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Chemical Manufacturers Welcome Challenges OfProduct Stewardship Final and most comprehensive Responsible Care code calls on producers to ensure safe passage of products from cradle to grave Susan J. Ainsworth, C&EN Houston, and Ann M. Thayer, C&EN Northeast News Bureau A s the chemical industry strives to / % restore its image and build credJ L S L ibility in the eyes of the public, companies have come to realize that they no longer can afford to surrender responsibility for their products at the close of a sales transaction. Communities around chemical plants, regulators, and environmental groups continue to raise questions about how chemical products impact human health and safety and the environment. As a result, chemical makers are taking on a broader role in the marketplace as responsible stewards of their products. Additional motivation to accept this weighty charge comes from the Chemical Manufacturers Association's (CMA) Responsible Care initiative. As a condition of membership in CMA, the 185 U.S. chemical-producing companies in the association pledge to support a continuing effort to improve the industry's responsible management of chemicals. To place more emphasis on proper use and handling of chemical products from cradle to grave, CMA members approved the sixth and final code of management practices—product stewardship—in April 1992. These practices, which companies are striving to have in place by 1997, aim to make "health, safety, and environmental protection an integral part of designing, manufacturing, marketing, distributing, using, recycling, and disposing of products." Although companies are approaching implementation differently, they face similar difficulties in addressing what many believe is the most encompassing of the Responsible Care codes. Internally, challenges derive from struc10
OCTOBER 17,1994 C&EN
turing and managing integrated companywide programs and allocating resources to areas where they are needed most. Externally, relationships with suppliers, contractors, distributors, and customers are evolving as chemical companies share new responsibilities of product stewardship. Even the most fundamental business aspects—products and processes—are changing in
light of stewardship concerns. But in the long term, after costs and benefits are weighed, product stewardship may help preserve the image, credibility, and continued success of the industry, as well as foster health, safety, and environmental protection. "Product stewardship is a significant activity and one that we put considerable resources into," says one chemical product stewardship manager. "But we believe there is also a sizable payback associated with it that doesn't necessarily affect the bottom line. The mere act of being proper stewards of our products and being very careful about how they're used ensures the products' longevity. And of course that is going to keep . . . our business viable as long as we take care of our homework and do our job." Unlike other Responsible Care codes,
product stewardship is not facility oriented. Instead, companies must implement and report on the code's 12 management practices companywide. Product stewardship may pose new complexities, explains Suzanne Croft, CMA's manager for product stewardship, "because it ties operating units of companies together that maybe previously weren't [connected], and in many companies, the infrastructure doesn't exist for easy communication." DuPont has had to coordinate efforts with other parts of the company as well as reach out to customers, recyclers, and industry associations to develop a more environmentally friendly process for making its Tyvek spunbonded polyethylene mailing bags. As a result of the coordinated effort, the company now produces Tyvek bags with 25% postconsumer recycled highdensity polyethylene derived from used milk and water jugs. In the past two years, this use of recycled material has kept more than 800 million jugs from landfills, says David E. Scarborough, business planning manager for DuPont's fibers department. To steward the Tyvek products further in their life cycles, DuPont has set up a corporatewide system to collect bags from many of its customers so that the bags can be recycled. For example, the bags can be reprocessed into products like plastic lumber, which is used to make various products, including landscape timbers, sign posts, household and marina decking, playground equipment, and park benches, says Scarborough. "Through the extensive effort and cooperation of these many groups, the program dedicated to the recovery of Tyvek has been a success." Although most companies do not have all their product stewardship prac-
tices in place, progress is being made, Croft says, and (ZMA is developing resources to help its members. By the end of 1994, chemical producers will complete the third annual self-evaluation process for CMA. Companies must rate their progress according to six stages: no action, evaluation of existing practices, d e velopment of an implementation plan, implementation, management practices in place, and reassessment of implementation. Depending on where a company stands when it starts the process, both the approach taken and the progress made to date differ widely among companies. Many chemical firms, such as Dow Chemical, DuPont, and Cytec, say that they have been building on existing programs. Dow dates its stewardship efforts back nearly 20 years, says Gregory G. Bond, senior manager for chemical technical service and development and environmental affairs. Even so, Bond, who manages product stewardship for Dow^ chemicals businesses worldwide, ranks the company as having had the code only about 68% in place in 1993. The need for product stewardshiprelated activities has been recognized for many years in agricultural chemicals. In 1987, when Rhône-Poulenc, Cranbuiy, N.J., acquired a division of Union Carbide, the company set up a formal product stewardship group, ex* plains Robert Bertwell, director of environmental affairs at Rhône-Poulenc's agricultural chemicals division. "It was management's perception at the time— because we were in the very high profile business of agrochemicals—that a group in and of itself was justified to deal with the issues we had on the platter." Much work still needs to be done, most product stewardship managers admit. Although reporting on a companywide basis, many manufacturers are setting priorities and choosing specific business or product areas in which to work initially; later, they will focus on full implementation of their programs. Initial choices generally depend on some measure of importance or concern to the company or its customers or on an inherent risk or hazard associated with certain products. At the same time, comments Bernard
