FORWARD: HOW TO USE THIS GUIDE
MANAGEMENT AND ADMINISTRATION
FORMULATING & PROCESSING
INFORMATION
CUSTOMER SERVICE
PERFORMANCE MEASUREMENT
APPENDICESTHERMOSET TECHNOLOGY DIVISION
A Business Unit of SPIPRODUCT STEWARDSHIP GUIDE
FORWARD: HOW TO USE THIS GUIDE
The Epoxy Resin Formulators of SPI strongly support the efforts of chemical manufacturers and distributors to make health, safety and environmental protection an integral part of the product life-cycle. This guide was created to help members of our industry develop and implement policies and practices that ensure protection throughout the product life-cycle.
The use of this guide is voluntary. Adoption of the guidelines is not a condition of membership in ERF. However, ERF strongly advocates the application of these policies and practices. Implementation of Product Stewardship improves the industry's health, safety, and environmental performance. It also promotes an improved image of the formulating industry to customers, communities, and regulators.
In order to adopt the principles of Product Stewardship, the Formulator must assess their current programs and policies against those called for in the guide. Those programs found lacking should be altered to include the practices in this guide. Required actions, policies or programs are designated by word "should" within a sentence. The term "should" indicates the Formulator may use any method or approach to achieve the intended outcome. The term "shall" indicates that the action is required by existing regulation.
As part of the adoption of process, the Formulator's suppliers, distributors, and customers should be notified that the Formulator has adopted ERF Product Stewardship and what they may expect as a result.
In an effort to continually improve their Product Stewardship Program, the Formulator will collect data reflecting program performance. The data will be used by the Formulator to direct efforts to improve the effectiveness of the program to protect health, safety and the environment.
The Formulator's Product Stewardship Program should include:
- A definition of the scope of the program
- A statement of the commitment to provide resources and management support
- Defined roles played by key personnel/departments
- A plan, with resources and timing, to ensure implementation
- A plan to ensure periodic program review
The Formulator should systematically gather, interpret and act on information regarding potential health, safety and environmental risks that may be posed by new or existing products. Potential sources of such information would include MSDS's from raw material suppliers, publicly available health and safety data bases, government regulations (e.g. OSHA regulations, TSCA 5(e) Consent Orders, etc.), and internal company data bases (e.g. TSCA 8(c) files, etc.).
Responsibility for review and assessment of this information should be in the hands of employees who are equipped by training and experience to appreciate its significance, arrive at sound risk assessments, and develop effective risk management strategies. Examples of effective risk management strategies would include label and MSDS warnings, personal protective equipment recommendations, and disposal instructions. Risk management strategies may also include reformulation of the product to use less toxic components, or restricting distribution to markets where industrial hygiene practices are known to be adequate.
The Formulator should have management systems in place to assure that safety, health and environmental considerations are reviewed as new products move through the development process. These considerations should be given equal weight to such considerations as product performance, cost, market acceptability, etc. in new product release decisions.
New products should not be launched until it is determined that it is possible to make, use, handle, distribute and dispose of the product safely in a responsible manner. The Formulator should also periodically review existing products and processes to minimize their health, safety, and environmental impacts.
The Formulator should collect, develop, and review chemical, physical, toxicological, and industrial hygiene data to provide a basis for proper engineering control and personal protective equipment recommendations applicable to typical manufacturing or application scenarios.
The Formulator should identify potential product exposures and document them in an appropriate system. The system should track information about actual exposures reported by employees and customers. This information can be used to help assess the suitability of work practices and personal protective equipment recommendations, as well as the need for new or reformulated products with improved environmental, health, and safety characteristics.
The Formulator shall perform a risk assessment of all raw materials, intermediates, products, and wastes, purchased or generated, from creation to disposal. The risk assessment should detail necessary precautions to protect the environment and health or safety of individuals during the product's life cycle. Formulators should request their suppliers provide adequate information to perform these risk assessments, typically through MSDS's, Labels, Product Bulletins, and Handling Guides. The Formulator should also employ additional sources of information where necessary (see Appendix for examples). If the Formulator cannot adequately assess risk because of insufficient information, it should consider characterizing hazards through product testing.
The hazards determined during formal risk assessment shall be communicated to employees and customers. Typically, labeling, MSDS, safe handling brochures and product bulletins should be employed to communicate hazards. For each product an up-to-date material safety data sheet and label shall be prepared. A system should be in place to assure these are supplied to customers and employees handling and using formulated products. The preparer should be fully aware of all ingredients used in the formulation. In addition, the Formulator should be aware of and use label and MSDS preparation guidance provided by appropriate standards such as ANSI Z400.1 (MSDS) and ANSI Z129.1 (Labeling). The Formulator should also maintain awareness and practical knowledge of applicable US (and global where appropriate) regulations concerning the distribution, use, and disposal of its products.
