Environmental health and safety (EHS) regulatory compliance programs and strategies, by definition, traditionally have been aimed at preventing violations, fostering safety and reducing risk.
New goals for EHS regulatory compliance programs include minimizing the adverse life cycle impacts of products and operations and require integrating EHS practices and expertise into core business processes. At the same time, a more complex regulatory imperative has evolved as global regulations become more complicated and dynamic. This new imperative creates an important shift in focus from violation prevention to embedded compliance.
Conformance has evolved to become less about reactionary tactics and more a part of a strategic business plan that includes supply chain actions with measurable success factors rather than vague attempts to preserve and promote brand image. This is evidenced by recent studies in which respondents identified competitive advantage/corporate brand as a less substantial driver for participation in enterprise sustainability as compliance with regulatory requirements.
How can you help your company integrate EHS principals and intelligence into core business processes to actually procure, use and create safer, greener products, thus supporting your organization in its efforts to competitively operate in an ever-changing regulatory and business climate? Is it possible to leverage existing EHS data and tools to reduce toxic footprint and develop better products?
ANALYZING THE SUPPLY CHAIN
As the volume and complexity of regulations increases worldwide, companies are forced to consider the safety, regulatory obligations, components and footprint of raw materials and non-process chemicals to which their employees, communities and customers are exposed. When combined with an intense focus on concepts such as greening the supply chain and running cleaner operations, companies are examining every phase of the product lifecycle to ensure they efficiently and cost-effectively are managing the full spectrum of their hazard communication and product stewardship requirements. In addition, it can be extremely important to ensure that suppliers are socially and environmentally responsible operators and if not, to discontinue relationships or apply pressure to encourage them to change.
This challenge is complicated by the fact that each phase of the product lifecycle has unique compliance and product stewardship requirements. From the cradle of research and development to the grave of waste disposal or cradle of recycling, a complete and detailed analysis of the compliance and sustainability requirements associated with each stage must be performed. In doing so, companies develop a better understanding of the types of data that are required to fuel compliance performance and product stewardship initiatives throughout the product lifecycle.
Consider the following issues during your supply chain analysis:
Research and development (R&D) and formulation laboratories perhaps can make the biggest impact in making progress toward green product creation. It is far less expensive to design a low-impact product than to manage or retrofit a high-impact one. Scientists and engineers working in R&D must track global regulatory requirements as well as available toxicological and eco-toxicological data. Data aggregation tools can be used to facilitate or enhance the flow of information.
The challenge, however, is to identify solutions that provide more than just a compilation of regulatory text. Value comes from data and information solutions that distill regulatory information into normalized content that seamlessly can be integrated into platforms and tools. Generating and maintaining such data in-house can be time consuming and highly inefficient.
Formulators should be encouraged to use environmental profiles to evaluate products prior to market release. The types of data maintained by EHS departments that are of greatest importance include:
- What components may be banned or regulated in certain markets?
- What means of transportation will be allowed for given formulations?
- What components trigger more intense regulatory scrutiny and obligation due to high-profile, negative attributes such as carcinogenicity? Can less impactful components be substituted?
- Will the components of these formulations require more elaborate safe handling measures than other formulatory options?
- Can the final product have a smaller toxicological carbon or water footprint by substituting one component for another?