SearchPRODUCT STEWARDSHIP
Since the launch of our Corporate Product Stewardship program in 2010, SABIC has been committed to evolving our company culture and internal capabilities to rise to challenges and become a high-performing organization in the eyes of both our internal and external stakeholders. This year, our efforts revolved around key themes of cultural improvement, safer & sustainable products, and our product compliance programs.
STRONG CULTURE
PRODUCT STEWARDSHIP KNOWLEDGE AND COMPETENCY
2022 marked the inaugural year for The Product Stewardship Experience in which we provided regular scheduled virtual training sessions to a broad internal audience. The six-module course was conducted across nine global training sessions, overseen by the SABIC product-stewardship staff and taught to over 180 employees in eight functional areas including legal, sales, supply chain, manufacturing, and R&D.
The training course was designed for SABIC personnel to understand the fundamentals of product stewardship and how they could connect these concepts to their roles to contribute to SABIC’s overall program success. It became a part of the formal SABIC learning and development program, and employees were given the opportunity to sign up online to attend future training sessions. The positive response from the employees boosted the program’s credibility and the feedback received from the facilitation team and the trainees will be taken into consideration when updating the course. We have also used the content to provide focused training to external stakeholders, including a group of scientists from the Saudi National Authority responsible for implementing the Chemical Weapons Convention mandates.
MANUFACTURING CENTER OF EXCELLENCE
In our ongoing effort to enhance the effectiveness of our Product Stewardship Center of Excellence program, we have strengthened our connections with our manufacturing and EHSS partners worldwide. A dedicated Manufacturing Focal Point (MFP) facilitates the flow of information between all parties on a range of critical topics, including product and raw material, human health and environmental hazard communication, Safer Chemistry initiatives, Occupational Exposure Limits (OELs), REACH readiness, and Responsible Care® Product Safety Code management practices. This year, we expanded the MFP role eligibility from Product Steward Specialists to include toxicologists, allowing for even greater technical dialogue on OELs and identification and control of high hazards.
SAFE PRODUCTS
RESPONDING TO CUSTOMER INQUIRIES
In our ongoing commitment to providing exceptional service, SABIC Product Stewardship endeavors to furnish our customers with top-notch product regulatory compliance documentation in a timely manner, ensuring that their needs are met with urgency and diligence.
This year, we continued to look for even greater efficiency with our Customer Declaration Portal (CDP) and use of Regulatory Data Sheets (RDS); this combines a number of product regulatory topics into a single document made available on the SABIC website. The RDS covers important information about our products, such as status related to Restriction of Hazardous Substances (RoHS), Phthalate Directives, REACH Substances of Very High Concern (SVHC), REACH Registration, Volatile Organic Compounds (VOC), Persistent Organic Pollutants (POPs), Conflict Minerals, Ozone Depleting Substances (ODS) and GHG Substances, Transmissible Spongiform Encephalopathies/Bovine Spongiform Encephalopathy/Genetically Modified Organisms (TSE/BSE/GMO), Polycyclic Aromatic Hydrocarbons (PAH), and many more.
In the first year that the RDS was made available on the company website, customers downloaded them 13,511 times. We saw the total number of cases for which we provide customized responses reduced for a second year in a row. In 2022, we responded to 10,411 specific customer inquiries (cases), in comparison to 12,001 inquiries in 2021. The total number of documents handled from these cases fell from 24,354 in 2021 to 21,201 in 2022, representing a 15% reduction in cases handled and documents prepared by our team over the year. SABIC looks forward to increasing efficiency in the coming years as new RDS are added for additional products while we increase the number of regulatory topics per RDS.
As a key aspect of our efforts this year, we developed a new tool to track Restricted Substance List (RSL) from many of our customers. The Product Stewardship team built this new database with a search engine to house an inventory of Brand Owners RSL from over 80 customers and it holds over 20,000 rows of data on chemicals under public scrutiny. The RSL tool will serve as a proactive data-mining tool to better understand our customers’ concerns while supporting our Safer Chemistry program and other sustainability initiatives.
