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Chemicals management example, in most developing countries – to alleviate poverty and improve the quality of life. Some possible ways to develop more integrated approaches to the implementation of international initiatives are set out below. Development of coherent approaches at the national, regional and international levels depends on adopting mutually reinforcing approaches at all levels. How this could be achieved is also discussed. Sound management of chemicals as a competitiveness factor Sound management of chemicals involves ensuring that they are managed throughout their life cycle in ways that result in minimum adverse effects. Increasingly, chemical suppliers’ customers are demanding, inter alia, sound information about chemicals’ hazards to ensure that production processes do not have significant adverse effects on human health or the environment and that the chemicals are transported safely. These demands by customers along the chemical value chain can have a significant impact on suppliers’ competitiveness. They are increasingly being recognized by the chemical industry as important to the industry’s continued competitiveness. This is particularly relevant in emerging markets, where legislative controls traditionally may not meet international norms. Mainstreaming sound chemicals management into the industry’s economic and investment strategies is a powerful instrument for promoting improved performance at the national level. Moreover, industry automatically seeks to streamline compliance with requirements and so makes a useful partner for governments in this regard. The impact of national activities on regional and international coherence Fragmentation of national approaches to regional and international instruments results in ministries engaging in activities at the regional and international levels without necessarily consulting with other relevant ministries. An example has been the almost complete absence of participation by economic ministries in the development of multilateral instruments like the Montreal Protocol and the Rotterdam Convention, both of which contain significant import/export control provisions. As import and export control is generally the responsibility of economic ministries, these ministries are best able to develop national systems that could accommodate the import/export control requirements of all international chemical instruments. Lack of national coherence is then reflected in international instruments. Likewise, in their inputs to institutions like the World Customs Organization (WCO) 10 economic ministries do not necessarily address the difficulties that could be experienced in implementing the import/ export control provisions of multilateral environmental agreements. Conversely, the international secretariats responsible for multilateral environmental instruments should seek greater coherence between themselves and their more economically and socially focused international counterparts (e.g. the WCO and the World Bank). Taking advantage of synergies It is clear that there are potential synergies among multilateral agreements regarding import/export control. In addition, more streamlined reporting mechanisms are possible. A more coherent approach to reporting would not only allow better informed identification of capacity building needs at the international level, but would also promote national coherence and coordination. The existence of potential synergies among various elements of the Bahia Declaration and GHS implementation is also clear. National implementation strategies should take this into account, and international capacity building initiatives should support national efforts to exploit such synergies. The role of international support for capacity building Support for international capacity building can play a major role in improving national coherence – if this support is provided in a coordinated and holistic way. The mandates of international agencies are generally quite specific, and often they do not take national institutional arrangements into account. Cleaner production centres promote the development of a coherent approach to sound chemical management, which is an integral part of cleaner production in any industry where chemicals are produced or used. UNIDO and UNEP support for National Cleaner Production Centres provides an opportunity to integrate sound management of chemicals and more competitive industrial development. 11 The Globally Harmonized System of Classification and Labelling of Chemicals Implementing the Globally Harmonized System of Classification will be a challenge to developing and developed countries alike. 12 The GHS is a sound starting point for an integrated approach to chemical management. It addresses two key elements of an integrated approach: ◆ classification of a hazard; ◆ communication of the hazard. Implementing this initiative provides an opportunity to develop a platform for sound management of chemicals along the value chain. A strategy for implementing the GHS in South Africa has been developed using a multi-stakeholder process, with funding from the South African government and the UN Institute for Training and Research (UNITAR). 