DuPont uses high-density polyethylene derived from discarded milk jugs (above) in an environmentally friendly process for manufacturing Tyvek bags. The company collects used Tyvek bags from customers (aboveright)for reprocessing into plastic lumber, which can be fashioned into various products, including the park bench shown on the rigfit D. Silverstein, product stewardship manager for Arco Chemical, Newtown Square, Pa., "we never expect to be 'fully there' since it is a continuous improvement process. Once we get to a point at which we feel comfortable, we'll just move the target a little bit further on." Eventually, the stewardship process is expected to reach all parts of an organization, not only from product or business perspectives but also in terms of company operations and functions. Thus, a common approach is to set up an oversight committee, often including senior management, to review the code, set policies, determine general procedures, and provide guidance. These committees are cross-functional as well, not only with specific product stewards but also with representatives from sales, marketing, safety, legal, transportation, R&D, environmental, toxicology, and other areas. However, Don Walker, product stewardship coordinator for Chevron Chemical's Houston-based olefins division, believes that such committees are rapidly "working toward self-extinction." Initially, the committee is a good approach, he explains, but "to be effective, the
business teams are the ones that have to implement [the programs]." In practice, broad stewardship policies are being adopted to meet specific business or customer needs. At Ashland Chemical, in addition to its policy committee—which is a subcommittee of the company's senior management Responsible Care committee— the company has set up product stewardship councils for all its product lines in each of three major operating groups: distribution, specialty chemicals, and petrochemicals. Because of its rare position as both a manufacturer and a distributor, Ashland's challenge is handling more than 6,000 products going to more than 60,000 customers, notes Scotty B. Patrick, group vice president for petrochemicals and technical at the EHiblin, Ohio-based company. The councils exist to implement the code and to deal with day-to-day issues such as risk management and product handling. The frontline people for product stewardship tend to be those in sales, marketing, and technical and customer service because of their familiarity and OCTOBER 17,1994 C&EN 1 1
NEWS FOCUS
Responsible Care's Product Stewardship Code of management practices Information and Characterization • Establishes and maintains inforPurpose: To make health, safety, and mation on health, safety, and environenvironmental protection an integral mental hazards and reasonably forepart of designing, manufacturing, seeable exposures from new and existmarketing, distributing, using, recy- ing products. cling, and disposing of the products of • Characterizes new and existing members of the Chemical Manufac- products with respect to theirriskby turers Association (CMA). The code using information about health, safeprovides guidance as well as a means ty, and environmental hazards and to measure continuous improvement reasonably foreseeable exposures. Esin the practice of product stewardship. tablishes a system that initiates reScope: Covers all stages of a product's evaluation. life. Successful implementation is a Risk Management shared responsibility. Everyone in- • Establishes a system to identify, volved with the product has responsi- document, and implement health, safebilities to address society's interest in ty, and environmental risk-managea healthy environment and in prod- ment actions appropriate to the product ucts that can be used safely. All em- • Establishes and maintains a system ployers are responsible for providing that makes health, safety, and environa safe workplace, and all who use and mental impacts—including the use of handle products must follow safe and energy and natural resources—key conenvironmentally sound practices. The siderations in designing, developing, code recognizes that each company and improving products and processes. must exercise independent judgment • Educates and trains employees, on and discretion to successfully apply the basis of job function, on the propthe code to its products, customers, er handling, recycling, use, and disand business. posal of products and known product Management practices: Each member uses. Implements a system that encompany shall have an ongoing courages employees to feed back inproduct stewardship process that formation on new uses, identified misuses, or adverse effects for use in provides the following: productriskcharacterization. Senior Management Leadership and • Selects contract manufacturers who Commitment employ appropriate practices for • Demonstrates senior management health, safety, and environmental proleadership through written policy, ac- tection for the operations under contive participation, and communication. tract or works with contract manufac• Establishes goals and responsibili- turers to help them implement such ties for implementing product steward- practices. Provides information and ship throughout the organization. Mea- guidance appropriate to the product and process risk to foster proper hansures performance against these goals. • Commits resources necessary to dling, use, recycling, and disposal. Peimplement and maintain product riodically reviews performance of contract manufacturers. stewardship practices. Approved: April 1992
direct contact with customers. "Stewardship really is a function of customer service and ensuring that the products are [delivered] in a reliable manner, that they are used properly, and that customers understand where they can get additional assistance," says Timothy Goodson, director of health, safety, and environmental affairs for RhônePoulenc's specialty chemicals division.
