Our Product Stewardship Management System, which includes product stewardship implementation tools, is the bedrock of our process. To ensure sustainable business practices, the system’s nine elements cover the full scope of the product life cycle—from product development through hazard communication, chemical regulatory compliance, transport of dangerous goods and customer response to end-of-life requirements.
We conduct an annual management review in each business to drive continuous improvement and ensure that any critical gaps are closed by a robust action plan. We supplement this process with compliance assurance audits that focus on key business risk.
We operate a centralized, global system to manage hazard communication documents. This starts with one global process for approving raw materials used to manufacture product, including all required hazard assessment data. Product formulas are automatically transferred to this system, which then provides an on-demand safety data sheet and hazard warning label for all languages and regulatory jurisdictions where we do business.
We also leverage the system’s data to support many other compliance requirements. These include chemical inventory and restricted and prohibited substances, as well as customer requests to support their sustainability programs. Examples include Leadership in Energy and Environmental Design (LEED), Green Building Initiative, environmental and health product declarations and life cycle assessments.
In parallel, we maintain a simple-to-use matrix that details regulatory requirements for all countries where we do business. This is supported by detailed procedures for compliance.
Continuous monitoring of regulatory changes and a project management process to implement changes to our compliance procedures ensure that we have no business interruptions.
Chemical Inventory Compliance
To ensure compliance, we maintain a robust central management system for notifications to the regulatory authorities, including those that oversee Registration, Evaluation, Authorisation and Restriction of Chemicals in Europe (EU-REACH), the Act on the Registration and Evaluation of Chemicals in Korea (Korea REACH), the Toxic Substances Control Act (TSCA) in the U.S. and many more.
We will complete more than 200 registrations ahead of the EU-REACH 2018 deadline and 15 priority existing chemical (PEC) registrations required under K-REACH.
Substance of Concern Scorecard
PPG's Substance of Concern Scorecard is a visual “picture” of the hazards, regulatory status and stakeholder concerns for substances that are critical to our business. The purpose of the scorecard is to provide an early warning about possible deselection of a substance from the marketplace.
The scorecard provides a forecast and timeline for possible deselection and is used by our technical community when selecting raw material and making decisions regarding new technology platforms.
We tracked 140 substances with scorecards in 2017, with two new substances added during the year.
Restricted Substances List
Our corporate-wide Restricted Substances List (RSL), which applies to all PPG products, establishes our current minimum acceptable requirements for restricting certain hazardous substances in our products. This includes areas of the world that lack chemical regulations.
We have a sustainable process to keep the list evergreen, and we conduct, at a minimum, a biannual review to ensure there are no restricted substances in our global product portfolio.
The RSL is based on the principle of controlling the health and environmental risks of commercial products by:
- Identifying specific chemicals with potential risks;
- Restricting the use of certain chemicals for specific uses or, in some cases, all uses; and
- Setting concentration thresholds based on the hazard of the chemical and intended product uses.
In 2017, more than 300 substances were restricted in our products for all uses and more than 900 substances were restricted for specific uses, such as consumer and aquatic.
We are very active in industry organizations and public forums. We also engage with customers, non-governmental organizations, government agencies and other stakeholders to ensure that we understand their requirements and they, in return, understand our position and requirements for efficient and sustainable business operations.
Our current focus is on three areas where there is opportunity to work with regulators for better regulation:
- TSCA and the Frank R. Lautenberg Chemical Safety for the 21st Century Act (LCSA) in the U.S., including new chemical notification processes (pre-manufacture notice and low volume exemption) that are fit for purpose;
- Titanium dioxide hazard classification in Europe to avoid inappropriate classification that can harm the reputation of the classification, labeling and packaging (CLP) system; and
- China volatile organic compound (VOC) regulations to achieve environmental goals with technically feasible solutions and a joined-up process for regulations at the federal and local levels.
Product Stewardship Leadership Development
We have built our product stewardship resources over many years, and we continue to evolve to meet changing business expectations.
Product stewardship experts are embedded in each business unit, where they have an intimate knowledge of the product portfolio and business requirements. In addition, corporate centers of excellence ensure that we maintain compliance and strive for improved efficiencies of scale.
Accessible and relevant training materials are deployed for all company stakeholders (technical, marketing, leadership, etc.), with on-demand or assigned access to training modules on all aspects of product stewardship.
To ensure regulatory compliance requirements are easy for our technical community to understand, we have deployed the Chemist’s Toolbox to provide easy access to the right tools.
The toolbox contains links to relevant product stewardship tools. It also offers a roadmap of the resources designed for chemists and formulators to support product stewardship needs at every level of product development—from new raw material registrations to changes in existing products—to reduce the risk of delayed product launch. In addition, the toolbox helps our chemists determine if their formulation is compliant for shipment to a particular country, find whether a substance in the formulation will likely be deselected from the marketplace and identify those substances that are causing hazard statements on a safety data sheet.