
• Potential exposure for contract manufacturers and customers.
• Exposure with parent compound and/or breakdown product.
• Human exposure and environmental release of the parent compound or an altered product from
product use and disposal. Types of populations and environments potentially exposed to the
product.
• Sources of potential human exposure to the product, i.e. direct worker, consumer, or
environmentally mediated.
• Aspects of the customer's use and handling of the product and the potential for misuse.
• Estimated volume and intended market.
3. Basic Toxicological Data

• Selection of materials and components, whenever appropriate, to minimize toxicity in the
manufacturing process and final product.
• Thorough literature search and structure activity relationships (SAR).
• Hazards and/or exposures testing, appropriate to likely uses, and disposal.
4. Basic Ecotoxicological Data

• Environmental media most likely to be impacted.
• Substance stability, i.e. persistent or decomposed by the environment, bioaccumulation.
• Environmental fate.
• Impact of material or degradation products.
• Environmental organisms most likely to be affected by releases of the product.
• Species most useful for predicting environmental toxicity.
• Contribution to formation of smog/global warming/stratospheric ozone depletion/accelerated
eutrophication.
• Potential testing.
156
5. Regulatory Data and Requirements
• Formal HSE process review which includes air, water, and waste emissions; VOCs; SARA 313
chemicals; RCRA hazardous wastes; ozone-depleting chemicals; heavy metals; persistent and
bioaccumulative chemicals; known carcinogens; new chemicals in categories of concern to the
Environmental Protection Agency (EPA).
• MSDS/label development.
• Inventory notification requirements identified and reviewed.
6. Pollution Prevention/Waste Minimization

• Systematic analysis of each process waste, i.e.. routine scrutiny of opportunities to reduce energy
consumption, recycle by-products, or reduce environmental impacts resulting from processing.
(Refer to the American Chemistry Council Guideline document "Designing Pollution Prevention
Into the Process, Research, Development and Engineering" for information on a basic approach.)
• Use of recyclable or renewable materials, when applicable.
• Environmental hierarchy in selecting components.
• Product design specifically to minimize waste, by-products and emissions resulting from use of
the product.
• Product or process modifications to reduce or eliminate by-products and wastes.
7. Distribution
• Identification of hazards associated with materials being transported, and appropriate precautions
for safe handling.
• Appropriate modes of transportation, packaging and label requirements for each product.
• Emergency response to releases, i.e. land, water, or air.
• Amount of use and geographic diversity of locations of use.
• Methods of shipment.
• Quantities to be shipped.
• Size of containers.
• Potential human or environmental exposure during shipping.
• Adequate spill containment during loading and unloading.
• Likelihood of accidental spillage.
• Control measures taken or being considered.
• Additional regulatory needs for transportation classification.
8. Life Cycle Principles

• Conservation of natural resources by incorporating recycled materials.
• Evaluation of energy or resource consumption for all product and packaging requirements.
• Reduction of overall energy use, i.e. both internal and customer use.
• Improvement through understanding of the product trail.
• Consideration of life cycle concepts in evaluation of products to identify potential impact
reduction.
157
9. Manufacture and Storage
• Inspection and maintenance of product manufacturing operations to ensure that production
equipment operates as designed under original specifications, and does not pose HSE risks by
producing unanticipated hazardous by-products or contaminants.
• Manufacture location.
• Manufacture quantities.
• Loss or escape of contaminants during manufacture.
• Potential for human exposure during manufacture, under both routine and exceptional
circumstances.
• Identification of job assignments with highest potential for exposure. Control measures taken.
• Support materials used in manufacture or handling that may require risk characterization.
• Control measures to minimize loss and accidental releases.
• Storage location, conditions, and capacity.
• Potential exposure of humans or the environment during storage.
• Intended location of use, i.e. non-isolated intermediate, or a site- or company limited
intermediate?
• Control of operating parameters and limits.
• Product stewardship training for new manufacturing staff.

• Internal product stewardship training.
• Customer product stewardship training.
STAGE GATE APPROVAL

When the work in Stage 2 is complete, the company can determine whether to continue to Stage 3, modify the
product or process and repeat Stage 2, or terminate further activity relative to the product or process change.
STAGE 3: COMMERCIALIZATION
This is the commercialization stage, where the new product or process proceeds to the marketplace.
One of the goals at this stage is to consider the customer's ability to use the product in a safe and responsible
manner. When developing safe handling recommendations, the company should identify the reasonably
foreseeable conditions under which the customer will use or misuse the product. Again, there will be some
overlap in the activities in Stages 1 and 2, but the main difference is the depth of review and level of detail in
the data collection.
There are some issues and considerations described in Figure 4 that may be applicable to the conception of a
product or modification of a process. The list is not intended to be all-inclusive, but rather a starting point for
data collection activities. Other considerations can be included, as appropriate, for the product or process or as
required by your company or business unit.
158
Figure 4 - Issues and Considerations of Commercialization Stage

Stage 2: Product and Process Development
1. Suppliers, Distributors, Contract Manufacturers
2. Volume, Customers, Markers, Uses
3. More Life Cycle Information
4. Disposition
5. Full Regulatory Information
6. Risk Characterization
7. Risk Management Activities
The following issues and considerations may be addressed in Stage 3, Commercialization:
1. Suppliers, Distributors, Contract Manufacturers

• Consideration of the ability and willingness of contract manufacturers, distributors and
customers to use products appropriately, based on product risk.
• Reasons for any restrictions.
2. Volume, Customers, Markets, Uses

• Likely volumes, markets/uses, number/types of customers.
3. More Life Cycle Information

• Adequate chemical management throughout the product life cycle.
• Conservation of natural resources by incorporating recycled materials.
• Reduction in overall energy use, including customers' energy use.
• Product improvement through understanding of product trail.
• Identification of potential impact reduction through life cycle evaluation of raw materials,
processes, and products.
• Review of all raw materials and formulations for compliance with company's product
stewardship guidelines.
• Establishment of mufti-disciplinary teams to solicit input from all key staff functions to ensure
that product and process improvements are based on all the stages of a product's life.
• Inclusion of HSE aspects of the manufacturing process in the product risk assessment.
• Calculation of amount of product expected to be released to each of the environmental media, i.e.
air, water, soil.
159
4. Disposition Environmental fate of product.
• Environmental hierarchy (source reduction, reuse, recycle, treatment and disposal) with
consideration for reducing the environmental impact of product and packaging.
• Identification of opportunities for product recycling by customers, i.e. designing packaging to
serve as a second use container.
• Determination of most appropriate mode(s) of product disposal to minimize volume and adverse
environmental impacts. Quantities of product disposed of by each media, i.e. air, wastewater, etc.
• Site of disposal, i.e. local or general.
• Likelihood of accidental spillage during disposal.
• Concentrations of product existing in aqueous discharge and in sludge resulting from sewage
treatment.
• Potential for migration to ground water resulting from landfill disposal.
• Potential for human exposure during disposal.
• Need for risk characterization of degradation products resulting from disposal involving
chemical or biological transformation of material.
• Eligibility of product for return and/or for reprocessing.
• Proper cleaning, reuse, recycling, etc. of packaging to minimize exposure to residue.
5. Full Regulatory Information