LUIZA GOUVÊA SANTOS
Product Engineer, South America Region Brazil, SABIC Petrochemicals
“Participating in the 2022 Product Stewardship Experience was a great opportunity for me to engage with other colleagues from SABIC and learn more about the initiatives Product Stewardship is implementing around the globe to assure product compliance, sustainable solutions, and safe use of chemicals. The case studies explored were my favorite part of the course. We discussed in multi-functional groups solutions to proposed and real-world situations using the knowledge we developed during the course. As a Product Engineer for the South America sites, I am applying what I’ve learned from the course into my daily work, which is to make sure raw materials and grades are introduced in South America sites in line with regulatory requirements and with the proper hazard communication. I also plan to help continuously improve the Good Manufacturing Practices (GMP) at sites in my region. I encourage my colleagues at SABIC to take part in this Product Stewardship Experience to explore how your role supports SABIC in the path towards safer chemistry and a more sustainable future.”
SCOTT C. LEE
Manager Raw Materials, North America Region (USA), SABIC Specialty Chemicals
“Product safety and sustainability are important to me both professionally and personally. The Product Stewardship Experience connected SABICs efforts on these fronts to SABIC’s businesses, functions and to the roles of my supply chain team that is responsible for managing raw materials for the Specialties business. The training content showed Product Stewardship’s engagement with topics such as the European Union REACH regulations that highly impact SABIC’s raw materials and supply chain across our manufacturing sites. SABIC’s raw material supply chain has also seen an increase in requests for sustainable materials and solutions, which was a key topic during the Product Stewardship Experience. Thanks to the Product Stewardship team for a job well done in delivering a meaningful and engaging learning experience.”
PUBLISHING SAFETY DATA SHEETS
In 2022, SABIC launched the new One SDS Portal― an Integrated Product Compliance System Initiative. This multi-year project provides great new features, such as the readily accessible SDS Portal that allows a single location for employees and external customers to search and view SDS for SABIC products. Meanwhile, internal SABIC users can now also retrieve an SDS via the MySABIC Fiori Mobile app. In the event of an emergency, it offers greater access to product safety data and hazard information, and has improved hazard communication delivery for stakeholders. The SDS portal also improves the effectiveness of our compliance management systems and processes, gaining new analytic and functional capabilities and providing centralized access to formulation data.
This year, we published approximately 130,000 SDS across all business groups; this is a slight shortfall overall when compared to the approximately 140,000 SDS published in 2021 as a result of the ongoing OneSDS project implementation as well as a reduced number of product SDS up for cyclic review. The large increase in published SDS for the Polyolefin business unit was due to a full transition of all SDS to the SAP-based OneSDS platform.
These special milestones were achieved thanks to the combined efforts of the Product Stewardship and IT project teams, and SAP consultants, enhancing SABIC’s compliance position and ability to operate more efficiently. We look forward to leveraging these advancements as part of the transformation in SABIC and creating value with our partners.
Total SDS Published (All Regions and Languages)
Total SDS Published (All Regions and Languages)
ASSESSING RESEARCH & DEVELOPMENT PROJECTS USING SABIC’S ACCOLADE TOOL
Since 2018, the EHSS and Product Stewardship assessments have become a key deliverable in the stage gated process, helping portfolio managers to spot regulatory compliance gaps, hazards, and opportunities and to react by making faster and better-informed decisions to maximize profitability in line with the highest SABIC process and safety standards. Accolade, SABIC’s Project Portfolio Management Tool, empowers T&I teams to collaborate in creating and updating the information that drives the management of SABIC innovation strategies, portfolios, and development activities. As a result of our efforts in the previous years to enhance Product Stewardship assessments and visual outputs, nearly 100% of projects launched in 2022 underwent a PST assessment of hazard potential, regulatory compliance, and overall risk to human health and the environment.