13 Agreement on an implementation strategy has been reached among industry, labour and the responsible regulators under the auspices of South Africa’s National Economic Development and Labour Council. The agreement is now being incorporated in the sectoral agreement among the chemical industry, government and labour on a sectoral strategy to promote the industry’s global competitiveness. Capacity building In preparation for the 2002 World Summit on Sustainable Development, the International Council of Chemical Associations (ICCA) 14 commissioned case studies on capacity building. One of these was undertaken in South Africa. Key stakeholders (government, industry and civil society organizations) with an interest in capacity building and awareness raising in the chemical industry were consulted. The specific capacity building needs and obligations identified by stakeholders in each sector are summarized below. Government ◆ Chemicals management capacity within government needs to be integrated and coordinated. Relevant policies and legislation (e.g. labelling requirements and implementation of UNEP’s APELL 15 Programme) need to be coordinated. ◆ Appropriate mechanisms should be established to raise public awareness of chemical safety through disseminating information that includes industrial emissions, safer alternatives, and the diagnosis and treatment of chemical poisoning. ◆ Customs and excise capacity needs to be enhanced to control transboundary movements of chemicals. ◆ Capacity within government departments needs to be developed to ensure successful implementation of the APELL Programme for responding to emergencies. Industry ◆ Industry’s responsibility is to ensure that information known about the potential risk of chemicals is sufficient to enable users to develop proper risk management strategies. Appropriate and meaningful information (easily understood by all) needs to be disseminated to all stakeholders. ◆ To develop and implement the principles of product stewardship, the activities of all stakeholders in the chain of chemical manufacture and use need to be coordinated. Appropriate training programmes should be developed and implemented to ensure a proper understanding of the principles of product stewardship by all stakeholders in the chain. ◆ Training programmes need to be strengthened and implemented to ensure that workers are effectively trained with respect to understanding chemicals classification and labelling and the information contained in Material Safety Data Sheets. 16 ◆ Industry’s Responsible Care initiative should be strengthened in regard to information dissemination and hazard communication. ◆ The principles of cleaner production and proper waste disposal should be promoted in industry. Civil society Civil society needs the capacity to ensure that it can participate effectively in processes related to chemicals management and can meet its obligations. Specifically, the roles of civil society include: ◆ undertaking independent research and evaluation concerning environmental issues; 20 ◆ UNEP Industry and Environment April – September 2004
Chemicals management ◆ supporting citizens who need assistance in dealing with problems arising from the use of chemicals; ◆ promoting environmental issues for the benefit of all citizens; ◆ disseminating to the general public information that has been made available by the government and the industry sector; ◆ informing industry and government about any issues of concern to the general public. Since the WSSD, South Africa’s Chemical and Allied Industries’ Association (CAIA) 17 has developed a strategy for extending Responsible Care along the value chain in response to some of the priorities identified above. A study is also being conducted to ensure that training activities are developed within the national skills development strategy. This strategy requires the development of sector skills plans for five-year periods. A review of training needs in chemical management is currently being undertaken to ensure that the required elements are included in the chemical sector skills plan for the period 2005-09 being developed. Meeting stakeholder expectations: Responsible Care The international Responsible Care initiative 18 is the global industry’s commitment to continuous improvement in safety, health and environmental performance. It was adopted in South Africa in 1994. Although implementation of this initiative in South Africa has contributed to the improvement of chemical industry performance in this area, the industry has acknowledged that much still remains to be done. The chemical industry recognizes its potential impacts on the environment, particularly on resource utilization. The Responsible Care initiative is implemented in South Africa through seven Management Practice Standards, covering: ◆ Health and Safety; ◆ Storage, Distribution and Transport; ◆ Pollution Prevention and Resource Efficiency; ◆ Community Interaction; ◆ Emergency Response; ◆ Product Stewardship and Process Safety. Implementation of these standards is evaluated every two years. Quantitative Indicators of Performance are collected annually. An annual award is made to the company that has shown the most improvement in respect of these indicators. The initiative provides a sound platform not only for improving compliance with environmental and health and safety legislation, but also for encouraging continuous improvement in performance beyond mere legal compliance. In the absence of comprehensive national legislation in the area of safety, health and the environment, Responsible Care provides a framework within which multinational companies can operate to the same standards as in their country of origin. Poor safety, health and environmental practices cost more in the long term than introducing sound chemical management practices. One of the major challenges facing industry in many developing countries is how to operate plants at an appropriate standard without the support of a national framework. Market access issues increasingly include social and environmental considerations. The ICCA report on the chemical industry’s contribution to sustainable development, prepared for the WSSD under the auspices of UNEP, recognized the need to meet increasing demand from stakeholders for Responsible Care to address stakeholders’ key areas of concern. 