• Regulatory implications of customer return of product/packaging waste.
• Competitive, regulatory and liability ramifications.
• Opportunities for competitive advantage by assisting customers in dealing with regulatory
constraints.
• MSDSs, labels, PMNs, etc.
6. Risk Characterization
• Preparation of written protocol to systematically evaluate risks.
• Characterization of pertinent risk (human health, environmental compatibility, physical safety,
regulatory compliance, public perception and strict liability) at each stage of the product's trail.
• Consideration of potential emission of chemicals during application, particularly at elevated
temperatures.
• Establishment of systems to anticipate and respond to significant changes throughout the
product's commercial lifetime, such as a change in markets (e.g., from industrial to consumer,
heath care to industrial or consumer, etc.), in customer applications, in process, in volume, or in
manufacturing sites.
7. Risk Management Activities

• Periodic assessment of customer feedback and market penetration to ensure that prior risk
assessment assumptions hold true.
• Modifications to the product and/or process, as appropriate.
• Additional literature, training, and/or MSDS or label modifications, as needed.
• Customer need for education and training regarding regulations.
• Customer need for education and training regarding safe and effective product use and disposal.
160
STAGE GATE APPROVAL
When the work in Stage 3 is complete, the company can determine whether to continue to Stage 4, modify the
product or process and repeat Stage 3, or terminate further activity with respect to the product or process
change.
STAGE 4: POST-COMMERCIALIZATION
The goal of post-commercialization is to validate precommercial assumptions and provide feedback for design
improvement. This information may be obtained from marketing and sales personnel, employees, and/or the
risk characterization process. This feedback may change the risk management actions (Management Practices
#6 and #8) and may trigger product or process redesign or modification.
Figure 5 - Issues and Considerations of Post-Commercialization Stage


Stage 2: Product and Process Development

1. Performance Review
2. New Use/Misuse Considerations
3. Issues and Concerns
4. Additional Hazard Data
5. Additional Exposure Data and Assessment
6. Disposal Considerations
7. Review and Update Risk Characterization
The following issues and considerations may be addressed in Stage 4. Post-Commercialization:
1. Performance Review
• Gather and evaluate feedback on customer's and distributor's suggestions for improvement in
product design relating to handling, use, and disposal, and provide this information to those
involved with future product modifications.
• Appropriate improvements can only be made when product-related expectations are dearly
understood.
• Gather information on customers' limitations in technical expertise and safety capability in
product handling, exposure, use, or disposal.
• Solicit customer feedback on product use from marketing and sales staff. Channel this feedback
from marketing and sales staff to those involved in modifying products and manufacturing
processes. Marketing and sales staff can provide feedback on customers' requirements for
handling, use, and disposal.
• Incorporate HSE issues associated with the product in product design reviews, in evaluation of
customer uses, and in development of disposal options.
161
2. New Use/Misuse Considerations
• Determine if there are any new uses/misuses for the product.
• Determine if current literature and warnings are appropriate to these new uses/ misuses and
modify as necessary.
• Take steps to stop or prevent misuses that could result in potential harm to humans or the
environment.

• Evaluate any unresolved issues and concerns with prior known uses and misuses.
4. Additional Hazard Data

• Review the most recent available literature, update prior hazard data and risk assessments, and
make necessary enhancements as required.
5. Additional Exposure Data and Assessment

• Review the need for additional exposure data based on prior uses/misuses and new uses/misuses,
and if existing data are not sufficient, determine the need for additional data.
6. Disposal Considerations
• Update prior disposal assumptions and provide additional guidance, services, training, or product
modifications, as appropriate.
7. Review and Update Risk Characterization

• Review and update, as appropriate, prior risk assessments based on the above.
• Consider changes in technology, volume, new uses, etc., as triggers for new risk characterization.
• Share HSE information with counterparts in other companies. The American Chemistry Council
membership network can provide you with resources for ideas and suggestions.
• Identify new marketing opportunities and potential concerns arising from this management
practice.
• Consider public perceptions.
• Consider HSE impacts on the process and on end product composition resulting from otherwise
"insignificant" changes in processes.
• Review specifications to consider whether minor components that could pose HSE impacts are
included in the specifications.
162
References
1. May 28, 1992, Memorandum from F. Henry Habicht II to all EPA Personnel on EPA Definition of
"Pollution Prevention."
2. Designing Pollution Prevention into the Process Research, Development and Engineering. American
Chemistry Council, 1993.
163
Environmental Acronyms
ACGIH TLV American Conference of Governmental Industrial Hygienists -Threshold Limit Value
EPA Environmental Protection Agency
HSE Health, Safety, and Environmental
MSDS Material Safety Data Sheet
NIOSH National Institutes for Occupational Safety and Health
PMN Premanufacture Notification
R&D Research and Development
RCRA Resource Conservation and Recovery Act
RTECS Registry of the Toxic Effects of Chemical Substances
SAR Structure Activity Relationships
SARA Superfund Amendments and Reauthorization Act
SARA 313 That portion of SARA pertaining to the requirement for a toxic release inventory list
VOCs Volatile Organic Compounds
164
Product Stewardship Guidelines for Risk Characterization/Risk Management
LEGAL NOTICE
These Product Stewardship Guidelines for Risk Characterization Risk Management ('Guidelines') have been
prepared to assist members of the American Chemistry Council and Responsible Care Partners in implementing
the Product Stewardship Code of Management Practices. They are intended to provide some helpful ideas to
American Chemistry Council members and Responsible Care Partners, and are not meant to define any
particular steps that should be taken in the implementation process. Members, Partners, and all entities involved
in the chain of distribution and sale of products have independent obligations to ascertain that their actions and
practices represent sound product stewardship.
These Guidelines are necessarily general in nature and leave dealing with product and site-specific
circumstances to members and partners. Members and partners may vary their approaches with respect to
particular products or locations based on specific factual circumstances, the practicality and effectiveness of
particular actions, and economic and technological feasibility. It is also understood that the timing and speed of
implementation by members and partners will vary by company, location, and the nature of products. These
Guidelines are not designed or intended to define or create legal rights or obligations. Members and partners
are, of course, expected to comply with federal, state and local laws and regulations, and should consult with
legal counsel concerning such matters. While this resource guide may refer to federal regulations, it is not
intended and should not be used to assess regulatory compliance.
respect to the accuracy or completeness of the information contained in this resource guide; nor does the
American Chemistry Council assume any liability of any kind whatsoever resulting from the use of or reliance
upon any information, procedures, conclusion, or opinion in this resource
guide.
COPYRIGHT NOTICE
© American Chemistry Council (1994)
limitations:

2. All copies of the work must include a cover page bearing the American Chemistry Council’s
notice of copyright and Legal Notice; and
165
Table of Contents
Introduction
Risk Characterization/Risk Management
Overview
Hazard Evaluation
Typical Hazard Evaluation Questions
Exposure Evaluation
Typical Exposure Evaluation Questions
Risk Characterization
Review Current Risk Management
Is Risk Management Adequate?
Examples of Potential Additional Risk Management
Case Examples
Case #1: New Material with Widespread Distribution
Case #2: Existing Material with Limited Distribution and Use
Case #3: Existing Material with Limited Distribution - Chemical Intermediate
Case #4: Residual Monomer in Polymer
Definitions
Acronyms
Bibliography
166
Introduction
These Guidelines were developed to assist members and partners implement the Product Stewardship Code of
Management Practices. While each company will have its own unique way of implementing the Code, these
Guidelines are intended to provide some helpful ideas on designing a process for Product Risk Characterization
and risk management.
The Guidelines are not intended to provide a checklist that is applicable to all companies, products or situations,
but rather to help identify some of the factors that might be considered in risk characterization and risk
management. The goal, as with all Responsible Care activities, is to identify areas where continuous
improvement is possible so that chemicals can be manufactured, transported, handled, used, recycled and
disposed of safely.
Responsible Care: A Public Commitment

Responsible Care is an initiative of American Chemistry Council to help its member companies improve their
human health, safety, and environmental (HSE) performance through sound business and management
practices.
Responsible Care is built around a set of guiding principles, several of which are particularly relevant to the
Product Stewardship Code:
• To make HSE considerations a priority in planning for all existing and future products and
processes;
• To develop and produce chemicals that can be manufactured, transported, used, and disposed of
safely;
• To extend knowledge by conducting or supporting research on the HSE effects of chemical
products, processes, and waste materials;
• To counsel customers on the safe use, transportation, and disposal of chemical products;
• To report promptly to officials, employees, customers, and the public, information on
chemical-related health or environmental hazards and to recommend protective measures; and
• To promote the principles and practices of Responsible Care by sharing experiences and offering
assistance to others who produce, handle, use, transport, or dispose of chemicals.
In order to put the Guiding Principles into action, six Codes of Management Practices provide guidance to
member companies in the areas of 1) Community Awareness and Emergency Response, 2) Process Safety, 3)
Employee Health and Safety, 4) Pollution Prevention, 5) Distribution, and 6) Product Stewardship. Collectively,
the codes address all aspects of chemical manufacturing activities and are designed to guide American
Chemistry Council members in continuously improving their performance.
167
Risk Characterization/Risk Management
Purpose
The purpose of the risk characterization/risk management process .is to identify and implement appropriate
systems to enhance product safety. The process employs –the use of management practices to enable
understanding and management of human and environmental risks at every stage of a product's life.
The purpose of this document is to provide companies with a framework for understanding the risk
characterization and risk management process consistent with Management Practices #4, #5, and #6 of the
Product Stewardship Code. The overall purpose of the Product Stewardship Code is to make HSE protection an
integral part of designing, manufacturing, marketing, distributing, using, and recycling or disposing of the
products. Management Practices #4, #5 and #6 specifically address risk characterization and risk management
as shown below.
HEALTH, SAFETY and ENVIRONMENTAL INFORMATION: Establishes and maintains information on
health, safety, and environmental hazards and reasonably foreseeable exposures from new and existing
products.
PRODUCT RISK CHARACTERIZATION: Characterizes new and existing products with respect to their risk
using information about health, safety, and environmental hazards and reasonably foreseeable exposures.
Establishes a system that initiates re-evaluation.
RISK-MANAGEMENT SYSTEM: Establishes a system to identify, document, and implement health, safety and
environmental risk-management actions appropriate to the product risk.
The intent of this document is to provide an understanding of the general process of risk characterization and
risk management through a description of the steps involved.
168
Overview
Information about product hazards and foreseeable exposures to the product are evaluated considering current
risk management practices. This evaluation provides information for developing a comprehensive risk
management program to be used to control risks of adverse impacts at all stages of product life from design,
manufacture, marketing, distribution, use, recycling, and disposal.
The evaluation of risk and conduct of risk management is a continuous process. (See Figure 1.) Hazard and/or
exposure information, along with information on use or use conditions, can change over time. Periodic review
of information and practices is needed to ensure that appropriate risk management practices are up to date and
fully implemented.
A company should consider documenting the results of the process for two reasons:
1. the documentation will make it easier to identify and implement the appropriate risk
management activities, and
2. a summary record of deliberations and conclusions will save time and resources by serving as a
starting point for updates and follow-up actions.
Hazard Evaluation
A hazard evaluation considers information on potential adverse effects on HSE and dose response relationships,
which leads to an understanding of the potential of the product to cause harm to human health or the
environment.
The hazard evaluation may include:

• Physical characteristics of the material, including form (liquid, solid, dust, etc.);
• Other characteristics that could affect exposure potential, such as vapor pressure, particle size, or
density;
• Chemical properties, such as reactivity, flammability, stability, explosivity, corrosivity, and
potential for decomposition;
• Characterization of the ecological fate and potential ecological effects; and
• Toxicological properties of the material.
Additional information may be obtained by comparing the product to similar substances. For new products, or
products where information is inadequate, testing may be needed. Testing needs are best determined by
reviewing potential exposure patterns from the product trail.
Sources of information for hazard evaluation include, but are not limited to: toxicology testing, clinical case
reviews, epidemiology studies, ecotoxicity testing, and vendor hazard communication information. If the
potential for recurrent or chronic exposure is expected, additional studies to evaluate effects such as target organ
subchronic toxicity, carcinogenicity, genotoxicity, sensitization, developmental and reproductive toxicity may
be deemed necessary. The need for, and priority of any additional studies will be made on a case-by-case basis.
The American Chemistry Council Hazard Characterization Resource Guide provides more detailed information
on assessing the potential hazards of chemical products. Case examples of hazard evaluation of new and
existing products may be found in this document. Additional information for hazard evaluation may be found in
the bibliography.
169
Typical Hazard Evaluation Questions
Because each product is unique, the hazard evaluation should be specific to a product and potential exposures.
The following questions are included to assist the translation of general principles into the evaluation of
individual products or groups of products:
Physical Hazards
• Assess flammability, explosive potential, reactivity, incompatibility
• Assess effects from contact (e.g., irritation, corrosiveness).
Human Health Hazards

• What is known of the mammalian toxicity (acute - such as toxicity, eye and skin irritation,
sensitization; subchronic; chronic - such as carconigenicity, teratogenicity, fertility and
reproduction; mutagenicity; neurotoxicity; etc.)?
• What are the likely routes (such as ingestion, inhalation, dermal, etc.) of human exposure to the
product?
• What are the likely target organs (such as lungs, kidneys, liver, skin, eyes, etc.) after exposure to
the product?
• Are there any human data (such as toxicological, health assessments, epidemiological, etc.)? A
• Are there any regulatory or other classifications in effect for the product?
Resource Optimization
• How efficient is our manufacturing?
• How efficient is our customer use?
• What happens to product packaging?
Product Identity
• Have the product's identity and physical and chemical properties been characterized?
• Have all significant components or impurities been identified?
• Has the information used to characterize the product been based on a sample that is
representative of the commercial product?
170
Exposure Evaluation
Exposure evaluation considers the magnitude, frequency, duration, and route of potential human and
environmental exposures. It also considers the nature, size and constitution of the potentially exposed
population. Important factors in characterizing potential exposure include conditions of packaging,
transportation, storage, use, reuse, and disposal. Identifying the risks posed by any material requires an
understanding of how and when it may come into contact with humans or the environment.
It may be difficult to conduct an exposure evaluation for a new product or new application if there is little
background information or historical data to examine. However, information on products being used in similar
ways or those made of chemically similar materials (structural analogs) may be reviewed and used in making an
evaluation.
In general, exposure evaluation begins with identifying potential routes) of exposure. Description of a product
trail analyzing all product uses may be helpful. The product trail may include evaluation of exposure potential
for employees, contract manufacturers, suppliers, distributors, and customers.
Human exposure may occur at many points during a product's trail and through many pathways. Workers may
be exposed during R&D activities, manufacture, transport, processing, or disposal. Consumers may be exposed
during use. Environmental releases may occur at any point in the product trail and may expose any number of
organisms. Human exposure is possible through multiple pathways including air, food, water, or soil.
171
Typical Exposure Evaluation Questions
Questions to consider regarding human exposure potentials may include the following:
• Are users typically industrial? Consumer? Both?

• What is or will be the product trail?
• What quantities of the product are used typically in customer locations?
• How is the product used? (Will it be used solely as an intermediate that is chemically converted
to other materials, or will it remain 'free` to consumer or industrial applications?)
• What are potential exposure routes?
• Do use and disposal lead to human exposure and environmental release of the compound or a
by-product?
• What is the potential for employee exposure (consider typical working conditions)?
• Consider fumes and gases given off during heating (e.g., polymers) or application techniques
(e.g., spraying).
• Is the sales and customer contact feedback system alert to exposure situations?
Questions to consider regarding environmental exposure potentials can include the following:
• What is or will be the product trail?

• What is the potential for environmental exposure through transport and storage, considering
routine practices and volumes?
• Do any emissions/discharges result from customers using, applying, or disposing of our
products?
• Where are these emissions discharged? Into water (streams, on-site waste water treatment
facility, off-site treatment systems, other)? Into air (stack emissions and/or fugitive emissions)?
Into landfills or regulated waste management facility?
• Is pollution abatement, treatment or waste management equipment needed for our product?
• Are discharge permits required for our materials?
• Have there been any unintentional releases, spills, or emissions of our product since the last
review (or in the last year)?
• Have there been any allegations or reports of environmental effects associated with emissions of
our product? Or inadvertent releases?
172
Risk characterization provides information for a sound risk management Program. It involves making
judgments about the likelihood of adverse effects on humans and the environment, which may occur at any
stage of the product trail. It takes into consideration the information from hazard evaluation and exposure
evaluation along with current risk management activities.
The risk characterization process allows the risk manager to identify hazards or exposure conditions along the
product trail that may be key points for risk management activities. Risk characterization considers situations
where exposure concentrations or durations may exceed those considered acceptable for a particular chemical.
The characterization is often qualitative rather than quantitative:
• Identify acceptable exposure levels (for the hazards) for humans or the environment by
completing the Hazard Evaluation;
• Identify potential exposure levels to humans or the environment from use, handling,
transportation, or disposal, by completing the Exposure Evaluation;
• Review current risk management practices to determine what exposures or hazards already have
been reduced or eliminated due to these practices; and
• Compare the likelihood for potential exposures to exceed acceptable levels.
173
Review Current Risk Management
A review of current risk management practices begins with identifying measures already in place to help protect
human health and the environment from hazards of a product or group of products. This should include a review
of the basic risk management tools, the Material Safety Data Sheet (MSDS) and label, delivery systems for the
MSDS and label, as well as any special precautionary instructions, manufacturing quality controls, packaging,
handling, transport or marketing practices designed to reduce risk. Thus, the review team should be aware of
and understand current risk management practices in place.
Risk Management will depend on the applications of the product, the customers, and methods of distribution. In
most instances, the single most effective risk management actions are the MSDS and precautionary labeling
related to the product in order to warn workers and users about hazards of the product and provide information
about ways to avoid potential overexposures. There may be more than one way to manage similar product risks.
For example, one business may manage the risk posed by a flammability hazard by deciding not to sell through
a large number of distributors. Another business may manage the risk by providing product distributors with
additional guidance or training on handling techniques. Both respond to the risk posed by flammability hazard.
Risk management for a new research and development material often initially consists of limited distribution
and careful controls to avoid exposure until product hazards can be determined. As commercialization
progresses and hazards are more clearly identified, appropriate risk management options for wider distribution
and use are available. In general, these activities are designed to limit exposure or reduce hazards.
For existing products, a company looks at products to assess whether existing quality control or quality
assurance programs are adequate to control product HSE impacts, in addition to reviewing known uses and use
conditions in the market place. Other specific risk management practices may be in place to address public
concerns or specific regulatory requirements.
After this review, a company will have a Risk Characterization, or an understanding of the nature, magnitude
and probability of a potential adverse health or environmental effect. This understanding combines results of
exposure and hazard evaluations and the uncertainties associated with each.
174
When risks have been characterized and understood; current risk management practices must be evaluated to
determine whether or not the current control practices are adequate to avoid overexposure, and therefore
preventing adverse impacts to humans and the environment. The objective is to identify additional actions that
are needed for controlling risks.
Additional Risk Management Activities