Employee commitment Among the greatest challenges in implementing the Product Stewardship Code is making the process an integral 12
OCTOBER 17,1994 C&EN
part of everyday companywide operations and employees' thinking, especially in the sales and marketing functions. As Walker comments, it means getting people "not to think of [stewardship] as something beside your business but rather something that is a part of your business." Keeping enthusiasm among employees consistently high is also very important, he adds, as is preventing product stewardship from being viewed as another "flavor of the month" corporate initiative. 'They've got the bottom line, and they've got a thousand other
• 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. • 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 these 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. These management practices should be implemented in conjunction with the Distribution Code of management practices. • Provides health, safety, and environmental information to direct product receivers. Commensurate with productrisk,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. Source: Chemical Manufacturers Association
things on their plate to worry about, so it is hard for them to always be thinking about product stewardship," says Walker. Senior management commitment is crucial, say chemical company managers, but may be a given when the company they head signs on to Responsible Care. Key to actually getting a code like product stewardship in place, they observe, is getting all employees to understand it, its purpose, and its potential benefits. The next challenge is to entice employees to use the tools that have been developed. With a steward
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NEWS FOCUS appointed for each product manufactured, Dow actually ties stewardship into these employees' job descriptions and duties, as well as annual performance goals and evaluations. The idea of product stewardship "not as added costs but as added value" frequently is pitched to middle management, sales and marketing employees, and customers. To help companies, CMA provides resources with examples of success stories directly aimed at marketing functions. "One of the chief issues is getting our business units to recognize the worth of the effort. If management there is not in favor of undertaking this kind of activity and doesn't understand the benefit, [then] you have a difficult time," says Goodson of RhônePoulenc. "Once that hurdle is overcome, the reallocation of resources and getting the right skills and the right tools in people's hands become a relatively simple process." Such challenges will continue into the future, he observes. "Building product stewardship into practice and having [employees] develop and use those skills naturally whenever they are with a customer is something that is built over years." Initiatives like product stewardship require resources—primarily people, time, and money—and where these are allocated often depends on how companies organize and prioritize their stewardship efforts. Many do not hire new staff, except possibly a few coordi-
nators or managers, and choose instead to make product stewardship part of each employee's job. By distributing the effort among many individuals in diverse areas, West Paterson, N.J.based Cytec has not had to devote added resources to its program. However, most companies still dedicate much time and effort to training, particularly their sales and marketing professionals. Cytec's product stewardship training team has developed a multifaceted program that is being presented to all employees. A core awareness program includes a slide presentation introducing product stewardship, a videotape giving concrete examples of stewardship throughout product life cycles, and a brochure highlighting case studies. A more in-depth program on areas such as hazard communication, regulations, and life-cycle analysis is being developed. Although companies estimate implementation costs as fairly significant, actual figures are never given and often are not tracked. An exception is Chevron Chemical, which has a separate budget for funding its implementation programs. However, Walker anticipates that as the company's business units take over stewardship practices they also will take over budgeting and funding. Overall, most managers do not consider the costs burdensome and say they are being accepted as a necessary or unavoidable part of doing business in today's environment. Still, Arco Chemical is trying to re-
duce its costs by targeting key concerns and prioritizing use of its resources. These are issues the company is "struggling with, especially in the present economy," notes Silverstein. "The answer [to] how much it will cost in the long term really depends on how far downstream we have to go. How much of the product's life cycle do we have to embrace? And how much do we do with our 'safer' products?" Company managers also are not specific about whether or by how much stewardship efforts are contributing to higher prices for products. Although Bertwell of Rhône-Poulenc admits that there probably are increases, "if you have a product available... where you might [otherwise] lose it if you are not doing a good job stewarding it, then it pays for itself. So you've got costs, but you've also got benefits coming back." For example, most companies can cite cost savings through cutting waste, recycling materials, using raw materials and energy more effectively, and decreasing environmental or other concerns, such as safety, before they occur.
Beyond the fence line
Whereas companies are focusing much effort on developing their stewardship programs internally, the real impact of the program will be outside their gates. Unlike other Responsible Care codes, says Ralph E. Smith, manager of Responsible Care and quality at Dallasbased Occidental Chemical, "this one is outside the plant fence lines. It is the first time that we have really started to deal with the customer end of the equation." Resources are being directed at developing communication and information tools for dealing with customers and other third parties. Working more closely with third parties—distributors, carriers, warehouses, contract manufacturers, and customers—is presenting many challenges. Among these are questions of how to approach customers, how to develop common understanding of associated hazards and commensurate risk information, and how to ensure customers are receiving the needed information. Throughout the exercise, company managers say that relationships with customers are changing, and even strengthening, through a greater awareness of their customers' needs. "I think we are looking to partner Responsive to product stewardship concerns, Dow scientists discuss potential uses, more with our customers," says Dow^ misuses, and hazards of a product based on laboratory findings. 14
OCTOBER 17,1994 C&EN
At Degussa, Responsible Care is having a ripple e PitXtygtisstiy the underlying prfkciplgs qfU^pûùsibleCflrë^ Hot mw*l We've always felt that enytrfinmenwlmanagement tstm bestœouïsefor bur customers, our erriployeeêyand the çommiinities in wnfcfiiveiive. J hrôughùut ouientire company> theseprinciples are àifvqrk ôhfy daily hasts. Products, processes, and:ëyen packaging are bemg sftapedp a greateréxtentby ennmnmenwi initiatives, uur MoMte; M^^tnàchtfnical complex Uses byproducts of one process "as raw materials for another, substantially reducing Plant u>aste. iik^Wise, progressive ideas such as WéciWs nietats recmtihg and reusable, htgfoefpcteney
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At Chevron, Don Walker (right in photo at left), a product stewardship coordinator for Chevron olefins, and fames Talton (left), a process safety coordinator, discuss a customer's audit of the company's Cedar Bayou plant, Baytown, Tex., which would include inspection of procedures for loading of olefins (above). Bond. "We need to convince them to assume their share of the burden of product stewardship." As a supplier, he explains, a company has an obligation to provide customers with accurate information on the performance characteristics of a material and its environmental, health, and safety properties and maybe to offer training on how to use it and dispose of it. "But we cannot be in a customer's facility every day when they are handling the product. They have to carry through their share of the burden of performing in an environmentally safe and effective manner. And we just have to convince them that we are partners in this, and together, if we are both holding up our ends, we are going to be successful." Still, say managers, there is a very small number of customers who are not even interested or who are reluctant to share information. More often, however, customers actively seek stewardship help and may see it as an added value. "When I first approached Arco Chemical senior management on the concept of going to customers and evaluating how they are handling our products, we were concerned that customers wouldn't let us in the door, let alone show us their products and their processes. And I was challenged to demonstrate that we could even do that," says Silverstein. 'That's where we started, and of course, we not only got in the door but we have had some very, very good dialogue." Between CMA member companies, the relationship can be relatively 16
OCTOBER 17,1994 C&EN
straightforward, because both parties are working under the same codes. This assumption can even be extended, because other trade associations such as the Synthetic Organic Chemical Manufacturers Association and the National Association of Chemical Distributors (NACD) have adopted Responsible Care or similar initiatives. But the situation can be complicated when customers, suppliers, or distributors are not CMA members. For example, Occidental Chemical estimates that less than 4% of its customers are CMA members.
