Customer Health and Safety
Our role in ensuring that health, safety and environmental protection are integral to the whole product lifecycle is through Product Stewardship. Our responsibility spans every stage of our operations; from the sourcing of raw materials in an increasingly fragile environment, to environmentally sensitive manufacturing processes and offering advice on the safe, efficient use and disposal of the finished products that contain our ingredients.
Product Stewardship is part of the International Council of Chemical Associations’ Responsible Care® initiative, which we fully support. It is a shared responsibility between chemical producers, suppliers and customers and requires close, sustained dialogue and working relationships between all stakeholders. This means sharing information up and down the value chain to identify and manage risks, and to ensure that chemicals are used and managed safely and responsibly throughout their lifecycle.
We have identified five core elements to Product Stewardship:
1. Raw material sourcing: To ensure that the raw materials we use to make our products are responsibly sourced
2. Supply chain engagement: To ensure that our suppliers act as ethically as we do in regard to areas such as human rights and the environment, whilst supporting our customers on their product traceability programmes
3. Product design: To deliver the most innovative and sustainable ingredients to our customers
4. Quality assurance: To contribute to and proactively seek higher quality standards across product and operational aspects of our Business
5. Responsible distribution: To ensure that goods are delivered reliably, safely, consistently and on time, supported by our status as an Authorised Economic Operator (AEO), a standard providing assurance on security
Product Stewardship does not sit with the responsibility of one team, but instead is an integral element of every part of our product value chain, from cradle (R&D) to grave (disposal). All business functions within Croda are engaged with Product Stewardship and in 2012 a RACI Chart was developed to map the responsibilities of product stewardship. This details which function has a ‘Responsible’, ‘Accountable’, ‘Consulted’ or ‘Informed’ role within the product stewardship chain. It is an integral part of each Business function, all of which report to the Group Executive Committee, and consequently the Board, on a regular basis.
Through successful Product Stewardship, we and our partners can meet the increasing demand for safe and sustainable chemical use to protect human health and the environment.
Product Service and Labelling, Marketing Communications, Customer Privacy and Compliance
As a business to business organisation we strive to maintain an awareness and conformance, where appropriate, to national and local laws and voluntary codes or guidelines, from entities such as the Food and Drug Administration (FDA), the European Food Safety Authority (EFSA), the European Commission, Cosmetics Europe, United States Environmental Protection Agency and Personal Care Products Council (formerly CTFA).
We ensure that all of the products that we supply are accompanied by a material safety data sheet (MSDS), which details any health and safety issues with the product as well as environmental effects such as persistence and bioaccumulation. This goes beyond our legal requirements, where MSDSs are only required in specific circumstances and all of our products are labelled according to regulatory requirement in the regions in which they are sold.
We have formal procedures in place to capture any non-compliance with regulations or codes relating to the health and safety of our products, labelling, marketing communications and customer privacy. We have a formal complaints procedure and all of our customers have at least one sales contact within the business. It is our intention to enhance this procedure to further embed it within our business to capture any issues or areas of potential risk.
All our products are assessed for their health, environmental and safety impacts from the product development stage, with advice available to the end customers so that any identified risks are known and can be controlled.
Product concepts come from a variety of sources, including customer interaction, market awareness and emerging product trends. In all these areas our research teams liaise with our product safety and regulatory affairs department from the beginning of new product development to ensure that products are assessed for their health, safety and environmental effects. Additional screening tests and modelling may be carried out depending on the expected end use of the product to enable safety assessments to be completed by our customers.
Our scientists ensure that our products meet as many of the 12 Principles of Green Chemistry as is reasonably practical. A number of these relate to reducing harm to human health during development, manufacture and end use. Wherever practically possible we stick to the principles relating to health and safety from the 12 Principles of Green Chemistry:
These principles are embedded in our new product development processes.
We have controls in place within our Enterprise Resource Planning System to ensure that a safety data sheet is produced for all products prior to manufacture to ensure that they are assessed against the criteria of the United Nations Globally Harmonized System of Classification and Labelling of Chemicals (GHS) so that all health, safety and environmental aspects can be considered for manufacturing, production, storage, distribution, supply and end product use.
During the manufacture of our products the risks to health and safety are managed by the Safety Health and Environment (SHE) department at each of our manufacturing sites. There are policies and procedures in place to ensure process safety and quality control. Our 19 manufacturing sites around the world are certified to the ISO 14001 standard and accredited to the OHSAS 18001 standard for safety management. We are committed to Responsible Care®, which underlines our commitment to SHE improvement. There are procedures and systems in place to ensure the safe storage of hazardous chemicals; this information is passed on to our customers where applicable. We have systems and procedures in place to deal with any transportation issue or emergency situation that may affect surrounding communities.