The type and aggressiveness of risk management efforts depend on the level and nature of potential risks of the
product. Risk management options that may be considered for chemical products encompass a wide variety of
activities along the product trail such as:
• Product Design and Manufacturing,

• Transportation and Handling, and
• Marketing
Specific risk management practices and rationale for selecting them should be documented for future
management reference and review.
Some examples of typical additional risk management activities are listed below. There are many additional
options available and companies will fit practices to specific product situations as appropriate.
Examples of Potential Additional Risk Management
Product Design and Manufacturing

• Change the product form to reduce exposure potential, e.g., convert a powdered product to
pellets to reduce dust, wet or dissolve a dusty product.
• Switch to less hazardous components (formulated products).
• Supply a less hazardous intermediate converted from more hazardous raw materials.
• If critical risk is due to an impurity, reduce the impurity concentration.
• Put in place engineering controls, such as covering containers, using closed piping, install local
exhaust ventilation.
• Encourage use of unique protective equipment during manufacture or handling.
• Determine whether additional toxicity or exposure information would help in product redesign
activities
Transportation and Handling

• Change distribution or packaging practices.
• Use dedicated storage facilities and transportation equipment or provide special training of
involved personnel.
• Qualify carriers in safe product handling practices and equipment.
• Test packaging under unique situations that may exist.
175
Marketing
• Train appropriate personnel in sales or marketing in Product Stewardship code requirements and
encourage them to feedback uses and questionable practices to risk managers.
• Should product recycling or reuse programs be considered?
• Limit certain uses or markets.
• Determine whether the distributor agreements should discourage product comingling.
• Request distributors to report back product uses, adverse effect information and any observed
questionable practices and misuses.
Continuous Improvement
Product risk characterization and management for a product requires periodic re-evaluation and updating.
Product stewardship and the protection of human and environmental health is a process of continuous
improvement.
The risk characterization/risk management process must have standard procedures in place for re-evaluating and
up-dating practices. The review process should be initiated on a predetermined periodic review schedule and
whenever a significant change occurs.
Periodic Reviews
A periodic review is recommended for all risk characterizations. The frequency of review should be decided
during the initial risk management planning stage. The frequency may depend on risk level. Higher risk
products may warrant a more frequent review cycle. Lower risk products may require a less frequent review
cycle.
Significant Changes
If there is a significant change in the information that was available when the initial risk characterization was
made, then an immediate review is required. Types of information that may initiate interim reviews include
significant new information in:
• Hazards or exposures,
• Uses or misuses,
• Increases in the number of customers or sales volume,
• Regulatory changes,
• Information from audits and inspections, or
• Customer concerns, complaints or TSCA 8(c) allegations, etc.
Feedback
The implementation of Management Practice #8, "Employee Education and Product Use Feedback," from the
American Chemistry Council Product Stewardship Code, provides a mechanism for channeling much of this
information back into the risk characterization review process. A carefully structured and well-defined product
risk management review process can improve a company's ability to respond efficiently and effectively to
changing safety needs and provides a strong foundation for a continuous Product Stewardship program.
176
Case Examples
The following hypothetical examples are presented to illustrate the process. They are not complete analyses.
Evaluations are specific to the cases presented and should not be generalized.
Case #1: New Material with Widespread Distribution -Household Detergent Ingredient Product Identity
The ingredient is a dusty solid with particles small enough to be inhaled. It is highly soluble in water.
Hazard Evaluation Information Development Strategy

Since consumer exposure is greater than worker exposure in the manufacturing plant, potential hazards to
consumers are given greater priority. Potential hazards to organisms in the aquatic environment also are
considered because the produce may ultimately be released to the aquatic environment.
Human Health Effects

The potential human health hazards of concern for a product such as this are short-term systemic effects by all
three routes: oral, dermal, and respiratory. Information is gathered and evaluated to determine whether or not
exposure to the chemical may cause irritation to eyes, skin, and respiratory tract; dermal sensitization;
reproductive and developmental toxicity; and longer-term systemic effects. Based on the information, it was
determined that the ingredient is irritating to eyes and skin, but is not a sensitizer, reproductive, or
developmental toxin.
Environmental Effects
Since the chemical may be released into the aquatic environment, information is collected and evaluated
regarding the chemical's short-term and long-term effects on aquatic organisms. The material is acutely toxic to
a wide variety of aquatic organisms in the concentration range from 1-10 mg/L. Its chronic toxicity is ten times
lower. It is readily biodegradable, with a half-life in river water of less than one day.
Manufacture, Transportation, Use, and Disposal

The undiluted ingredient will be manufactured at one site and transported in bulk by rail to several formulating
plants across the country, where it will be blended into the final detergent product. This product will be used in
homes throughout the country. After use, the detergent is discharged into sewer systems or septic tanks. After
appropriate wastewater treatment, it may enter surface waters or ground water.
Human and Environmental Exposure