Poulenc developed a program called Responsible Pesticide Use to communicate to farmers "how Rhône-Poulenc wants its products managed." The program encourages farmers to store chemicals properly, under lock and key, and not to distribute them to others who may misuse them. It has been successful and well received by the industry, Bertwell says. "The company was concerned enough to develop this program... to try to communicate to the grower that there were ways we did not want our products used, that there were severe penalties associated with misusing them, and that they Preaching to the choir could be implicated if they ended up "While a lot of our advertising is sort giving our materials to someone else of preaching to the choir," says Smith, who used them in an improper way." "we have a very diverse customer In addition to having a diverse range base, and so we have a selling problem of customers, most companies must there. We need to get customers on- also manage a broad range of products, board with the entire concept, plus we each requiring a different type or dehave problems trying to figure out how gree of stewardship. Surveying custo approach customers." For example, tomers and other third parties about he asks, how do you tell customers that what they want or need is a frequently you don't like the way they're operat- used means of developing information ing while trying to make a sale at the resources for product stewardship. same time? And companies must deal Product literature as well as seminars with customers with very different lev- and training are among the informaels of technical knowledge and experi- tion and communication tools being ence in handling chemicals. developed by companies to be provid"When we see that there is an issue ed to third parties by sales, marketing, developing—it may be related to a par- and technical personnel. ticular activity that represents a gross The most frequent starting point for misuse or abuse of one of our prod- information is material safety data ucts—we take a very active role in de- sheets (MSDSs), which are routinely veloping specific communication and distributed with products under Occueducation programs to attack that prob- pational Safety & Health Administralem and try to alleviate it," says Bertwell. tion and Department of Transportation About a year and a half ago, Rhône- regulations. Chevron Chemical has
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been working to update and provide new information in its MSDSs and to set up a new system that updates their distribution daily. Walker explains that, depending on the product, Chevron Chemical has different ways of communicating guidelines for handling and use. For low-risk products, guidelines may be left with a customer along with a phone number to call for information. Guidelines for higher risk products might be reviewed with a salesman. And for an extremely high risk product, the salesman may take along technical representatives to meet with the customer's technical people to determine if training or additional help is warranted. As well as the MSDS, specialty chemical producer Velsicol Chemical uses internal information management systems that include a comprehensive list of acceptable and unacceptable uses of products to respond to customer concerns. For example, storage is 18
OCTOBER 17,1994 C&EN
ers product-use information primarily by surveying its customers, either through mail-out questionnaires or during the course of sales calls, says Smith. To augment that system, Occidental Chemical plans to train its technical personnel to serve as the company's eyes and ears when they are out interacting with customers. The effort is one step in Occidental's plan to devise a more uniform and comprehensive system for gathering end-use feedback on its products. Like many companies, Olin, based in Stamford, Conn., says some of its businesses already have in place very good systems for gathering customer feedback on the use, handling, and disposal of its products; the challenge lies in bringing all of its businesses equally up As partners in Responsible Care, to speed. In one notable program, Chevron and Stolthaven (Houston) Inc. employees work together Olin's pool chemicals business has set up a "pool care hot line" that serves as (above) to ensure safe handling of Chevron products, including "an invaluable source of information unloading of olefins at about how our products are being used Stolthaven's marine terminal at or misused." The primary purpose of the Houston Ship Channel (left). the hot line is to allow the average consumer to call in to get information among the areas of greatest con- about how to use Olin's products, says cern for its customers. For haz- Foster Gerrard, director of safety and ardous chemicals, it is company loss prevention for Olin's chemical dipolicy that a product will not be visions. With the information culled sold until the product steward from as many as 200,000 calls per pool knows how the buyer will use season, "we can go back and improve and handle it. The Rosemont, our literature or improve our training Ill-based firm also has found it programs" to help ensure that prodnecessary to visit customers at least an- ucts are used properly in the future. nually to determine how products are As companies work to expand their being used and handled and to answer customer feedback channels, they recquestions. ognize the need to prioritize their efArco Chemical has developed what fort, to focus on more hazardous prodit calls product safety bulletins, which ucts or those that go into newer, more usually run about 100 pages and de- dynamic end-use markets. The maturiscribe health, safety, and environmen- ty of end-use markets is a factor that tal hazards; proper handling proce- companies consider in prioritizing their dures; good industrial hygiene; stor- customer feedback efforts. Gathering age; and other practices, explains customer feedback is not as high a priSilverstein. The company has bulletins ority at Occidental Chemical, says for its six high-priority products in Smith, partly because its core products each of three regional areas—Europe, have been used in the same way for many years. "Chlorine, caustic soda, the Americas, and the Pacific Rim. and polyvinyl chloride have been Customer feedback channels around a while, so we don't expect to As manufacturers develop closer re- get hit with any new surprises relating lationships with their customers, they to how these products are being hanare gaining a more sophisticated un- dled or used by our customers," says derstanding of how their products are Smith. Organizing product-use data into a being used. The Product Stewardship Code is motivating companies to de- usable form is another challenge that velop more formal methods of collect- many of DuPont's strategic business groups have tackled. "Typically, we ing product-use feedback. Currently, Occidental Chemical gath- are simply adding product steward-
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Product Stewardship Code spursriskassessment, management efforts Chemical manufacturers have been assessing and managing risk associated with their products for a long time because of the nature of their business. However, the Responsible Care code of management practices adopted by the Chemical Manufacturers Association (CMA) is pushing companies to develop more sophisticated systems for dealing with risk, factoring in information about health, safety, and environmental hazards and reasonably foreseeable exposures. Few, if any, companies seem untouched by this effort. Smaller companies are struggling to develop grassroots programs. And industry leaders are equally busy refining the way they carry out risk assessment and risk characterization of their products in the interest of continuous improvement that runs as a common thread through all of the Responsible Care codes. Recognizing the challenges inherent in developing risk characterization and management programs, CMA is developing a resource tool that will help smaller companies with more limited resources develop their own programs, says Suzanne Croft, CMA's manager for product stewardship. The resource tool, entitled "Product Stewardship Guidelines for Risk Characterization/Risk Management/' addresses risk characterization and subsequent risk management by providing an overview of the components, hazard, and exposure evaluations. Under the current schedule of development, it is expected to be available later this month from CMA Publications Fullfillment Unfortunately, no one program can be cloned for use by every company.