The Formulator shall communicate the risks associated with material handling to internal employees through orientation and on-going training. The effectiveness of training should be evaluated through testing of employee competency. Feedback should be gathered through methods such as employee suggestions, audits, and during training sessions. The feedback should be used to improve communication and training of risks.
Formulators should provide safe handling, use, and disposal information to their customers. Formulators should determine the product safe-handling, use and disposal information to be communicated to customers beyond what is normally included in MSDS's and labels. Formulators should also determine the form additional information would take, such as newsletters, bulletins, etc., and how information would be conveyed to the customer. Delivery could occur through direct personal visits, telephone contacts, various mailings, or presentations at trade association meetings. Formulators should implement systems to obtain feedback from customers to determine if the information they receive is sufficient to assure safe product handling, use, and disposal.
Formulators should tell their customers that they are committed to ERF Product Stewardship and what the customer can expect as a result of that promise. The Formulator should identify and train customer contact personnel to discuss product stewardship issues with their customers on an established frequency. These individuals should be knowledgeable in safe handling, use, and disposal methods; proactively seek information from the customer about his product-use experiences; and be able to respond to customer concerns. Formulators should utilize existing relationships with direct customers and trade associations to enhance their ability to foster safe product use.
There should be a defined communication system in place to assure information received from the customer is passed on to others within the Formulators' organization with the training and experience to evaluate its broader significance. After immediate review of this information for such considerations as TSCA 8(e) reportability or 8(c ) recordability, OSHA, and product safety (CPSC) implications, the information should be compiled and retained in such a form as to render it accessible to help guide ongoing company product stewardship efforts, such as new product development, customer outreach, business plans for existing products, etc.
The Formulator should establish procedures to collect performance measures to assess the suitability and effectiveness of their product stewardship. Measurements may include, but are not limited to:
- Internal audit reports
- Internal walk-through results
- Customer surveys via mail, phone, or site visits
The Formulator should use the measurements to identify areas for improvement of their product stewardship program. Responsible persons should act to improve suitability and effectiveness of the program based evaluation of performance measurements.
I. REGULATORY DRIVERS
The Formulator is directed to review requirements of the following health, safety, and environmental regulations. Requirements of these regulations as well as those from State and other authorities must be integrated into the product stewardship program as applicable.
29 CFR 1910.132-138 - Personal Protective Equipment - Concerns hazard assessments, selection, and training
B. 29 CFR 1910.1200 - OSHA Hazard Communication Program - Concerns hazard assessments, labels, and MSDS's.
C. 29 CFR 1910.1450 - OSHA Laboratory Standard - Concerns internal communication of hazards within the laboratory.
D. 40 CFR 261 - Hazardous/Solid Waste Identification
E. 40 CFR 700-717 - Toxic Substances Reporting & Recording
D. 49 CFR 100 through 180 - Hazardous Materials Regulations
E. 16 CFR 1000 through 1799 - Consumer Product Safety
F. WHMIS - Canadian Haz. Products Act; Haz. Materials Information Review Act
G. Canadian Transportation of Dangerous GoodsII. SOURCES OF HEALTH & SAFETY INFORMATION
A. Patty's Industrial Hygiene - latest edition
B. ACGIH TLV / BEI Booklet
C. ACGIH Documentation of TLV's and BEI's
D. Registry of Toxic Effects - NIOSH
E. Internet:
National Inst. of Health: http://www.ncbi.nlm.nih.gov/htbin-post/Entrez/query?db=m
NTP: http://ntp-server.niehs.nih.gov/cgi/iH_Indexes/Res_Stat/iH_Res_Stat_Frames.html
SAREC: http://www.sarec.ca/english/l-frames.htm
MSDS's on-line: http://www.ilpi.com/msds/index.html
OSHA: http://www.osha.gov
O. H. Interactive: http://www.penton.com/oh/member/newsline/newsline.htmlIII. SOURCES OF ENVIRONMENTAL INFORMATION
A. Roytech's Suspect Chemicals Sourcebook
B. Internet:
EPA: http://www.epa.gov
Enviro-Net: http://www.enviro-net.com
ACHMM: http://www.achmm.org/alinks.html
Thermoset Technology Division of the SPI.
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