The potential market for such an ingredient is very large, estimated to be 0.5 - 1 billion lbs. per year. Workers
who manufacture and blend this product, consumers who use it, and organisms in the aquatic environment are
the populations that are potentially exposed to the hazards of this material.
Exposure Evaluation
While there may be limited exposure to a detergent ingredient during manufacture, the exposure potential is
significantly greater for the consumer. Exposure may be by respiratory contact, dermal contact, or oral contact.
Respiratory and dermal exposures can easily be modeled and quantified.
Respiratory Contact
Consumers may be exposed to powder detergents by inhaling particles, which become airborne when the
detergent is poured from the box. This pouring process can be simulated in the laboratory and the airborne
concentration of the detergent particles in the breathing zone and the duration of exposure can be measured.
177
Dermal Contact
A second exposure potential is dermal. It is not uncommon for the person doing the laundry to place his or her
hands into the wash water to distribute the clothes or to retrieve or add an article of clothing. Again, the
concentration of the ingredient in the wash water and the duration of contact is easy to calculate or measure.
Another common practice is for the launderer to prepare a paste or slurry of detergent and apply it by hand to a
stain or soiled spot on the fabric. This exposure concentration may be relatively high and last for a minute or
two.
A third example of dermal exposure is by contact with clothing containing a detergent residue. While this
concentration is typically very low, the contact period may be 14-16 hours, resulting in significant exposure
potential.
Oral Contact
A third human exposure potential is via drinking water. Most detergent ingredients are discharged into a sewer
system where they undergo a sewage treatment process. The treated wastewater is discharged into a waterway
or, in some areas, used for irrigation. This surface or ground water eventually may be the source of municipal
drinking water or well water. Thus it is important to study the environmental fate of these ingredients in order to
estimate their removal and their potential for human contact through drinking water.
Ecological Exposure.
Ecological exposure includes the surface water and ground water described in the preceding paragraph. In
addition, exposure may result from detergent ingredients, which are absorbed into sewage sludge. This sludge
accumulates in the treatment plant and is periodically removed and used as a soil conditioner and fertilizer. The
fate of the ingredient in soil must be determined to fully characterize exposure potential to terrestrial plants and
animals.
Current Risk Management

The MSDS warns that the product is irritating to the skin and eyes. Typical use levels in detergents (20%) result
in sewage concentrations of about 3-8 mg/L. Removal during sewage treatment is <98%. Consumer contact is
limited because of dilution in the wash water. The detergent box carries a statement that unused product should
be disposed of down the drain so it will biodegrade during sewage treatment.

Reports of adverse effects in consumers are limited to occasional skin or eye irritation. There is an adequate
margin of safety between concentrations in the aquatic environment and concentrations, which would cause
adverse effects. There is no buildup after 30 years of use. Risk management is adequate.
178
Case #2: Existing Material with Limited Distribution and Use - Specialty Hydraulic Fluid,
Product Identity
The hydraulic fluid product is a liquid formulation of several components with a high octanol-water partition
coefficient. While the product has a low viscosity, it may form mists under some use conditions.
Hazard Evaluation Information Development Strategy

The potential hazards associated with incidental consumer contact are considered. Because of use and disposal
patterns, potential hazards to organisms in the aquatic environment also are considered.

The potential human health hazards of concern for this product short-term systemic effects from respiratory or
dermal contact. This contact could potentially cause irritation to eyes, skin, and respiratory tract, and dermal
sensitization. Information is collected and evaluated to determine the potential for these short-term effects, as
well as longer term systemic effects on reproductive and developmental toxicity. Information also is collected
and evaluated on the individual ingredients.
Due to its discharge into surface waters, information is collected and evaluated on the chemical's short-term and
tong-term effects on aquatic organisms. Because of the high octanol-water coefficient, additional evaluations
are performed to determine potential for accumulation of the fluid in the food chain. Information also is
gathered and evaluated on the environmental fate of combustion by-products.

The fluid is manufactured at one site and transported by rail, either in bulk or in 55gallon drums, to factories
across the country where it will be used in heavy equipment operations. During use, the fluid may leak into the
floor of each factory and may be discharged down drains into sewer systems from which it may enter surface
waters.

The market for a specialty fluid is not large, and the volume of fluid in commerce is low. Workers who blend
this fluid, workers who use it, and organisms in the downstream aquatic environment are the populations that
are exposed to the potential hazards of this material. The potential routes of human exposure are dermal and
respiratory.
Exposure Evaluation
The manufacturing process for this low volatility fluid is a closed process. The fluid has defatting properties,
which helps assure that the recommended gloves are used to keep dermal contact very low. To determine
respiratory exposure during manufacture, the workplace air concentration was monitored by chemical analysis
to estimate short (15 minute) and long-term (8 hour shift) exposure. The process effluent discharge and
downstream sediment also can be monitored for the fluid to determine acute and chronic releases to the aquatic
environment.
To determine its ecological impact, ii is necessary to estimate the amount of the fluid which comes into contact
with the environment. Only a few factories use this fluid for heavy-duty hydraulic systems. The sales volume to
each facility is known. It can be assumed that the annual sales volume is made up of leakage plus change out.
By knowing the recommended change out frequency, the amount of leakage to the environment can be
estimated.
179
Two of the factories discharge their wastewater directly to small rivers. For these sites it is possible to estimate
river water concentrations by dividing the annual leakage by the annual river flow (available from the EPA or
the US Geological Survey). For the other facilities, wastewater is discharged to sewage treatment plants. For
these plants it is important to determine the percentage of removal during the treatment process before
calculating the potential concentration in the receiving water.
As noted above, this organic fluid has a very high octano water partition coefficient. Therefore it might have a
tendency to bioconcentrate in aquatic organisms, leading to high concentrations which could harm organisms
themselves or the humans consuming the organisms. This potential was quantified by monitoring fish in cages
just downstream from the sewage discharge into the river. No significant accumulation was found in a 30-day
experiment.

Worker exposure is controlled by the use of closed systems and protective equipment. The used hydraulic fluid
is collected and burned in incinerators.

From both human and environmental exposure, current risk management was found to be adequate.
180
Case #3:
Existing Material with Limited Distribution - Chemical Intermediate
Product Identify
The chemical is a liquid with high vapor pressure. It is volatile at room temperature. The chemical has a high
octano/water particle coefficient. This means the chemical, when in water, will accumulate in the fat tissues of
organisms, including fish. Its chemical fate and half-life in the environment are unknown.
Information is collected and evaluated regarding the chemical's short-term and long-term effects on aquatic
organisms. Due to its discharge into surface waters, information is gathered and evaluated regarding the
environmental fate of this chemical in surface waters. The environmental fate in soil also is gathered and
evaluated. If there is evidence of accumulation of the chemical in the food chain, additional evaluations are
performed.
Potential hazards to organisms in the aquatic environment also are considered. Discharge occurs to both
Publicly Owned Treatment Works (POTW) and to streams under National Pollution Discharge Elimination
System (NPDES) permits. The percent treatment efficiency of the POTW in removing the chemical and its
half-life in rivers is unknown.