ship as an element of existing qualitytracking systems," which are computer-based schemes that simplify reporting and tracking of quality information about a product, says J. Richard Haden, DuPonf s product stewardship manager. "What we've been able to do is modify those systems slightly so that they will accept product stewardship information as well as quality information, which really [aren't] all that different." Built into the system is a mechanism for notifying appropriate business team members of any problems with how a customer is using, handling, re20
OCTOBER 17,1994 C&EN
Each manufacturer has its own set of priorities, based on its customers' needs, says Croft. However, in the spirit of sharing that many companies say is "the beauty of Responsible Care," companies are using other companies' programs as models for their own. Like most chemical manufacturers, Dow Chemical uses a risk characterization system that factors in a product's flammability, explosivity, reactivity, toxicity, tendency to persist in the environment, and potential to bioaccumulate in the environment On the basis of these data, it then assigns each product to one of three categories, reflecting how hazardous it is. These characterizations are tied to specific practices that help Dow manage risk. For example, products in the most hazardous category are not sold through a distributor Dow ships directly to its customers and only in bulk, not in drums, says Gregory G. Bond, the company's senior manager for chemicals technical service and development and environmental affairs. As part of its risk management effort, Dow also conducts what it calls product stewardship reviews. In this process, upper management teams study each business and its products, looking at all aspects of the life cycle and how the business is managing the risks inherent in its products. Then they recommend "action steps" for the business to take to improve its product stewardship. Every product gets reviewed at least once every three years; hazardous products are checked out more frequently. Most chemical manufacturers agree that they cannot keep tabs on the risk associated with all their products all the time. Prioritization is key. Occi-
cycling, or disposing of a product, "so they can act on it." Most often, companies can correct improper practices involving their products through limited intervention—communicating with a customer or offering assistance. In addition, companies such as Dow try to take a proactive approach by learning as much as they can about an intended product use even before beginning a sales relationship. "We want to find out about any inappropriate applications for our products ahead of time and prevent any potential mishaps," says Dow^ Bond.
dental Chemical uses commensuratewith-risk definitions to identify the products that need most attention, says Ralph E. Smith, the company's manager of Responsible Care and quality. "Basically, that means that chlorine is not treated exactly the same way as polyethylene pellets." The company has developed a three-part formula to assess the risk associated with its products, and the data are pulled together on a spreadsheet that business teams and salespeople can access to help them make informed management decisions. One part of the formula factors in the volume of product used and the Hazardous Materials Identification System rating, a designation developed by the National Paints & Coatings Association that accounts for how hazardous, flammable, and reactive a material is, says Smith. The second level of the formula factors in how the customer uses chemicals through a relative ranking done by Occidental Chemical's sales or marketing professionals, says Smith. "In other words, are they using it all in closed vessels, such as tanks or piping, or do they have 50 people sitting at a long table working with this material by hand?" The third part of the formula takes into account the sophistication of the customer. "A customer that is a leader in safety and health management is not going to be as much of a concern as a small outfit working out of a garage," for example. With a relative ranking in place for each of its products, "we can prioritize our efforts to help the customers that need it most, and thafs important, given that Occidental Chemical does not have unlimited people, time, and money."
However, when Dow determines that a customer is not using or handling one of its products correctly, the company goes through a multistep process that has led to withdrawal of sales, says Bond. In that process, Dow first notifies the customer that the company has an objection or a concern and then attempts to talk to the customer about how Dow might help improve the situation. Dow^ sales organization usually initiates the dialogue, but the discussion sometimes moves to upper management "to get the proper attention to the issue. We give the customer
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some time to work on the problem, and if the effort fails, we let them know we may have to suspend sales and then proceed to do that, if necessary." Bond says Dow terminates sales relationships on a fairly infrequent, but regular, basis. Recently, for example, the company learned that a customer, by heating a Dow product, was producing decomposition products that posed an environmental threat. "We tried to work with them, but in the end, we just could not support that application." Chevron Chemical, too, recently cut off supplies of a heavy aromatic distillate to a customer because "we could not get enough data to feel comfortable about how it was being used," says Walker. "After visiting the customer's location, a business team decided that we were not going to sell the product to that customer for environmental, health, and safety reasons. This particular team probably would have made the same decision in the absence of the Product Stewardship Code, but it sure makes it easier to arrive at that conclusion when you know that the corporation is asking you to look at this issue very carefully." Although companies are sometimes forced to terminate sales relationships, they say the step is used only as a last resort. If s much more constructive to try to bring that customer up to speed on how to handle a product rather than abruptly cut them off, says Bond. Passing along that knowledge could help prevent a future accident with another supplier's product. "We want to work to improve the overall performance of everyone in the industry, because we are being judged by the lowest common denominator," he adds.