REGULATORY COMPLIANCE
FOOD CONTACT APPLICATIONS
In 2022, Product Stewardship worked closely with product managers from different SABIC business units to evaluate SABIC’s portfolio applicable for food-contact applications. This meticulous analysis led to identifying substances that were not listed in the latest positive-list draft for Japan’s food-contact materials. Consequently, Product Stewardship successfully advocated for the inclusion of these substances in the final positive list to the Japanese regulatory body. This enables SABIC to supply a portfolio of food-contact materials in Japan, where a positive-list-based food contact regulatory framework will be fully enforced as of June 1, 2025.
K-REACH
SABIC met its goals for regulatory compliance with the inclusion of the basic risk-assessment result in SABIC SDS for South Korea, as mandated by the K-REACH Template 26 requirements.
DUE DILIGENCE
The product stewardship team is firmly embedded in the due-diligence process of evaluating new technologies and mergers and acquisitions. The team played a key role in obtaining licenses to sell in different regions for various new products that were added to the SABIC portfolio from the Aramco assets and GCGV asset. Additionally, the product stewardship team has evaluated various technology-venture projects to secure product safety compliance that further drive SABIC’s sustainability agenda.
ANALYTICAL TESTING
Our global analytical science lab at STC Bengaluru is a center of excellence (CoE) facility for Product Stewardship testing. This facility is equipped with advanced instrumentation capabilities that are needed for regulatory compliance data and product-safety evaluation. Partnering with global product stewards over the past two decades has enabled SABIC to secure compliance from renowned global regulatory agencies (for example, US Food and Drug Agency, US Environmental Protection Agency, European Food Safety Authority, Chinese Food Safety Authority, and the Japanese Ministry of Economy, Trade and Industry). This lab is accredited with ISO 17025-2017 quality-management systems and has successfully completed its external process audit cycles in 2022 from NABL (a government of India statutory agency) to deliver reliable experimental data and advice for its stakeholders working on sustainable growth programs.
In 2022, we developed and validated 13 new trace-level analytical methods adopting internationally accepted standards. To help enable market expansion with new product portfolios, six polymers were assessed for environmental impact required for registration/notification across various regional global regulatory agencies. Nine chemical substances, spread across various business units (BUs), were characterized in detail to meet the EU-REACH compliance obligations. The lab performed risk-based product-safety evaluations for dozens of different work requests; in the area of food contact, pharma, healthcare, Global Harmonized System (GHS)/SDS, raw material qualification, substance of concern testing; and drinking-water compliance, which enabled the global Product Stewardship function in securing compliance for the business.
SUSTAINABLE SOLUTIONS
SAFER CHEMISTRY
The Safer Chemistry program is an integral pillar in the overall SABIC Sustainability strategy. SABIC has a deep understanding of the global imperative for responsible chemical management, and is dedicated to promoting practices that minimize negative impacts on both the environment and human health through the production and use of chemicals. The objective is to define suitable actions that reduce the hazard footprint of the products sold in the marketplace. Each potential CoC undergoes several reviews by Product Stewardship, Technology, Business, and Procurement personnel, and if viable opportunities exist, action is taken and documented. Even if action is not taken at the time, the documentation will be reviewed on a cyclic basis or if new information becomes available to warrant high priority review.
In 2022, SABIC scrutinized the first 25 prioritized CoCs currently used in production and found opportunities to take varied action according to the following groupings:
– Substitution of a CoC with a substance with a lower GHS hazard footprint.
– Concentration reduction of a CoC as used in product formulations.
– Banning a CoC for future use in product design.
– Eliminate use of COC.
– Stop production and repurpose assets (for CoCs that SABIC produces as an end-product).
– No action(s), continue with current use.
