SABIC’s Product Stewardship program is built upon a mission of creating a strong product stewardship culture leading to excellence in product risk management. We believe this adds business value across the global supply chain through safe, compliant, and sustainable solutions.
PRODUCT STEWARDSHIP KNOWLEDGE AND COMPETENCY
A key aspect of the Responsible Care® Product Safety code is to foster a company environment wherein personnel who have accountabilities for managing product safety have the proper understanding to successfully implement their related actions. To promote this understanding, SABIC created the Product Stewardship Experience, an advanced adult learning curriculum. In 2021, the program was modified from a three-day in-class environment to virtual delivery over six WebEx sessions due to the challenges presented by the global COVID-19 pandemic.
Since 2016, SABIC has been internally reporting and managing product stewardship incidents (PST). PST incidents are related to violations of global chemical control regulations (e.g. EU REACH), concerns of SABIC products during their life cycle, reputation, and finance, and/or failure to meet internal Product Stewardship standards and requirements. Similar to EHSS incidents, the Product Stewardship incidents are classified from class A (most severe) to class E (least severe, including near misses). In 2021, SABIC did not have any reported class A Product Stewardship incidents related to non-compliance with chemical control regulations resulting in a fine, penalty or warning.
Over the past year, SABIC introduced two systems that allow easy access and reporting of PST incidents for all global SABIC functions. The enhanced capability to capture product safety and regulatory compliance-related incidents throughout the value chain and the product lifecycle will further strengthen SABIC’s product stewardship culture and performance.
MANUFACTURING CENTER OF EXCELLENCE
In 2021, we continued to expand our Product Stewardship Center of Excellence (CoE) concept within the Manufacturing and EHSS community in two new regions: Europe and North America. The CoE platform allows for timely discussions and engagement on important topics such as Safer Chemistry, REACH readiness, Responsible Care® product safety codes, practices of hazard identification, communication, risk management, and mitigation.
BUSINESS FOCAL POINT
Several years ago, Product Stewardship initiated a program to strengthen our engagement within each business unit by assigning a specific expert as a Business Focal Point (BFP). This program allows for regular two-way dialogue between each business unit and Product Stewardship on topics such as growth opportunities, challenges, and regulatory compliance, toxicology, or product safety requirements.
RESPONDING TO CUSTOMER INQUIRIES
A major goal of Product Stewardship is to continuously improve efficiency in delivering high quality SABIC compliance documents to our customers in a timely fashion.
In 2021, we developed and rolled out regulatory data sheets (RDS) on several polymer and chemical products for direct access to our customers through our corporate website. With RDS and several standard letters now available on the SABIC website for Engineering Thermoplastics (ETP), Specialties, Polyolefin, Agri-Nutrients, and certain Chemical products, the total number of cases handled through our Customer Declaration Portal process decreased from 12,559 in 2020 to 12,001 in 2021. The total number of documents handled from these cases decreased by about 12% (27,737 vs. 24,354 in 2020 and 2021, respectively), thereby indicating immediate efficiency benefits in our first year of the RDS roll out.
PUBLISHING SAFETY DATA SHEETS
To meet our hazard communication requirements, we published approximately 140,000 Safety Data Sheets (SDS) across all business groups in 2021. This is a significant increase compared to 2020 due to new products from our JV partners and our R&D activities, changing regulatory classifications, periodic reviews, and expanding sales into new countries.
PRODUCT SAFETY: RISK DISCOVERY MANAGEMENT PROCESS
In 2021, the EHSS and Product Stewardship risk assessment became a compulsory deliverable. These projects are being assessed and prioritized by EHSS and Product Stewardship. This mandatory touchpoint will enhance the interaction between technology organizations and the EHSS and Product Stewardship functions, ensuring risks are identified at an early stage of innovation, and that products and processes developed meet the highest SABIC process/product safety standards.
RESPONSIBLE CARE® PRODUCT SAFETY CODE MANAGEMENT PRACTICES
As part of our Responsible Care® commitment, SABIC continued to drive the safe use of products in its entire value chain beyond regulatory requirements.
