We are the stewards of our products throughout their life cycle
We take responsibility for minimizing the human health and environmental impacts of our products throughout their entire life cycle. The focus areas below outline our multi-faceted approach to product stewardship.
In 2021, we continued to improve our product stewardship processes and systems. A few examples of our activities include:
- Enhanced our Product Stewardship Management System and review and audit processes based on extensive benchmarking;
- Introduced a new system, the Emerging Issues (EI) tool, to identify, track and monitor emerging issues from various sources around the world including proposed regulations, non-governmental organizations (NGOs), societal trends, and customers;
- Expanded our use of Substance of Interest (SOI) Scorecards, which include a visual for forecasting the hazards, regulatory status and stakeholder concerns for substances that are critical to our businesses; and
- Continued to increase the number of declarations of substance composition and lifecycle assessment information to support customers achieving certifications and declarations of their products required by green building schemes.
Read on to learn more about product stewardship at PPG.
Our Product Stewardship Management System, which includes product stewardship implementation tools, is the bedrock of our process. To ensure sustainable business practices, the management system’s nine elements cover the full scope of the product life cycle, including 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 risks. All businesses are audited on a three to five year cycle. In 2021, we were able to complete product stewardship audits on five businesses in three regions.
We continued to conduct extensive benchmarking with industry peers in 2021, and we incorporated significant learnings into our Product Stewardship Management System and review/audit processes.
Our centralized Global Product Stewardship (GPS) system manages the data required to author hazard communication documents.
In accordance with Globally Harmonized System for Classification and Labeling (GHS) classification principles, an internationally agreed-upon standard managed by the United Nations, we use a global hazard evaluation (GHE) process to assess and review 100% of our raw materials prior to them being used to safely manufacture our products and before we develop safety data sheets (SDS). Our GHE process reviews a raw material's impact on human health, physical and chemical properties, environmental impact and compliance with global regulations and PPG policies. Each PPG product formula is automatically transferred to our GPS system, which then provides an on-demand GHS-compliant SDS and a hazard warning label. These labels are available in many languages and meet the regulations of the more than 70 countries where we do business.
The GHS classifies substances for health, physical and environmental hazards. In 2021, 80% of PPG products sold globally in 2021 were scored using a new methodology to determine the degree to which they were sustainably advantaged. The methodology includes an assessment for UN GHS Category 1 and/ or 2 hazard warnings on products and of the products scored, 42% were not classified with hazards under GHS Category 1 or 2. We consciously choose lower hazards, especially in architectural coatings products due to their heavy use in consumer, commercial and residential projects.
Our automated email distribution for SDS is 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. This includes the ability to distribute an SDS for non- PPG manufactured products, automated distribution for the latest SDS after a major version change, and distribution of an SDS to multiple email addresses for customers.
We leverage the GPS data to support many other compliance and customer requirements. These include chemical inventory, PPG and customer restricted substances lists, and customer requests to support their sustainability programs. Using the global data allows us to quickly respond to customers and identify any potentially problematic or concerning substances.
The system is used frequently by many functions throughout PPG, including product stewardship, product development, supply chain, manufacturing and marketing.
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, Authorization and Restriction of Chemicals in Europe (EU-REACH).
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, enabling us to get our products in-market faster.
Regulatory and Emerging Issues
In parallel to our GPS system, 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. We recently launched a new tool to facilitate the early identification of issues with regulatory and financial impact to our businesses and provide a way to prioritize those that are most impactful. For high-impact issues, we have implemented strategic management plans to manage the impact to PPG related to substance deselection, regulatory changes and end-use restrictions. Combined with improved workflow management and close linkage with the research and development community, this tool will further position us as a proactive business partner to our customers.
Leveraging technology to improve awareness and compliance
In 2021, we launched our Emerging Issues (EI) tool to stay up to date on compliance and other regulatory issues. Because businesses are evolving in a fast-changing and complex environment, we recognized the need to be faster, smarter and more agile. EI helps us anticipate regulatory changes to capitalize on business opportunities while driving early compliance with regulations.
