We all need to help reduce the impacts of manufactured products on our environment. When a producer, brand owner, importer, retailer, or consumer accepts the responsibility for reducing a product's environmental impact, we call this PS.
PS helps us transition from a linear to a circular economy.
http://www.mfe.govt.nz/waste/product-stewardship/about-product-stewardship
Private advocacy groups and institutions have also defined PS based on their activities and emphasis. One example is given below:
3.2.7.1 Product Stewardship Institute
The Product Stewardship Institute – a consumer advocacy group – defines product stewardship as “the act of minimizing the health, safety, environmental, and social impacts of a product and its packaging throughout all life cycle stages, while also maximizing economic benefits.”
3.2.7.2 Product Stewardship Society
This group was formed in 2013 with a focus on professional development through education, publications, and networking. Their definition is:
Responsibly managing the health, safety, and environmental aspects of products throughout their life cycle and across the value chain in order to prevent or minimize negative impacts and maximize value.
In reviewing the abovementioned examples, common elements become quite clear. Whether defined as a set of principles, a program, a tool, a policy, or a process the focus is a product. The risk management of products throughout their life cycle requires an integrated organizational approach, and close relationships with customers and others involved in the supply chain to make PS happen. Drivers for these activities are regulatory, moral, and ethical in nature.
3.3 Fundamental Program Elements for Product Stewardship
In reviewing the abovementioned definitions, common elements and principles do become clear. PS is about the SHE aspects of products throughout their life cycle. PS requires that a company manage its products from their inception to disposal, commonly referred to as “cradle to grave.” When implemented it is designed to make health, safety, and environmental protection an integral part of the design, manufacture, distribution, use, recycle, and disposal of products. As such PS has clear links to occupational hygiene and overall pollution prevention efforts.
So what are the stages or specific activities in the PS concept? They include the following:
Product Design and Development. This stage includes bench‐top research as well as the markets or uses anticipated for the product being developed. Depending on the region of the activity it can include some elements of compliance. More often it requires sound professional judgment on the possible hazards of a product, developing appropriate handling procedures based on the known and suspected hazards of the products being developed and the development of appropriate hazard communication documents when full information on the product may not be available. This stage also requires consideration of possible use conditions as they relate to potential use and exposure scenarios.
Purchasing. Obtaining services and products, feed stocks, and processing supplies should be considered as an important part of the life cycle of a product and included in PS practices. These practices should include assuring you are doing business with companies with good SHE practices, assuring your service providers are doing business in an environmentally sound matter and obtaining appropriate information on the products you buy.
Manufacturing. This is the stage most familiar to occupational hygienists. It is the activity involved in the product manufacturing and handling facilities. This is the stage of PS with many regulatory requirements that benefit PS. It is the stage where classic industrial hygiene is practiced.
Distribution. Once a product leaves the manufacturing location, the direct ability to control the risks of the product begin to decline. This phase in the product life cycle includes transit, in transit storage, packaging/repackaging, and other distribution activities. There are regulatory requirements for transportation of specific defined hazardous materials that define container specifications and some elements of hazard communication, but for complete PS all products need to be considered commensurate with the hazard and risk.
Marketing. This includes the applications and uses that the company intentionally sells to, marketing literature on applications, and the representations made by the marketing personnel. It is important that marketing literature does not conflict with technical literature and is appropriately descriptive of the hazards and handling needs for a product without becoming a substitute for an material safety data sheet (MSDS).
Use Conditions. Being aware of customer uses and commensurate with the hazard of the product, the customers' ability to handle product safely is key to accomplishing good PS goals. Having a formal system in place to respond to customer questions and indications of misuse are also integral to a good risk management program. Considering the feedback you have received in the ongoing development of your hazard communication or handling documents for the customer can result in improved risk management and communication.
3.4 Interdisciplinary/Organizational Issues
Based on the aforementioned elements, it is clear that implementing PS takes a cross‐functional approach and affects many departments or functions in a company. This requires significant effort in a company to maintain an understanding of each function's role and to assure each function is performing the activities needed. Furthermore, the PS function itself can be comprised of several distinct disciplines including Toxicology, Occupational Medicine, Industrial Hygiene, and Regulatory Affairs. If specialists in these fields are not within the PS function of an organization, the different forms of expertise will need to be available, or those doing PS will need to develop a working proficiency in the mentioned areas. This is a challenge Occupational Hygienists are familiar with. It is quite normal for a hygienist to bring together engineering, management, hourly, and union personnel to solve a problem or implement a solution. These skills and experience translate well to working in a PS program.
3.5 Regulatory Foundation for Product Stewardship
There are no specific regulatory requirements for chemical producers or other manufacturers to have PS programs. However, if one can agree to describe the elements of PS as discussed in this chapter, then there are clear regulatory requirements that support individual elements of the concept.
At this time, in the United States Federal statutory authority to control the environmental impacts of products downstream from the manufacturing operations as contrasted to manufacturing locations and operations is limited. SHE regulation has traditionally focused on regulating manufacturing facilities. Transportation regulations apply to the portion of the products in commerce that meet specific Department of Transportation (DOT), or equivalent transportation agencies, hazard classifications. However, some select elements of PS are becoming increasingly evident in regulations, or requirements, involving the life cycle aspects of products. These range in scope from individual chemicals to manufactured articles. There is a new emphasis or focus on human and environmental protection through the regulation of products. As an example the revised Toxic Substances Control Act (TSCA), now known as the Lautenberg Chemical Safety Act (LCSA) is resulting in a broader scope of authority for the US Environmental Protection Act to regulate the commercialization and use of existing