19 To address this issue, the South African chemical industry undertook the development of a strategy to extend Responsible Care along the value chain. The strategy was developed by assessing current chemical management practices. Information was collected through a process of interviewing key organizations and/or associations that represent the different stages in a chemical life cycle (i.e. raw material supply, primary chemical manufacture, secondary chemical manufacture, import/export, consumption/end-user, transportation, waste management). The chemical management instruments currently in use include: ◆ safety, health and environmental management; ◆ risk assessment; ◆ supplier-user agreements; ◆ provision of information and guidance for users; ◆ information management; ◆ development of safer products and processes; ◆ incident management; ◆ performance monitoring and review; ◆ import/export procedures; ◆ training and awareness raising; ◆ safe disposal of waste. The results of the investigation confirmed that, to a greater or lesser extent, sound chemical management practices are generally in place for raw material suppliers, primary and secondary chemical manufacturers, and importers and exporters. However, these practices at best extend to downstream entities by only one link in the chemical chain. The needs of consumers (the end-users of chemical products) and service providers (e.g. waste management firms and road hauliers) were identified by interviewing representatives in those areas. This group identified a range of priorities to help them manage chemicals more safely and increase their confidence in the chemical industry. These include: ◆ independent verification of the implementation of the Responsible Care initiative; ◆ a standardized approach to provision of hazard information; ◆ consistent use of chemical terminology; ◆ the need for a life-cycle approach; ◆ uniform procedures for handling of chemicals; ◆ training of users and awareness raising, ◆ improved comprehensibility of hazard information. A strategy has been developed to improve implementation of Responsible Care in South Africa to address these issues. It includes the following elements: ◆ independent verification of implementation of Responsible Care; ◆ targeted marketing campaigns to raise awareness of the benefits of using Responsible Care companies as chemical suppliers and as service providers to the chemical industry; ◆ assistance to smaller companies in implementing Responsible Care; ◆ additional support to companies in implementing Responsible Care; ◆ training of chemical users. Experience with implementting Responsible Care in South Africa has shown that performance in areas like worker safety (measured in terms of incident reports) has improved, as has the frequency of transport incidents. By 2004 all Responsible Care signatory companies had established formal mechanisms to engage with communities near chemical plants. The way forward The three priority areas for sound management of chemicals discussed in this article reveal the complexity of the challenge that faces countries in developing sound strategies for chemicals management in ways that exploit the benefits of chemicals while ensuring that they are managed throughout their life cycle with minimum adverse effects. The South African chemical industry is attempting to meet the challenges of moving towards a more integrated approach to chemical management by addressing the three areas described. Responsible Care is being used as the platform for developing a more integrated approach by incorporating all elements of chemical management along the value chain into implementation of the initiative and independently verifying companies’ performance. Implementation of the GHS will be a departure point for better interaction with consumer groups in regard to disseminating more comprehensible information on chemical hazards. The national strategy being developed for the chemical sector will support the integration of chemical management elements with economic and social objectives. The need to integrate capacity building efforts in the national skills development strategy is recognized. The chemical industry is working with other stakeholders to ensure an integrated approach. Another important need is for international capacity building efforts to be aligned with national strategies for skills development. Development of a Strategic Approach to International Chemicals Management (SAICM) provides a unique opportunity for national, regional and international agencies involved in the management of chemicals to consider ways in which much needed streamlining can become a reality. The catalytic role this initiative can play in promoting a more integrated approach at national level is being explored. In addition, South Africa has recently been admitted to membership of the OECD’s Good Laboratory Practice (GLP) initiative, leading to Mutual Acceptance of Data, which presents a further opportunity for better integration at national level. 20 If the ideal of an integrated approach to chem- UNEP Industry and Environment April – September 2004 ◆ 21
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THE UNEP DIVISION OF TECHNOLOGY, IN
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