up a distributor product stewardship program under which "we have actually gone out and made physical inspections of more than 300 sites—all of our general chemical distributors' facilities—over the past five years." Although on-site audits are an effective way for manufacturers to ensure that distributors are properly handling their products, they tie up a lot of resources and can be disruptive to a distributor's operations. Recognizing this problem, NACD is developing a thirdparty verification program under which it will audit its members' facilities for environmental, safety, and health performance and share the results with interested manufacturers. The vigor with which NACD has adopted this program "has given us greater confidence in their operations," says Bond. As a result, Dow is moving away from its own auditing program. "If our distributors are going to be proactive in engaging a third party to inspect their operations, it means we don't need to be going into their facilities as often to do it." Manufacturers also are putting more faith in distributors and other chemical handlers that have become partners of Responsible Care. In June 1990, the CMA board approved a program that shares the Responsible Care initiative with companies that do not believe they can participate as members of CMA—which is set up specifically to serve the manufacturing community. As a partner, those companies must
implement all elements of the code that apply to their business. In return, a partner company or association gets the opportunity to help shape the Responsible Care initiative as it continues to grow and mature. The partner also gains access to an expanding resource network that will aid the implementation process. Most important, the program gives distributors and chemical carriers a forum for showing that they understand the obligation that goes with the product they are handling. To help its members screen distributors that are not Responsible Care partners, CMA's distribution committee has developed a self-assessment protocol for distributors. For example, Ashland Chemical says it gives the document to its distributors and asks them to evaluate themselves. As a distributor itself, Ashland says it has rated its own performance by using the protocol and shares the results with any of the manufacturers it deals with. From a manufacturer's perspective, the protocol saves time and allows it to compare its distributors on the same basis. As if it were not enough to keep tabs on how customers and distributors are handling, using, and disposing of their products, some manufacturers are making the effort to track their products later in their life cycles, in keeping with the spirit of the code. Rhône-Poulenc, for instance, has set up a stewardship program to encourage its customers and distributors to monitor all sales of its materials. "We want to know ex-
Auditing distributor operations In addition to focusing on customers, the Product Stewardship Code calls on CMA companies to review periodically how distributors are handling their products, to work with them to smooth out any problems, and to terminate the business relationship, if necessary. To address this management issue, Eastman Chemical, based in Kingsport, Tenn., ensures that its distributors are trained in proper storage and handling of products. In addition, a health, safety, and environmental assessment team reviews new distributors to be sure that they will take proper care of Eastman's products. Similarly, Dow has set
As part of a continuing effort to ensure proper product handling, an Ashland Chemical salesman explains product information to a purchaser of fine ingredients. OCTOBER 17,1994 C&EN 2 1
NEWS FOCUS
Life-cycle analysis measures costs within 'system boundaries' From a groundbreaking study books of a company. But like acin 1969 that analyzed packaging counting, there are conventions. If and was sponsored by Coca-Cothose are agreed [upon], you can la, life-cycle analysis (LCA) has have comparable results from difdeveloped into a serious disciferent analyses. Now you can pline for measuring the impacts have two LCAs and get two difof processes and products on the ferent results. They are different environment—and on a companot because the science was ny's financial results. The methwrong, or the adding up was odology has been advanced furwrong, but because the assumpthest in Europe, where it already tions were different" is finding its way into public One study by Dow Europe expolicy-making and environmenamined recycling of high-density tal initiatives. polyethylene bottles used,forex-, ample, as containersfordetergents The discipline has spawned and fabric softeners. Supported by two organizations dedicated to the Brussels-based Association of the methodology. One is SETAC, Plastics Manufacturers in Europe, the Society of Environmental Dow Europe's Russell (left) and Fussier (right)the study looked at four options Toxicology & Chemistry, foundfor disposing high-density polyed in 1979 and currently based in consider data from life-cycle analysis in weighing options for critical issues such as recycling. ethylene mechanical recycling, inPensacola, Fla., and in Brussels. cineration with energy recovery, Its members are individuals working to develop LCA into a rigorous effects directly associated with manu- incineration, and landfill Costs of the science. The other is SPOLD—the Soci- facture. 'Tor LCA, the system boundary initial bottle manufacturing, delivery, etyforthe Promotion of LCA Develop- must therefore be drawn around the and so on were assumed to be conment—founded in 1992 and based in whole life cycle of the materials and en- stant, and so the study was abletofocus solely on costs of different disposBrussels. Its members are companies ergyflows,"he observes. who support LCA as a decision-makAccording to David Russell, project al options. Energy recovery became ing tool leader for life-cycle assessment at the key facton A combination of enerOther trappings indicate that LCA Dow Europe, "What life-cycle analysis gy recovery and mechanical recycling has "arrived/' For example, "The LCA does is make you think about a lot of offers the best environmental results Sourcebook, a European Business different things to lead you to make in both energy and resource optimizaGuide to Life-Cycle Assessment" pro- better decisions. You can take a broad- tion, the study concluded. vides a wide range of information er view of your business." The study ran nearly 18 months, but about methodology, consultants, and Claude Fussier, vice president for much of that was setup time—such as databases, among other subjects. It environment, health, and safety at setting up computer systems, learning was published last year by SPOLD, Dow Europe and president of SPOLD, what questions to ask, and determinU.K. environmental