When we receive inquiries from customers, non-governmental organizations (NGOs) or agencies, or when social interest is detected, PPG employees can enter an issue in our EI tool for review. As part of the planning process, members of the EHS Product Stewardship team analyze the issue to determine its risk and potential impact on PPG. From there, the team develops a monitoring or action plan that may include advocacy with trade associations or governmental agencies. Plans can also include business, technical or manufacturing activities to help PPG maintain compliance or explore new business concepts.
The PPG Global Community of Expertise (CoE) for food contact regulatory compliance aligns with our approach to standardize processes and procedures in support of each of our businesses.
The Food Contact CoE leverages existing practices and tools for a fine-tuned approach for our food contact coatings. It is tied into early research and development (R&D) to ensure safety by design, and it will keep sustainability aspects in mind. Additionally, the Food Contact CoE monitors new regulations related to the Green Deal/CSS to ascertain any impacts to the business.
We will continually update our approach with new and relevant information when regulations and public concerns arise. We also provide input for internal stakeholders such as the PPG Substance of Interest (SOI) and Restricted Substance List (RSL) programs.
Toxicology is an integral component of sustainable product development. We endorse the principles of green toxicology, which describe the application of predictive toxicology in the design, manufacture, use and disposal of new materials and chemicals.
Green toxicology complements green chemistry, which has the objective of contributing to the development of products that are safer for humans and the environment by using predictive toxicology testing.
Green toxicology broadly supports green chemistry by providing tools to assess hazards so that more sustainable, less-toxic products can be developed. Green toxicology directly applies to principles 3, 4 and 10 of green chemistry – less hazardous chemical synthesis, designing safer chemicals and design for degradation.
To achieve these goals, chemists must have tools and processes to evaluate hazards. We use various validated methods to assess hazards that can be applied early in product development. An example is new approach methods (NAMs), which include computer-based modeling and cell-line-based testing to assess hazards.
We support global efforts to reduce animal testing, as this is a pillar of ethics-based sustainability. Our animal welfare policy is available on ppg.com.
We use three toxicology processes to evaluate and monitor substances used in our products – Early R&D (ERD) Hazard Screen, Substance of Interest (SOI) Scorecard and PPG RSL.
Driven by global, cross-functional committees, these three processes are linked to monitor and manage health and environmental risks of raw materials throughout the development and commercialization of our products.
ERD Hazard Screen
During a new product's R&D phase, we assess the hazard of raw materials and potential byproducts using a hazard screen process. In 2021, we completed more than 66 of these early screens to guide our R&D chemists during product development. Following a product's commercialization, we may develop an SOI Scorecard incorporating this assessment and any new hazard information to further guide our businesses.
Our SOI Scorecard includes a visual for forecasting the hazards, regulatory status and stakeholder concerns for substances that are critical to our businesses. Its purpose is to guide responsible product stewardship and build our confidence to further use those substances with low risk for a sustainable product portfolio.
During 2020, we semi-automated the SOI Scorecard with regulatory information to provide more frequent quarterly updates to our stakeholders. By the end of 2021, we had 163 scorecards tracking 228 substances, with some scorecards monitoring numerous substances within the same family. We created an additional 15 scorecards for substances or substance families in 2021.
We continually update our SOI Scorecards with new regulatory, scientific and market developments. When updated, we review substances for placement on the PPG RSL. Linking the two processes enables our technical community to begin the process of product reformulation prior to the inclusion of a substance on the PPG RSL.
The PPG restricted substances list (RSL) establishes our current requirements for and restrictions on the use of certain hazardous substances in our products. PPG's RSL applies to all PPG products globally, including those sold in areas of the world that do not have chemical regulation programs.
PPG's RSL Program is based on an evergreen process that includes a review through which we evaluate substances for addition to the list and new information about substances already on the list. We also conduct periodic assessments (at least twice per year) of our RSL Program to ensure that it is being implemented in all of our businesses globally.
PPG's RSL Program is based on the principle of addressing the health and environmental risks of substances that we use, produce and sell. We identify substances for inclusion on the PPG RSL based on international conventions, country-specific requirements and substance-specific information. For example, the PPG RSL includes all substances covered by the Stockholm Convention on Persistent Organic Pollutants and industrial substances on the Rotterdam Convention Prior Informed Consent (PIC) list.
