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by one. Instead, technology will do the
basic work and highlight the products the
experts need to give their attention to.
These tools are no longer just about
frameworks. They have to be predictive
frameworks, with embedded content, that
enable users to simulate certain things.
We are already seeing companies
leverage these tools more and more in
product stewardship to address
regulations, consumer expectations and
also the announcements companies
themselves make about their products’
carbon footprints.
Manufacturing
Probably the biggest product risk during
this stage is ensuring the safety of workers.
It is critical to ensure they have access to
the right data at the right time, particularly
SDSs but also information and on the
chemicals they are using and instructions
on the use of chemicals in the workplace.
The right engineering controls and
personal protection equipment (PPE) to
keep workers safe are also essential.
Chemical risk assessment tools are very
helpful here. Often, additional information
about raw materials is useful in
manufacturing, specifically about the
formula and the concentrations of
chemicals in it.
The first thing when it comes to
reducing risk in manufacturing is the wellestablished
risk assessment formula that
Risk = Hazard x Exposure. Risk
assessment should take into account both
the inherent hazards in a substance and
the amount and frequency of a given
worker’s exposure.
There are guidelines about the
exposure side of the equation but there
are also a lot of things that cannot easily
be controlled: how and where the
chemical is applied, the method of
application and so forth. Eliminating
hazards at the front end is probably the
easiest way to control risks.
This is where regulatory screening lists
come in handy, such as for substances of
very high concern (SVHCs) under REACH,
carcinogenic, mutagenic and toxic to
reproduction (CMR) substances and
California Proposition 65 chemicals. In
this way, you can ensure such chemicals
never get into your facility or at least
minimise the amount.
Distribution
Technology can also support companies
in being proactive in terms of compliance
with regulations at the distribution stage of
a chemical’s life. The two most important
documents in this respect are the SDS and
the label. It is also critical to ensure the
customer has both by whatever means you
send it to them.
Keep in mind also that other
information and other notifications may
need to be communicated to local
authorities or downstream users. These
include European Chemicals Agency
(ECHA) notification and Proposition 65
notifications and labelling. Individual
consumers are experiencing the latter
when they do their grocery shopping, so
awareness will only grow. It may be
necessary to send additional information
to Poison Centres in the EU.
Distribution is also an area where you
need to keep the end in mind. Package
sizes and the mode of transport are also
elements of product sustainability. This is
where you need to make sure that your
choices are not just the most efficient but
also have the lowest impact on the
environment.
Environmental risk is making its way
into the business process at this stage, too.
From a product stewardship or a
transparency perspective, more and more
companies are starting to put carbon
footprint information or other supplemental
information on the products they distribute.
Particularly in Europe, it is increasingly
common to see this kind of information on
product websites – and it often covers the
whole product life cycle. So, in
distribution, it becomes necessary to
calculate such things as fuel and electricity
consumption. Companies ahead of the
curve are using workflows to optimise their
process for lower impacts to support
carbon footprint statements.
Use
Although one might think that products
cease to be part of the manufacturer’s
responsibility once they have reached the
customer, this is not the case. In reality,
they remain on the hook for information
they have put out regarding their products.
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