Over the past few years, we worked on enhancing the Product Safety management practice related to value chain communication, cooperation, and outreach as defined by the American Chemistry Council. We identified 10 priority chemicals and established a proactive value chain engagement with customers that goes well beyond responding to customer inquiries. In previous years, this approach was piloted with a few selected chemicals in some regions.
In 2021, we were able to implement the program on a global scale. All customers of the defined priority chemicals have been approached with information packages, in which we encourage them to engage in proactive two-way communication.
In 2021, Product Stewardship worked with SABIC business, manufacturing, and procurement stakeholders and took a leading role in submitting chemical substance registrations and notifications to comply with the UK REACH regulation as part of the UK’s chemicals regulatory regime that was installed after Brexit. The team met all relevant deadlines to allow SABIC to continue to manufacture, import, sell, or distribute its products in the UK.
Product Stewardship rolled out an EHSS Regulatory Calendar tool in 2021. This tool secures timely triggers for our global product stewardship professionals to initiate scheduled regulatory tasks.
Product Stewardship requirements for the business continue to be embedded within SABIC EHSS standards, with primary focus areas including raw material qualification, product qualification, and Good Manufacturing Practices (GMP). In 2021, we focused on the global implementation of revised requirements and engaged in several audits of manufacturing sites. These were mostly carried out virtually due to COVID-19 restrictions limiting on-site participation.
Our lab at SABIC Technology Center, Bengaluru, India, is equipped with state-of-the-art instrumentation facilities. The lab is ISO 17025 accredited and is periodically audited by a government statutory agency (National Accreditation Board for Testing and Calibration).
In 2021, the lab was equipped with an additional Gas Chromatography Mass Spectrometry (GC-MS) instrument with headspace to meet the growing product safety testing demands of our business. The food contact compliance testing performed has enabled the addition of a new high flow grade (QR) of polypropylene to our portfolio. Environmental impact assessment studies paved the way for the notification/registration of various ULTEM™ polymers with various global regulators.
SABIC is fully aware of the global need to foster the sound management of chemicals, ensuring that chemicals are produced and used in ways that minimize significant adverse impacts on the environment and human health. Therefore, we are committed to reduce or avoid the use of Chemicals of Concern (CoC) beyond current global regulations and market needs. This commitment led to the launch of the Safer Chemistry program in 2020, which is now one of the four main strategic sustainability initiatives within SABIC.
SABIC is striving to implement Safer Chemistry principles during all stages of the product lifecycle. We will be engaging with our suppliers and customers to create a transition to raw materials and products with a lower hazard footprint, where viable.
We will initially focus on substituting CoC where suitable alternatives are available or can be readily developed. This will lead to a gradual reduction or phase-out of CoC in our products, based on product stewardship and business criteria. Where suitable alternatives are not feasible in the short term, we will consider other mechanisms to minimize the impact of our products on human health and the environment, by reinforcing current Responsible Care® Risk Management and communication practices.
In 2021, we reviewed our entire chemical inventory of over 1800 substances as part of our portfolio analysis and about 350 were identified that meet our CoC definition. This represents about 20% of the global SABIC substance portfolio. These 350 substances were ranked with a newly developed SABIC prioritization tool, using publicly available data and harmonized classifications. 25 substances with high scores from the tool were packaged and delivered to the business units and the Technology & Innovation organization. From there, they will undergo a comprehensive business assessment, identify a short list of viable opportunities, and initiate technology programs to phase out or reduce the number of CoCs in our portfolio.
The Product Stewardship team continued its strong presence in chemical trade associations around the globe, to ensure that regulatory developments are identified early, and our industry response is well coordinated. SABIC also remains a trusted party in the global roll-out of the Globally Harmonized System of classification and labeling of chemicals (GHS) and Responsible Care®,especially in the Middle East region through our leadership within the GPCA. Through key product stewardship and toxicology-related conferences, expertise on complex regulations is shared, thereby building a stronger global product stewardship community.
Product Stewardship recognizes the importance of ESG disclosure and reporting. Our efforts are aimed at increasing the overall transparency of our programs and public confidence related to hazard and risk assessment metrics and managing chemicals of concern.