When substances are added to PPG's RSL, a target date for restriction or prohibition is established and progress to meet the target date is tracked biannually. Since PPG's RSL is applied to all PPG products globally even in areas of the world where there are no chemical regulation programs, it goes beyond regulatory compliance.
In 2021, we had 1,132 substances that were restricted for all uses in our products and more than 388 substances that were restricted for specific uses, such as in consumer products or medical devices.
The elimination of lead as an intentionally added ingredient in any PPG products is an example of PPG's RSL Program in action. For many years, lead has not been intentionally added to any of PPG's consumer products and in 2019, we achieved our goal of eliminating lead from all non-consumer products as well. PPG's non-consumer products contained lead as an intentionally added ingredient solely to meet the unique specifications of PPG's customers. Over the course of several years, PPG worked with those customers to develop alternative formulations that do not contain lead but achieve the same performance characteristics. We are now focusing on ensuring that lead is not used as an intentionally added ingredient in new products developed, as well as products that are added to PPG's portfolio through acquisitions.
Life Cycle Assessment
A life cycle assessment (LCA) is a scientifically recognized method for assessing the environmental and human health impact of products – from the extraction of raw materials to the disposal of a product at the end of life. An LCA covers a wide range of environmental and human health impacts, including most commonly reported impact categories such as climate change, measured by kg CO2-eq per functional unit.
PPG's Product Sustainability (PS) CoE serves all businesses globally, enabling each to benefit from a scientifically sound calculation of the environmental and human health impact of its products. The CoE is focused on three areas to increase LCA/Product Sustainability assessment capabilities.
At the corporate level, the PS CoE engages with multiple software vendors and explores possibilities to develop tools, such as an automated LCA tool that can be integrated with everyday business processes and report product LCA information at the individual product level. As the chemical industry faces increasing demand for product specific LCA information along a company's value chain, PPG strives to become an early adopter to apply stateof- the-art system solutions for a more sustainable product.
Second, the PS CoE supports PPG's R&D community to understand a product's environmental and human health impacts during the product development stage.
Our simple recipe screening tool makes it easy for users to assess a formulation’s environmental and human health impacts. Product developers can enter up to four formulations into the application and compare the life cycle impact across important environmental and human health indicators. Developers can integrate life cycle analysis into their product design and be proactive to choose a product formulation with the lowest life cycle impact.
Besides corporate level and R&D efforts, the PS CoE also supports our Customer Sustainability team to quantify a product's life cycle benefits that are realized in our customer's operations or in the use of products by our customers. This insight enables us to develop truly customer-focused sustainably advantaged products and avoid shifting environmental burdens to other parts of the value chain. One of the PS CoE's core capabilities related to customer support are generating Environmental Product Declarations (EPD) and Health Product Declarations (HPD). Our EPDs and HPDs are used to support our customers' sustainability efforts around the globe.
We are very active in industry organizations and public forums. We also engage with customers, nongovernmental 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 advocacy efforts are global and encompass regulatory matters related to environment, health, safety and product stewardship.
We track and prioritize opportunities for advocacy based on risk and financial impact, and we rely heavily on our businesses to engage in our advocacy efforts.
To ensure alignment among our businesses and to provide direction on engagement, we have established the PPG Advocacy Steering Committee. The committee meets routinely to monitor the progress of current advocacy efforts and review new initiatives. Though there are numerous chemical specific advocacy efforts underway, the following principles are applied to keep our messaging consistent:
- Sound science;
- Risk-based approach; and
- Practical solutions.
More specifically, we continue to engage with the U.S. Environmental Protection Agency (EPA) on matters related to TSCA implementation under the Lautenberg amendments, such as workplace chemicals management and risk assessment. In Europe, we are closely following the Chemical Strategy for Sustainability under the EU Green Deal to ensure we provide comments to advocate for risk-based, sustainable solutions supported by sound science. In other parts of the world, such as Latin America, we are advocating for a risk-based chemicals management strategy as countries prepare chemical inventories.
Product Stewardship Leadership Development
We have built our product stewardship resources over many years, and we continue to evolve to meet changing business expectations.
Our Product Stewardship organization is a centralized function to support our businesses and customers more efficiently and effectively. There are three main groups:
- Community of Expertise (CoE);
- Regional operations teams; and
- Product Stewardship business partners.
