We take responsibility for minimizing the human health and environmental impacts of our products throughout their entire life cycle.
Our approach to product stewardship is multi-faceted.
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.
During 2018, we completed these audits using updated protocols. This marks the third iteration of our product stewardship auditing process, which began in 2012. All business units are now being audited on a three- to five-year cycle. In addition, we have carried out extensive benchmarking with industry peers, and we incorporated significant learnings into our Product Stewardship Management System and review/audit processes.
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 (SDS) and hazard warning label for all languages and regulatory jurisdictions where we do business.
Process enhancements in 2018 included automated email distribution for safety data sheets based on customer orders placed for our products sold around the world. Known as STAN (SDS Transmission and Notification), the system supports region-specific SDS distribution while offering increased functionality.
We leverage the data from our centralized system to support many other compliance requirements. These include chemical inventory, PPG and customer restricted substances lists, and customer requests to support their sustainability programs. Such programs that use data from our global system include the U.S. Green Building Council Leadership in Energy and Environmental Design (LEED®) and Europe’s Building Research Establishment Environmental Assessment Methodology (BREEAM®).
The system data also support life cycle assessments (LCA), environmental product declarations and material transparency documents. LCA results provide a better understanding of the environmental impact of our products in emerging air quality markets like China and customer manufacturing processes in the automotive and industrial coating markets. LCAs also play a role in quantifying the environmental impact of our own complex distribution schemes.
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, including customer use requirements. Examples include food contact, restriction of hazardous substances (RoHS), volatile organic compound (VOC) emissions and items intended for use by children.
Continuous monitoring of emerging issues and regulatory changes and a project management process to implement changes to our compliance procedures ensure that we have no business interruptions. New tools are under development to facilitate the early identification of issues with regulatory impact. Combined with improved workflow management and close linkage with the research and development community, the tools will further position us as a proactive business partner for our customers.
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.
During 2018, we completed more than 200 EU REACH registrations ahead of the May deadline, as well as 21 Korea REACH priority existing chemicals (PEC) registrations ahead of the June deadline. Despite issues with the process the U.S. Environmental Protection Agency is now using to evaluate new substances, we successfully completed 11 low volume exemptions (LVEs) and three pre-manufacture notices (PMNs) required under TSCA/ Frank R. Lautenberg Chemical Safety for the 21st Century Act (LCSA). We had an additional six PMNs still under review at the end of 2018.
New chemical notifications (mostly new polymers) in Australia, China, the Philippines, Taiwan and Vietnam allow us to leverage our leading-edge polymer technology in the development of sustainably advantaged products for all business units.
Much of our technical leadership is based on the development of polymers. Our regulatory team works closely with our polymer chemists, advising them on the “design of polymers for regulatory compliance” and providing support at all stages of the development process.
This early involvement allows us to complete the registration process in any of the nine country inventories that require polymer notification well ahead of product launch, getting our products to market faster.
“We commend PPG for phasing out the sale of methylene chloride and NMP paint strippers at its nearly 1,000 stores across the Americas,” said Mike Schade, Mind the Store campaign director, Safer Chemicals, Healthy Families. “This sustainability commitment is helping to transform the marketplace away from these hazardous products and promote safer solutions. This will help to protect both consumers and professional contractors. We hope PPG will also extend these efforts to the sale of commercial and industrial methylene chloride and NMP paint removal products in the Americas and globally in the near future.”
Substance of Concern Scorecard
Our Substance of Concern (SOC) Scorecard is a visual “picture” of the hazards, regulatory status and stakeholder concerns for substances that are critical to our businesses. Its purpose 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 materials and making decisions regarding new technology platforms. It also aids in the development of sustainably advantaged products.
During 2018, we developed 28 scorecards. At year’s end, we had 99 scorecards available for use in product development, with some scorecards monitoring numerous substances within the same product family.
We continually update scorecards with new regulatory and non-regulatory developments.
Restricted Substances List
Our Restricted Substances List (RSL), which applies to all PPG products globally, 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 2018, we had more than 470 substances that we restricted for all uses in our products and more than 800 substances that we restricted for specific uses, such as consumer and aquatic.
A good example of the progress that we are making is the elimination of products that contain lead. At the end of 2018, we had eliminated 91 percent of the non-consumer products that previously contained lead (lead was removed from consumer paint many years ago). We are on track to eliminate production of the remaining lead-containing products by the end of 2019.
In 2018, we linked our early toxicological assessment, SOC Scorecards and RSL to monitor and manage health and environmental risks of raw materials throughout the development and commercialization of our products.
During a new product’s research and development phase, we assess raw materials for their safety using a toxicology screening assessment. Following the product’s commercialization, we may develop an SOC Scorecard using information from the assessment and any new hazard information.
When SOC scorecards are updated, we also review substances for placement on the RSL. This requires our businesses to reformulate or obsolete products containing the restricted substance above the stated threshold.
Linking these processes enables our technical community to be aware of SOCs and begin the process of product reformulation or obsolescence prior to regulatory action.
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 continues in three areas where there is opportunity to work with government agencies for better regulation:
- TSCA and LCSA in the U.S., including new chemical notification processes (PMN and LVE) that are fit for purpose. We have continued discussions with the U.S. Environmental Protection Agency to help it further understand the issues and agree on a path forward for mutual benefit.
- Titanium dioxide hazard classification in Europe to avoid classification that can harm the reputation of the classification, labeling and packaging (CLP) system. We participated in successful multi-stakeholder interactions to modify the original proposal, and we continued to advocate for an alternative approach to manage poorly soluble low-toxicity powders.
- China’s VOC regulations to achieve environmental goals with technically feasible solutions and a joined-up process for regulations at the federal and local levels. We provided input on various elements of proposed legislation and conducted productive engagement with authorities.
We also interacted with authorities in the Philippines, successfully providing an understanding of the significant hazard difference between high-hazard crystalline silica and non-hazardous amorphous silica. This protected our synthetic amorphous silica products from classification. We also continued to advocate in the Philippines and globally for a consistent interpretation of the understanding of polymer of low concern.
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 and region, 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. We added 30 training modules in 2018 and developed a new onboarding program.
Our Product Stewardship Training Matrix identifies 35 training elements, and 23 of these are available via online training, with many in multiple languages. During 2018, we recorded the completion of 26,000 training units.
To ensure regulatory compliance requirements are easy for our technical community to understand, we developed and continue to support the Chemist’s Toolbox to provide easy access to the right product stewardship tools.
Through links, the toolbox 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.