The potential human health hazards of concern are short-term systemic effects, irritation to eyes, skin, and
respiratory tract, and dermal sensitization. Information is collected and evaluated regarding these potential
hazards.

Manufacture of the product is limited to three sites. Ninety percent is shipped in bulk tank trucks and rail cars
and ten percent is shipped in drums. Twenty-five users apply this chemical intermediate to form polymers. A
chemical intermediate is a material whose chemical identity is altered during use by the customer. Normally,
less than 0.1 residual intermediate remains in the polymer, which is then compounded and blended further.

For a chemical intermediate, whose chemical identity is altered during use, exposure is limited to releases from
the manufacturing operations, transportation and processing/ conversion. Exposure characterization involves
examining human contact (oral, dermal, respiratory), environmental release, and possibly environmental fate
resulting from each of these steps. It also is appropriate for the customer or the supplier to determine whether
the new chemical entity needs risk characterization.
The use of this chemical intermediate is large and the volume of the chemical in commerce is high. Populations
that are exposed to the potential hazards of this material are the workers who manufacture this chemical,
workers who transport or use it, and organisms in the aquatic environment. The potential routes of human
exposure are dermal contact and inhalation..

The manufacturer and product users installed local exhaust ventilation systems to control airborne exposures
and workers use gloves and aprons to protect against dermal exposures. A respirator is used when the heated
product is sample. An air monitoring program at various sites shows that manufacture and use exposure are
controlled by the current product risk management practices.
181
• Is risk management appropriate for humans? YES
• Is risk management appropriate for the environment? Not enough data. Suggest biodegradable
testing to obtain a better understanding of fate and possible bioaccumulation in the environment
and specific media, and to assess what the toxicity is for those media.
182
Case #4: Residual Monomer in Polymer
Product Identity
The substance is a plastic part or fiber that contains residua/unreacted monomer (or an T additive) that has the
potential for migration of the polymer material.
Human Health Enacts

The article itself is innocuous. The residual monomer is a known skin irritant, is absorbed through the skin, and
can cause liver damage. The monomer also can vaporize once it reaches the exterior of the polymer. An
occupational exposure limit has been developed for the monomer.
The monomer is released into water, is moderately toxic to fish, and is inherently biodegradable. There are no
environmental limits.
Human Exposure
For some users, the product is in contact with skin for prolonged periods of time and could come in contact with
certain food groups. Thus some estimate or measurement is needed of the rate of migration and the release from
the polymer surface in order to determine the exposure potential. The FDA and the National Science
Foundation have defined procedures to determine potential exposures.
Estimates for dermal contact could consist of wipe testing or extraction in saline or food simulating solvents
over a representative time period, or biological monitoring of test species. Since the monomer also is volatile
once it reaches the surface, air concentrations in a controlled temperature chamber can be measured or
calculated from migration rates and various room sizes and ventilation rates. Worst case, conservative estimates
may need to be made.
Environmental Exposure
The quantity of monomer contained in the polymer is very small and the release rate very low. Thus, adverse
environmental effects are not expected.
Current Risk Management:

MSDS

The results of the estimates or tests for determining how much material can be extracted will be used in the
exposure estimates. This will allow a strategy to be developed for risk management. The data may suggest that
no risk management activities currently are indicated.
183
Definitions
Hazard Evaluation
An understanding of the potential of a product to cause harm to human health or the environment.
Exposure Evaluation
A description of the potential exposures to humans and the environment from the production, distribution, use,
and disposal of a compound.
An understanding of the nature and magnitude :of an adverse health or environmental effect. This description
combines results of exposure and hazard evaluation and describes the uncertainty associated with each step.
Risk Management
Implementation of methods controlling adverse impacts to humans and the environment from the manufacture,
use and disposal of a chemical product. It is a continuing process subject to periodic review.
184
ACGIH American Conference of Government Industrial Hygienists
ATSDR Agency for Toxic Substances and Disease Registry
EPA Environmental Protection Agency
HSE Health, Safety, and Environmental
MSDS Material Safety Data Sheet .
NIOSH National Institutes for Occupational Safety and Health
NPDES National Pollution Discharge Elimination System
OSHA Occupational Safety and Health Administration
PEL Permissible Exposure Levels
POTW Publicly-Owned Treatment Works
R&D Research and Development
TLV Threshold Limit Value
TSCA Toxic Substances Control Act
185
1. 1990 Toxics Release Inventory, US EPA, Office of Pollution Prevention and Toxics, EPA
700-S-92-002, May, 1992.
2. US Environmental Protection Agency, "Guidelines for Exposure Assessment," Federal Register.

57(104):22888 (1992).
3. The Risk Assessment of Environmental Hazards: A Textbook of Case Studies, D.J. Paustenbach, editor,
John Wiley 8 Sons, New York (1989).
4. Risk Analysis in the Chemical Industry, American Chemistry Council, Washington, DC (1985) .(See
especially the chapter, 'Exposure Assessment in Risk Analysis," by Curbs C. Travis,)
5. American Chemistry Council (1990). Programs to Assess Volatile Emissions. American Chemistry
Council, Arlington, VA, May 1990 .
6. EPA (1989). Exposure Factors Handbook. Exposure Assessment Group, Office of Health and
Environmental Assessment, Washington, DC, July, 1989, EPA/600/8-89/043.
7. EPA (1991). Chemical Engineering Branch Manual for the Preparation of Engineering Assessments,
Volume 1: CEB Engineering Manual. Chemical Engineering Branch, Economics and Technology Division,
Office of Toxic Substances, February 1991, PN-3786-64.
8. EPA (1992). Dermal Exposure Assessment: Principles and Applications (Interim Report). Exposure
Assessment Group, Office of Health and Environmental Assessment. Washington, DC, January 1992,
EPAI600/8-91/0118.
9. Gad, S. (1988). Product Safety Evaluation Handbook, Chapter 15. Marvel Dekker, Inc., New York, NY,
ISBN 0-8247-7829-4.
10. Hawkins, N. C., M. A. Jayjodc and J. Lynch (1991). "A Rationale and Framework for Establishing the
Quality of Human Exposure Assessments," American Industrial Hygiene Association Journal, 53(1):34-41,
January 1992.
11. Jayjock, M. A. (1988); "Assessment of Inhalation Exposure Potential from Vapors in the Workplace,"
American Industrial Hygiene Association Journal, 49(8):380-385, August 1988.
12. National Academy of Sciences (1991). Human Exposure Assessment for Airborne Pollutants. National
Academy Press, Washington, DC ISBN 0-309
04284-4.
13. „ Roach, S. (1992). Health Risks From Hazardous Substances at Work: Assessment, Evaluation and
Control. Permagon Press, Inc., Tarrytown, NY
14. Lyman, W. J., W. F Reehl and D. H. Rosenblatt (1982). Handbook of Chemical Property Estimate
Methods. McGraw Hill, Inc., NY.ISBN 0-07-039175-0. ISBN 0-08-040837-0.
15. Versar, Inc. (1984);'Exposure Assessment for Retention of Chemical Liquids on Hands;" Versar, Inc.
Contract No. 68-01 6271, Task No. 56.
186
16. American Chemistry Council, 'Hazard Characterization Resource Guide' (1994).
17. Life Cycle Impact Analysis - Part 1: Issues (draft report), Research Triangle Institute, Research Triangle
Park, NC, 27709-2194, EPA Contract Number 68-W9-0080, November, 1992.
18. A Technical Framework for Life-Cycle Assessments, Society of Environmental J Toxicology and
Chemistry, Washington, DC, January, 1991.
19. A Conceptual Framework for Life-Cycle .Impact Assessment, Society of Environmental Toxicology and
Chemistry, Washington, DC, March 1993.
187
Appendix A: Glossary
Contract Manufacturer (loll manufacturer)