The outcome of our assessment of the first 25 islisted in the table below:
| Proposed actions to be taken on CoCs |
|
# (From first 25 reviewed CoCs) |
|---|---|---|
| Substitute CoC with lower hazard profile substance | 3 | |
| Stop CoC production and close or repurpose manufacturing assets | 1 | |
| Eliminate raw material CoC use | 3 | |
| Lower product concentration of CoC (typically 10-100%) | 0 | |
| Ban use of CoC in new product design | 4 | |
| Total | 11 |
In total, there were 11 CoCs from the first batch of 25 CoCs for which proposed actions were identified. Another outcome of our assessment of batch 1 was discovering that about one-third of the CoCs were present as low-level unintentional impurities in purchased raw materials. As a result, we implemented a current threshold limit of 10 ppm for unintentional impurities; this is two orders of magnitude lower than major regulatory thresholds of 1,000 ppm. If the unintentional impurity in the substance (not the final product) is above 10 ppm, then it falls under the scrutiny of the Safer Chemistry program. This allows for a more conservative approach since many raw materials would be further diluted to the sub ppm level in the final product. Meanwhile, another 25 prioritized CoCs (batch 2) were released and are undergoing technology reviews as the program progresses into 2023.
The Safer Chemistry program team has defined four potential business metrics that are currently under review for final approval. The purpose of these metrics is to set formal targets regarding CoCs and enhance the transparency of our actions to the outside world. These metrics focus on identifying opportunities to take action; committing to take action; and making quantitative measurements on the number of products and sales revenue associated with CoC actions. We aim to have these metrics approved and in place in the first half of 2023.
RESPONSIBLE CARE® PRODUCT SAFETY CODE MANAGEMENT PRACTICE
SABIC participated in the ACC's development of the newest edition of the Responsible Care® product safety code. Refinements to the new code were made to increase understanding of the implementation requirements and, more appropriately, measure the Company’s performance in meeting its obligations to the 11 management principles. The new code was ratified and will begin its roll-out in 2023.
SABIC Product Stewardship also held several workshops during the regional summits, focusing on the Responsible Care® Product Safety Management Practice, reviewing the current state of implementation, and identifying the areas in which SABIC has excelled and where there are opportunities for continuous improvement. These include leveraging the new OneSDS platform and updating regulatory content; improving overall transparency in our risk characterization process; strengthening our partnerships with EHSS via the Manufacturing Center of Excellence concept; increasing our Safer Chemistry awareness within business and T&I communities; and expanding our overall value chain stakeholder network.
The team also started the five-year cyclic review for the first 10 of 50 high-priority, comprehensive risk characterizations for SABIC key products. The results identified no changes over the last five years in either human health or environment hazards, exposures or risks. The team aims to complete a review of a new batch of 10 products every year as well as risk prioritization for new products that entered the SABIC portfolio in the past year. The same will apply to all high priority products.
PRODUCT REGULATORY ADVOCACY
EUROPEAN REGIONAL ADVOCACY: THE CHEMICALS STRATEGY FOR SUSTAINABILITY
Launched in December 2019 by the European Commission, the European Green Deal is a growth strategy with an overarching aim to turn Europe into a toxic-free and climate neutral environment by 2050. The European Commission presented the Chemicals Strategy for Sustainability (CSS) on October 14, 2020, providing a detailed strategy for implementing this vision, and it lays out more than 50 actions that will have a direct impact on the industry and users of chemicals products.
SABIC supports the Green Deal’s goal to achieve climate neutrality by 2050 and the approach to make the economy and society in Europe more sustainable. To this effect, our innovative solutions and processes such as our TRUCIRCLE ™ portfolio and SABIC Safer Chemistry program are well-placed to actively contribute to achieving the ambitious goals.
ARABIAN GULF REGIONAL ADVOCACY
SABIC plays a significant role in implementing the Globally Harmonized System of Classification and Labelling of Chemicals projects in the Gulf Corporation Council (GCC―Saudi Arabia, UAE, Qatar, Kuwait, Bahrain, and Oman) and Africa.
The GHS implementation project is sponsored by the Responsible Care® Committee at GPCA. SABIC, as the Chair of the Product Stewardship SubCommittee at GPCA, had the opportunity to engage with the Supreme Council of the GCC to explain why the United Nations’ endeavor for all countries to adopt the GHS as regulation holds benefits for the government, industry, and society. As SABIC continuously engages with the Chemicals Management Committee at the GCC, the Company will lead a one-day workshop focusing on the requirements to transform the existing GCC Standardization Organization (GSO) and GHS standards into a formal regulation.