consultants Sus- observes: "It used to be that people ing how to analyze the answers. "If tainAbility, and Business in the Envi- would look at, for example, how much we were to repeat the study now, ronment, a London-based nonprofit would a product weigh, how much knowing what we do now, it would organization. would it cost for its functional perfor- probably take about two man-months Roland Clift, director of the Centre mance. Or they would look at the en- of effort," says Russell. "The initial for Environmental Strategy, University ergy consumed or the feedstock tied hurdle is particularly expensive— training the people, and so on." of Surrey, U.K., speaking before the up in its manufacture." Chemical Industries Association's inBut another way to make a material As a result, companies are working vestment intentions conference in Lon- choice is to look not only at the eco- to develop techniques for "scoping," don this past April, noted that LCA is nomics but also at an environmental or condensing LCAs, for relatively increasingly being used as a decision- profile. "LCA helps you get a broad quick and superficial analyses, when supporting tool in improving environ- view of complete systems. You see op- full studies are not needed. Argues mental performance. LCA attempts to tions when you look at the data, and John Elkington, a director of Sustainaccountforthe upstream inputs of ener- you can attach costs to them," Fussier Ability, "Don't do an LCA just to d e gy and materials and downstream says. fend the status quo—it works best as emissions and residues of a product or Adds Russell: "LCA should be part of an opportunity-led approach." process, as well as those environmental something very neutral, like doing the Patricia Layman actly where they are going, who has actually purchased them, and how they will be used," says Bertwell. As added motivation, Rhône-Poulenc gives monetary compensation to customers who properly steward their products and severely penalizes those who fail to perform. Although Bertwell declines to 22
OCTOBER 17,1994 C&EN
specify how hefty penalties might be, he says that they "can be large enough to tie up a significant portion of a customers' livelihood." As manufacturers set up systems to track products as they flow to distributors, customers, and other users downstream, CMA members also must en-
sure that they are looking over the shoulders at their suppliers. The code requires that manufacturers get the appropriate health, safety, and environmental product information and factor it in their purchasing decisions. But manufacturers say they are just now beginning to address the issue of
fËV«ΕHARDTOCmTHEM OL α
generation enjoys a higher standard of living than ever before. The marvels of this centuiy include trans
portation, communications and chemistry for better living. • But these achievements have not come without a price. Any schoolchild can tell you the dangers we face in air, water and soil pollution. • As one of the worlds leading chemical manufacturers, Rhône-Poulenc actively supports a program called Responsible Care®, the chemical industry's public commitment to protecting our environment. In the United States alone, Rhône-Poulenc has reduced releases to the environment by nearly two-thirds since 1987. • But this is not good enough. Our pledge is to continue to improve our performance with the goal of being one of the most environmentally sound companies in our industry. All while serving mankind with products that give us a better way of life. • We believe this responsibility of caring for the environment rests squarely on our shoulders now, for the generations to come.
||
(ÏP RHÔNE-POULENC \
CN 5266, Princeton, New Jersey 08543-5266 (908) 297-0100
© 1994 CIRCLE 3 1 ON READER SERVICE CARD
"We're All Product Stewards At Cytec." The people of Cytec are commited to their customers and their communities around the world, to make safety, health and environmental protection and integral part of each product's life cycle stages including designs, manufacturing, marketing, distribution, use, recycling, and disposal.
m
CYTEC PRODUCT STEWARDSHIP STAGE ONE
STAGE TWO
STAGE THREE
STAGE FOUR
Customer Need
Product Design and
Raw Materials Selection
Manufacturing
Development
Continuously work with customers to understand their health, safety, and environmental goals, as well as their performance requirements, to determine how Cytec products can help meet these goals.
Design and develop products to meet customers' needs. Use laboratory and field research to evaluate new products, especially for health, safety, and environmental performance. Work to develop products with reduced environmental impacts including energy use reduction and reduced disposal costs. Potential product and process risks are estimated.
Research ways to reduce our use of toxic or hazardous raw materials while maintaining product performance. Raw materials are substituted as appropriate. Cytec requires raw materials suppliers and contractors to review their products and processes so that they supply the most effective materials and the latest health, safety, and environmental data.
Cytec's products are manufactured with the objective of enhancing the safety of Cytec's and our customers' employees; minimizing production of waste; conserving energy; improving the production process; and reducing adverse environmental impact.
STAGE EIGHT
STAGE SEVEN
STAGE SIX
STAGE FIVE
Disposal
Recycle and Re-Use
Product Usage
Product Distribution
Containers and unused products are recycled or disposed of in a safe, efficient manner which meets or exceeds applicable environmental regulations.
Minimize waste production and energy consumption to conserve the environment and improve productivity. Conserve natural resources through recycling and utilization of waste raw material, packaging and products.
Labeling, Material Safety Data Sheets (MSDS), and technical literature inform Cytec customers how to safely use Cytec's products in a manner which minimizes risk to human health and the environment.
Shipments are made in properly labeled, high integrity containers, using thoroughly trained, qualified operators who follow approved procedures and are in compliance with all state and federal transportation guidelines. Responsible Care®
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IVTEC
CYTEC INDUSTRIES INC. Five Garret Mountain Plaza West Pâtërson, Nd Ό7424 201/357-3274
©1994 Cytec Industries Inc. All Rights Reserved :
NEWS FOCUS suppliers. Even though Dow has been practicing product stewardship for a long time, "we typically hadn't really thought of product stewardship as ex tending back to suppliers," says Bond. "We viewed it in terms of managing product through our R&D, production, distribution and then use and disposal by the customer. We've been very much downstream focused.
