PRODUCT STEWARDSHIP

Code of Practice

GCWellonJune 2010

PRODUCT STEWARDSHIP

Definition

Product Stewardship is the shared responsibility for understanding, managing and communicating the impacts to human health and the environment through the life cycle of chemical products. This life cycle involves the development, production, use, distribution and end-of-life management of products.

PRODUCT STEWARDSHIP CODE

PRODUCT STEWARDSHIP CODE

Purpose & Scope

make health, safety and environmental protection an integral part of designing, manufacturing, marketing, distributing, using recycling and disposing of our products

PRODUCT STEWARDSHIP CODE

Purpose & Scope

shared responsibility; everyone involved with the product – address society’s interests in a healthy environment and products that can be used safely

employers responsible for providing a safe workplace people who use and handle products must follow safe and

environmentally sound practices

PRODUCT STEWARDSHIP CODE

Purpose & Scope

“each company must exercise independent judgment and discretion to successfully apply the code to its products, customers and business”

PRODUCT STEWARDSHIP CODE

Relationship to Responsible Care© Guiding Principles

6 out of 10 RC Guiding Principles are directly related to PS

PRODUCT STEWARDSHIP CODE

Management Practices

3 general categories:o Management Leadership and Commitmento Information & Characterizationo Risk Management

Total of 12 Management Practices outlined in theProduct Stewardship Code

PRODUCT STEWARDSHIP CODE

Management Practices:Management Leadership & Commitment

1. Leadership:

written policy; active participation; communication

PRODUCT STEWARDSHIP CODE

Management Practices:Management Leadership & Commitment

2. Accountability:

establish goals; measure performance

PRODUCT STEWARDSHIP CODE

Management Practices:Management Leadership & Commitment

3. Resources:

commit necessary resources

PRODUCT STEWARDSHIP CODE

Management Practices:Information & Characterization

4. HSE Information:

establish & maintain information on HSE hazards; new & existing products

PRODUCT STEWARDSHIP CODE

Management Practices:Information & Characterization

5. Product Risk Characterization:

characterize product risk using HSE information

PRODUCT STEWARDSHIP CODE

Management Practices:Risk Management

6. Risk Management System:

system to identify, document & implement HSE risk-management actions

PRODUCT STEWARDSHIP CODE

Management Practices:Risk Management

7. Product / Process Design & Improvement:

consider HSE impacts during design, development and improvement

PRODUCT STEWARDSHIP CODE

Management Practices:Risk Management

8. Employee Education & Product Use Feedback:

train employees – handling, recycling, use, disposal encourage employee feedback – uses, misuses, adverse

effects

PRODUCT STEWARDSHIP CODE

Management Practices:Risk Management

9. Contract Manufacturers:

select / work with contract manufacturers who use appropriate HSE practices

provide information & guidance – handling, recycling, use, disposal

review performance

PRODUCT STEWARDSHIP CODE

Management Practices:Risk Management

10. Suppliers:

require suppliers to provide HSE information and guidance on their products

consider HSE practices when making procurement decisions

PRODUCT STEWARDSHIP CODE

Management Practices:Risk Management

11. Distributors:

provide HSE information to distributors select / work with / review distributors – use, handling,

recycling, disposal; transmit information to downstream users

PRODUCT STEWARDSHIP CODE

Management Practices:Risk Management

11. Distributors: (continued)

work to improve improper practices if necessary improvements are not made, consider

termination of business relationship

PRODUCT STEWARDSHIP CODE

Management Practices:Risk Management

12. Customers, Other Direct Product Receivers:

provide HSE information foster proper use, handling, recycling, disposal and

transmittal of HSE information to downstream users

PRODUCT STEWARDSHIP CODE

Management Practices:Risk Management

12. Customers, Other Direct Product Receivers : (continued)

work to improve improper practices if necessary improvements are not made, consider

termination of product sale

PRODUCT STEWARDSHIP CODE