SABIC also plays a significant role in the United Nations Environment (UNEP) GHS Africa Project by chairing the Industry Working Group that consists of members from key players in the chemicals industry, trade associations, and other factions. GHS Africa Project is a four-year program led by UNEP and financed by the European Commission and ICCA, targeting Kenya, Ghana, Nigeria, and Ivory Coast, with a completion date in December 2026.
In 2022, SABIC worked with the steering committee to set the foundations of the project, and hired a consulting firm to perform a gap analysis and an industry consultant to focus on the role of industry and its contribution to the project. A key milestone was achieved in making a public announcement about this project after the steering committee meeting in UNEP’S headquarters in Nairobi, Kenya, alongside government officials and regulators from the four targeted countries.
ESG DISCLOSURES RELATED TO PRODUCT STEWARDSHIP
In our 2021 Sustainability Report, SABIC Product Stewardship initiated a discussion on ESG matters. We highlighted our efforts to enhance the transparency of our programs and our objective to bolster public trust concerning hazard and risk assessment metrics, the management of CoCs, and the disclosure of any product stewardship-related compliance incidents that led to fines, penalties, or warnings.
We have discussed our core Product Stewardship pillars, such as responding to customer inquiries, hazard communication, regulatory compliance, Responsible Care® Product Safety Code Management Practice, EHSS/Product Stewardship reviews of our technology & innovation programs, and our Safer Chemistry sustainability initiative. The goal is to continue our Product Stewardship mission of a strong Product Stewardship culture leading to excellence in product risk management, adding business value across the global value chain through safe, compliant, and sustainable solutions.
In 2022, our ESG Product Stewardship-related disclosures are as follows:
– Percentage of products that underwent a hazard assessment = 100%
- Note: All products and raw materials are evaluated for their hazard potential using the GHS for Classification and Labelling of Substances. All hazards are disclosed in our Product SDS when present at or above the regulatory threshold of 0.1%.
– Number of REACH SVHC that may be present in SABIC products above the regulatory threshold of 0.1% = 3
- Note: All SVHC that may be present above the regulatory threshold of 0.1% are disclosed on our Product SDS. Specific details on the SVHC compounds and the specific grades impacted can be found on our RDS for ETP, Specialties, polyolefins, and several chemical products.
– Number of chemicals used that are listed by California Prop65 = 8
- Note: All chemicals (bisphenol A, tetrabromobisphenol A, styrene, carbon black, antimony trioxide, dichloromethane, acrylonitrile, and 1,3-butadiene) that are listed by California Prop65 are disclosed on our Product SDS where applicable. (https://www. sabic.com/en/sustainability/productstewardship/product-regulatory-documents).
– Detailed strategy and procedures for managing hazardous chemicals:
- SABIC Product Stewardship adhered to the Responsible Care® Product Safety Code Management Practices as our foundation for identifying and managing hazardous chemicals. All hazard information is disclosed on our Product SDS and comprehensive risk characterizations are done for all high priority products.
- SABIC solidified the Safer Chemistry program as a sustainability pillar for sound chemical management.
- SABIC’s Project Portfolio Management Tool, Accolade, enables Product Stewardship to engage with the company’s Technology & Innovation function to help identify potential new hazards and risks early in project development.
– Commitment to developing alternatives to reduce or avoid (phase-out) the use of CoCs.
- 11 substances with proposed actions to be taken (following evaluation of first 25 potential CoC candidates)
– Number of potential CoCs to be evaluated = ~350
- Approximately 350 out of 1,800 raw materials, monomers, process chemicals, additives, impurities, and products.
- <1% of SABIC products contain a CoC above the regulatory threshold of 0.1% and are typically bound to the polymer matrix and therefore not bioavailable.
- Number of incidents (non-compliance with regulations resulting in fines, penalties, warnings, or voluntary codes) = 0