Product Stewardship

Product Stewardship

Product stewardship is designed to make health, safety and environmental protection an integral part of the design, manufacture, marketing, distribution and use of our products. Effective product stewardship covers all stages of our products' life cycle. Key Product Stewardship Systems Risk review procedure for new products, new products uses and new business arrangements. The company utilizes a formal risk review procedure for products being considered for first time production and sale, new product applications, new sales jurisdictions or certain new business arrangements such as resale products and contract manufacturing. To initiate this review, research and development, process engineering, and sales groups provide specific risk linked information to the Risk Management Department prior to manufacture or sale of a new product. Information typically provided includes (but is not limited to) anticipated manufacturing processes, product composition, known product end uses, anticipated sales jurisdictions, raw material safety data sheets, packaging, transportation and storage issues. A review of this information is then undertaken by Health and Safety, Product Risk (Toxicology, Regulatory, etc.), and Environmental specialists. This system is used to identify the overall risk potential of Vanderbilt products during manufacture and use. Possible follow-up actions from this review may include (but are not limited to): process modifications, product application restrictions, changes in product formulation, additional risk characterization (testing), product abandonment, risk communication, and regulatory compliance. Product Stewardship External Risk reviews. The company utilizes an external risk review procedure to help ensure health and safety systems are adequate during product distribution, contract manufacturing, and warehousing. Formal review forms are analyzed for acceptability by Risk Management staff (Health and Safety, Product Risk, and Environmental). Typically, when problem areas are identified, remedies acceptable to all involved are adopted. In the unusual circumstance remedies can not be agreed upon, R.T. Vanderbilt Holding Company, Inc. reserves the right to refuse an arrangement until and unless the product can be handled in a safe manner. Product Risk prioritization. R.T. Vanderbilt Holding Company, Inc. ranks products that have the highest risk potential in order to reduce or eliminate potential risks to the public, environment, and customers. Through risk priority setting, the company is better able to direct resources, in the most advantageous manner, to products that have the highest potential risk. Risk prioritization encompasses inherent risks (toxicity, corrosivity, flammability, etc.), amounts shipped, transportation modes and product end use. In addition, a formal product incident reporting system is used to track incident frequency and severity. This information is used as part of product risk prioritization. Material Safety Data sheet (MSDS) system. R.T. Vanderbilt Holding Company, Inc. maintains a computerized MSDS system capable of producing MSDS's in multiple languages and formats. The company utilizes a regulatory database which is used for MSDS production and regulatory compliance. R.T. Vanderbilt Holding Company, Inc. uses this regulatory compliance function to allow product sales to countries where the product has regulatory clearance. The company utilizes a formal MSDS request and revision procedure to ensure that all data elements are in place before MSDS generation. In addition, resale product MSDS's are reviewed before being entered into our MSDS system. MSDS's are reviewed as appropriate, distributed to customers and updated when new regulations, testing results, or other new information becomes available. Product Risk testing program. Risk assessment of products begins before product introduction and continues throughout the life cycle of the product. The company is actively engaged and participates in certain testing initiatives with the US EPA and worldwide competent authorities. One initiative involves the High Production Volume (HPV) testing program. This program requires the assembly of robust toxicity testing dossiers on high volume products and involves testing partnerships with other companies through the American Chemistry Council and similar organizations. The company also requires prioritized tests on chemicals to address additional regulatory needs, provide meaningful MSDS information, or to generally provide better product risk information. REACH Program. REACH is the new European Regulation on Registration, Evaluation, Authorization and restriction of Chemicals. It entered into force on 1st June 2007. Among other obligations, REACH will require the registration of chemical substances, followed by an evaluation process. In this process, the substances on their own, in mixtures or in finished goods are evaluated and Industry is responsible for assessing and managing the risks posed by chemicals and providing appropriate safety information to their users to protect the human health and environment. The registration process will stretch over the next 11 years and will be preceded by a pre-registration phase (June 1, 2008 through December 1, 2008). The REACH Regulation provides that a producer or an importer in the European Union (EU) of any chemical substance, either as such or present in a preparation, at more than 1 metric ton per year will have to register such substances within strict time-frames. Formal Product Stewardship Committee. A corporate Product Stewardship committee meets as part of our commitment to continuous improvement. Members of senior management, research and development, sales, transportation, legal, and risk management are invited to participate in this process. The committee looks at product life cycle issues with the goal of reducing the potential risks to people and the environment through better understanding of toxicity, handling, transportation, and other product linked issues.

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