A contract manufacturer is an independent party that produces a product (or intermediate) or supplies a process
for production of a product using materials or methods proprietary to the contracting company. Title to products
remain with the contracting company throughout the process. The definition also encompasses operations such
as repackaging and structural alteration. Disposition of produced materials, surplus materials, by products,
co-products and wastes from the operation are at the direction of the contracting company. Confidentiality
agreements between the contracting parties are the noun. Payment for the service may take many forms, i.e.,
currency, product exchange, or services. The contract manufacturer should not be contused with a supplier who
furnishes a good or service in a much looser arrangement.
Direct Product Receiver

An entity (not an individual) to whom we transfer a product. This definition is included to capture categories of
product receivers (such as brokers) who may not fall into the traditional customer category.
Product
Chemical substances and mixtures, materials and equipment, articles, licensed technology and services related
to product use that are sold, distributed in commerce, or otherwise provided.
Product Lifecycle
The lifecycle of a product embraces those stages through which it retains its product identity. Typically, the
lifecycle would include:
• Product concept and development (even though a commercial product does riot yet exist)
• Manufacture
• Transport and handling in the chain of commerce
• Use
• Disposition (reuse, recycle, disposal)
Product lifecycle should not be confused with Life Cycle Assessment (LCA), which is an evolving science
methodology for assessing the various environmental impacts of a product. LOA attempts to focus almost
exclusively on environmental impacts, with little attention paid to health and safety impacts.
Risk
Risk refers to the probability that harm will occur from exposure.
The qualitative or quantitative process of estimating the potential for adverse effects to occur under various
product use and exposure situations. h is performed by combining the product hazard information with potential
exposures. Because hazard and potential exposure data along with public perception can change with time, the
risk must be reevaluated routinely.
Risk Management
Risk management is action taken to reduce potential risk. This may range from no action to providing health,
safety, and environmental information to reformulation, repackaging, market restrictions, etc., based on the risk
characterization.
188

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Product Stewardship Code

©American Chemistry Council (1992)

3. Copies of the work may not be sold.

David Alcorn Harry Hunter Larry Rampy

Chapter 1: The Product Stewardship Code 9

Chapter 2: How Product Stewardship Relates to Your Job 29

Chapter 3: Responsible Care 91

Chapter 4: Additional Resources 99

Relationship to Responsible Care and Guiding Principles

Each company shall have an ongoing product stewardship process that:

Management Leadership and Commitment

2. ACCOUNTABILITY and PERFORMANCE MEASUREMENT: Establishes goals and responsibilities

4. HEALTH, SAFETY and ENVIRONMENTAL INFORMATION: Establishes and maintains information

6. RISK-MANAGEMENT SYSTEM: Establishes a system to identify, document and implement health,

9. CONTRACT MANUFACTURERS: Selects contract manufacturers who employ appropriate practices

12. CUSTOMERS AND OTHER DIRECT PRODUCT RECEIVERS: Provides health,

Relationship To Other Codes of Management Practices

How To Use This Guide

Purpose and Scope

Relationship to Responsible Care and Guiding Principles

(7) Will 1 be required to carry out a customer audit?

(8) What is meant by the term "work with?"

The Importance of Self-Evaluation

How to Complete the Form

PRODUCT STEWARDSHIP CODE OF MANAGEMENT PRACTICES

MEMBER SELF-EVALUATION FORM

Responsible Care Coordinator

PRODUCT STEWARDSHIP CODE OF MANAGEMENT PRACTICES

Management Practices Categories

1. LEADERSHIP: Demonstrate senior management leadership

2. ACCOUNTABILITY and PERFORMANCE

3. RESOURCES: Commit resources necessary to implement and

4. HEALTH, SAFETY, and

6. RISK-MANAGEMENT SYSTEM: Establishes a system to

7. PRODUCT and PROCESS DESIGN and IMPROVEMENT:

8. EMPLOYEE EDUCATION and PRODUCT USE

10. SUPPLIERS: Requires suppliers to provide appropriate

11. DISTRIBUTORS: Provides health, safety and environmental

12. CUSTOMERS AND OTHER DIRECT PRODUCT

ct Conceptualization Product Design Process Design Distribution, Use,

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Consideration: An employee might be recognized for exceptional

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As you evaluate resource needs, it is important to encourage

A decentralized business organization may be a barrier for maintaining centralized administration of an

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Share HSE expertise with distribution and customer support functions.

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Develop a written protocol to evaluate products.

Consideration: Helpful methods for proper documentation include:

Consider conducting periodic multi-disciplinary product safety reviews.

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Document technical issues early in the development of a new product or process.

Develop a written protocol to evaluate products.

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Regard customer assistance and education as a risk management technique.

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Possible Activities to Consider

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Discuss risk management techniques with HSE professionals in other organizations.

Consider conducting periodic multidisciplinary product safety reviews.

Possible Activities to Consider: