Clearing up product stewardship issues

02 May 2005 00:01  [Source: ICB]

Dear Sir,

The UK Chemical Industries Association is delighted to see that ECN is committing so much space this year to recent developments in product stewardship. This Association has been at the forefront of these changes and I should therefore like to take this chance to underline some of the key arguments advanced so ably by Chris Eacott in ECN (ECN 21-27 March).

First, product stewardship issues should definitely not be looked at within the confines of the term ‘chemical industry’, as they involve the whole supply chain. Product stewardship requires the active and constructive participation of representatives of all stages of that chain to develop and implement real actions to address the actual and/or perceived concerns which our stakeholders are voicing.

As public concern has largely shifted from ‘process’ to ‘product’ (in itself something of a tribute to the effectiveness of Responsible Care), so this inclusive factor has become much more significant.

Indeed, of all the elements of Responsible Care, product stewardship has been the most challenging to implement with signatories.

Unlike those elements of Responsible Care that are clearly identified with manufacturing at site level, the business – and decision-making – activities associated with product stewardship are spread throughout the organisation’s sites, often on a global basis. This global factor proved a key driver in the recent international and European review of Responsible Care.

Second, I would argue that caution needs to be exercised in linking product stewardship to Reach. The former concept is far broader than the latter; it is more than just meeting legislative and regulatory requirements.

A fundamental feature and guiding principle of Responsible Care is going beyond legal compliance and working towards best practice. This, equally, applies to product stewardship.

Product stewardship is also about seeking more sustainable products and process, but not just hazard identification, exposure assessment and risk assessments. It is about being proactively engaging with the users along the supply chain and end-users, to listen to, understand and address their potential concerns so that they do not become issues that must be addressed through increasing levels of regulation.

Rather, product stewardship aims to promote effective and credible voluntary mechanisms that help meet society’s needs and expectations – and underpin, too, a sustainable chemical industry.

Colin Chambers,head of group operations and assurance, Chemical Industries Association

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