Including suppliers in the loop "Although we've always paid atten tion to who our suppliers are, the code is motivating us to look more deeply at their environmental, health, and safety practices," continues Bond. As a starting point, Dow is categorizing its suppliers according to whether they are members of CMA or other organizations with Re sponsible Care programs. To learn more about its suppliers that are outside that circle, Dow recently mailed out a survey asking these suppliers a series of ques tions about emergency response proce dures, safety and environmental pro grams, and hazard communication. "The survey is not meant to give Dow all the information it needs on the supplier's operations and philosophy of doing business, says Bond. "Rather it is designed to open the dialogue with our suppliers about their practices so we can then identify areas where we may need some improvement and work cooperatively with them." Dow hopes the survey also will convey the degree of its commitment to Responsi ble Care "and let [the suppliers] know that we are taking it seriously." Through implementation of the Product Stewardship Code, "we have come to realize that the supplier link in the chain is every bit as important to our overall business success as any oth er part," says DuPonf s Haden. Chev ron Chemical says it now appreciates better how its suppliers' procurement decisions and other management prac tices can have a bearing on Chevron's product risk characterization process, says Walker. For example, the risk management team for Chevron's plastics business unit realized it needed more data on additives it buys from suppliers to help it more accurately characterize emis sions from extrusion operations. "So very soon we will be at our suppliers' doorsteps, asking questions, looking for additional information, and hoping that they will help us," Walker says.
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OCTOBER 17,1994 C&EN 25
If Tomorrow's Chemists and Chemical Engineers Are to Have the Chance to Do Marvelous and Wondrous Things, Today's Chemists and Chemical Engineers Must Show Them the Way.. .Responsibly.
As children, we learn by doing. Often we are helped along by a teacher, someone whose experience can help us avoid mistakes and misunderstandings. Vulcan Chemicals is taking that same educational approach with our customers and in the communities we serve. Through programs such as our Chemical Product Responsibility Process (CPRp) and Customer CareT,M we are helping to ensure that employees and customers understand our commitment to attain environmental, health, and safety excellence. At Vulcan Chemicals, Responsible Care is more than a simple idea. It is a corporate commitment extending from our top executives to our engineers and truck drivers. CIRCLE 4 0 ON READER SERVICE CARD
Success with Responsible Care today means tomorrow's chemists and chemical engineers will still have room to explore. At Vulcan Chemicals, responsible leadership is an idea we practice every day.
Uulcan CHEMICALS
We Have the Future in Mind. \klcan Chemicals A Division of Wean Materials Company P.O. Box 530390 Birmingham, AL 35253-0390 1(800)873-4898
NEWS FOCUS bers, and resins without the use of p- year. These ethers are reduced-toxicity substitutes for existing products xylene feedstock. Spurred by product stewardship used in the coatings industry. As manufacturers get a grip on the most immediate links in the product concerns, companies are screening Arco is also among a handful of stewardship chain—marketing, distri- their products for environmental, companies applying product stewardbution, and end use—they are begin- health, and safety effects before taking ship principles even earlier in the R&D ning to extend their reach, looking back them out of the R&D laboratory. Arco cycle. In a process it calls product lifeto design and improvement of prod- Chemical says it always factors these cycle issues analysis, Arco conducts a ucts as well as forward to recycling and considerations into its decisions about systematic review of a potential produltimate disposal. Basically, the code whether to market a new product. A uct over its life cycle to identify barriers says that each company should estab- case in point is a series of propylene to commercialization as well as new lish and maintain a system that makes glycol ethers that Arco launched last market opportunities. The process health, safety, and environmental impacts—including the use of energy and natural resources—key considerations in designing, developing, and improving products and processes. Many companies have approached the "green" issue by reevaluating existing products and processes. Eastman Chemical, for example, actively tests existing chemicals to keep pace with advancing toxicological standards. DuPont, too, regularly screens its existing products. As a result of that effort, Haden says, it is often necessary to make changes in its manufacturing process, reformulate a product a couple of times to eliminate undesirable trace by-products or contaminants, or reduce a product's packaging. "It's been imCentury® CD can help you achieve portant for us to view our offerings not just as stand-alone products but as total greater value in your fatty acid mixture. This systems that are effective as well as enunique low color mixture of vegetable-based vironmentally sound." Similarly, Rhône-Poulenc "has made fatty acids (acid value 213) can be used some dramatic strides in its effort to reformulate our products to make them to replace or extend more expensive safer to handle," says Bertwell. Just this fatty acids and is produced at our year, the company commercialized a new technology that allows it to reforISO-9002 certified plant. mulate highly concentrated liquids into gel-like substances that can be envelMake a small change— oped in water-soluble packages. The get greater value with Century® CD. whole bundle can be "thrown into a tank" with liquids, allowing the material to be handled in a much safer manner and eliminating any packaging-disposal problems, he says. Product stewardship also has spurred companies to redesign manufacturing Union Camp OLEOCHEMICALS processes so that they are more enviUnion Camp Corporation ronmentally friendly. For example, this Chemical Products Division past March, DuPont unveiled plans to 1600 Valley Road expand its polyester-recycling capabiliWayne, New Jersey, NJ 07470 ties with the 1995 startup of a methTel 201-628-2331 anolysis facility at its Cape Fear site, Fax 201-628-2780 near Wilmington, N.C. Postconsumer products and postindustrial polyester We Never Stop Making Things Better once destined for landfill or incineration will be recycled chemically to produce virgin-quality polyester film, fiCIRCLE 3 3 ON READER SERVICE CARD Greener products and processes
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