Our CoE experts provide regulatory monitoring and develop company requirements and tools to support the regional operations teams. These teams respond directly to internal and external customer inquiries, striving for efficiencies of scale. The product stewardship business partners focus on driving growth through product stewardship. They work directly with our businesses and have an intimate knowledge of business product portfolios and requirements.
As part of this reorganization, we launched a central workflow tool called Product Stewardship (PS) Pulse. All product stewardship requests are now initiated within the tool by PPG users globally.
PS Pulse provides a collaborative site for users to flow requests between all members of the product stewardship teams and escalate requests based on level of expertise required for response. Users are also provided with a central location for knowledge articles for self-help and education on various topics.
We deploy accessible and relevant training materials for all company stakeholders (technical, marketing, leadership), with on-demand or assigned access to training modules on all aspects of product stewardship.
Our Product Stewardship Training Matrix identifies more than 40 training elements, and the majority are available on-demand from our Evolve learning platform. In 2021, we recorded the completion of more than 5,000 training courses on product stewardship topics through Evolve.
To ensure regulatory compliance requirements are easy for our technical community to understand, we developed and continue to support an EHS Toolbox. This centralized compilation of links to information contained on our intranet makes it easy for users to access the right product stewardship tools.
The EHS 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 introductions to formulation 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 require hazard statements on a safety data sheet.
Coatings are used extensively in the building and construction market for protective and decorative purposes on the building itself and as part of components or machinery installed in the building.
We leverage data from our systems to produce declarations that support the requirements of green building schemes. These include the U.S. Green Building Council's Leadership in Energy and Environmental Design (LEED®), Europe's Building Research Establishment Environmental Assessment Methodology (BREEAM®) and the WELL BUILDING STANDARD®.
Our LCA capabilities allow the in-house production of environmental product declarations (EPDs), which declare the environmental impact of the product over its entire life cycle.
To support LEED Material Ingredients reporting, we generate Health Product Declarations (HPDs), which outline the substances present and indicate the results of screening these substances against the HPD Priority Hazard Lists and the GREENSCREEN FOR SAFER CHEMICALS®. We also support substance screening and declarations for Cradle-to- Cradle certification of products.
We provide regulatory VOC content data and support in obtaining external emission testing certifications, both of which are part of the green construction programs requirements for identifying products which have a low impact on indoor air quality.
As well as supporting the requirements of green construction schemes, these assessments and certifications enable users to make informed choices on the products they choose in relation to the chemicals used, the impact on indoor air quality and the broader environmental impacts.
Where PPG coatings are incorporated into products destined for the construction sector, we provide declarations of substance composition and life cycle assessment information of the coatings to support customers achieving certifications and declarations of their products required by green building schemes.
PPG SAFEASSURE™ for Sustainable Packaging
Part of our Packaging Coatings new product development process, the PPG SafeAssure program is a stringent protocol for screening both starting chemicals and those migrating into food or beverages to assure the longevity and sustainability of new packaging technologies.
The program goes beyond the legal compliance requirements for packaging coatings to support the market in demonstrating food safety. It builds a dossier of key information to allow the onward supply chain to conduct appropriate risk assessments and build confidence in food or beverage products released to the market.
State-of-the-art methodologies around analytical science and risk assessment and our computersimulated toxicological assessments support our innovative coating portfolio. We invest substantial time, cost and effort in this area to support our packaging customers.
Last year, we found new opportunities to reuse residual product that would otherwise be shipped for disposal and updated packaging from virgin to post-consumer recycled (PCR) plastic, ultimately contributing to the circular economy. Our architectural coatings product packaging, excluding the handle and lid, have up to 100% recycled content in the U.S. and up to 80% in Europe. We are currently testing packaging that uses 100% recycled content for the lid.
We also expanded our partnerships with organizations focused on circularity and waste reduction, including the PAINTCARE™ program in the U.S., ProductCare in Canada, the ECO-PEINTURE™ non-profit in Quebec, and PaintBack in Australia, all of which allow consumers to recycle leftover or unwanted paint. We are exploring additional paint recycling opportunities globally where available. Learn more in the Waste section.