We ensure that all the products that we supply are accompanied by a material safety data sheet (MSDS), which details any health and safety issues with the product as well as environmental effects such as persistence and bioaccumulation. This goes beyond our legal requirements, where MSDSs are only required in specific circumstances and all our products are labelled according to regulatory requirement in the regions in which they are sold.
Our sales and marketing teams work closely with our research teams and regulatory department to ensure that any details that are provided to customers relating to health and safety are accurate and reflect the information that is sent out with the products that we supply.
There is a move within chemical control legislation to require that risk assessments are completed to ensure that any hazard associated with a product is adequately controlled from the manufacture of the product through to its end use and associated service life. In many jurisdictions’ chemicals requiring assessment are prioritised on the basis of known hazards. Within Europe this requirement is captured under the REACh regulation (Regulation (EC) No 1907/2006). The EU chemicals regulation, REACh, concerning the Registration, Evaluation, Authorisation and restriction of Chemicals, came into force on 1 June 2007 creating a single regulatory system for dealing with chemical substances.
To conform to REACh regulations, each producer and importer of chemicals in volumes of one tonne or more per year must register them with the European Chemicals Agency (ECHA) and submit information on their properties, uses and safe ways of handling them. This registration obligation has been phased in with three key deadlines according to volume and hazard. Phase 1 was completed in December 2010 for volumes >1000 tonnes per annum (tpa) and certain high hazardous substances. Phase 2 had a deadline of 1 June 2013 for volumes ≥ 100 tpa. The phase 3 deadline is 1 June 2018 for all substances ≥ 1 tpa
We have played a lead role in REACh registrations since the beginning, with our Product Safety and Regulatory Affairs team working to coordinate the generation and gathering of information to support registrations for products across the whole portfolio. As of 2017, registrations have been submitted in all three phases with the final phase being the most important in terms of the range of products captured.
In general, our products comprise a small percentage of the final product, so it is a challenge for us to manage the health and safety implications in finished products. By providing good quality information and data to our customers we allow them to make informed decisions and accurately determine if there could be any potential issues for end consumers.
Our control over the ultimate disposal of the goods that contain our products is also limited, however we control what we can by ensuring that our products are as environmentally friendly as possible by examining biodegradability and persistence, and have minimal potential impact to human health in terms of toxicity and bioaccumulation.
Further information on our product stewardship can be found throughout the Sustainability Report.
We have formal procedures in place to capture any non-compliance with regulations or codes relating to the health and safety of our products. We have a formal complaints procedure and all of our customers have at least one sales contact within the business. It is our intention to enhance this procedure to further embed it within our business to capture any issues or areas of potential risk.
During the year we were not aware of any incidents relating to non-compliance in this area.
Due to strict legislation within the chemical industry in the area of product labelling, we ensure that we conform to all regulations in the regions in which we operate and we aim to exceed these standards where possible.
We require information related to health and safety and the labelling of products from all of our suppliers, this information is collected at each manufacturing site and is passed on to our product safety and regulatory affairs department. In general, this information is received in the form of a material safety data sheet (MSDS), but where we require more information for regulatory purposes we work with our suppliers to gain the data that we require.
The procedure for the MSDS means that 100% of our products are required to be labelled with information relating to content, safe use and disposal of the product. The sourcing of the components of the product is not given on the MSDS but it stored in our procurement system SAP if the information is required by the customer.
All products are assessed against the relevant national and international chemical labelling legislation to ensure that the health, safety and environmental hazards of the product are assessed and the appropriate hazard and precautionary statements are used. Information about safe handling and use of our products is passed on to our customers in MSDSs and product safety information statements.
We work closely with our customers to ensure that our chemicals are sufficiently assessed for safe use in end consumer products and ensure that any environmental or health impacts of our products are identified. As our products are generally used as a small percentage of end consumer goods, the information that we provide to our customers is vital for them to accurately determine any potentially harmful effects of their formulations for consumers or the environment.
Any potentially hazardous effects of our products to human health or the environment are identified and clearly shown on our product labels and in the MSDSs that we provide to our customers. These include, amongst others, biodegradation, persistence, bioaccumulation and toxicity.
Further information about the health and safety of our products can be found in the Customer Health and Safety Indicator GRI 416-1.
We continue to monitor and adapt to any changes in national and international chemical labelling legislation across the world and it is Croda policy that all products are supplied with a Material Safety Data Sheet (MSDS), which is a detailed informational document that describes the physical and chemical properties of the product.
During the year we were aware of 23 isolated incidents where labelling did not meet local requirements of voluntary codes. None of these isolated incidents resulted in fines, penalties or warnings. We rectified these issues as soon as they were identified and at no time was health and safety compromised.
We will continue to comply with regulations and voluntary codes relating to marketing communication and promotion and will continue to monitor and improve our processes and procedures in this area.
During the year we were not aware of any incidents relating to non-compliance in this area.
During the year there were no significant fines for non-compliance against the Group.
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