Nice blog by Michael Kirschner summarizes steps to take to deal with all the challenges that are threatening products containing chemicals “of concern.” He advises manufacturers to take the following steps:
- Collect full material disclosure from your suppliers. Simple declarations and certificates are useless. If your suppliers insist on continuing to provide this level of information in light of the changing marketplace, make sure you understand why they’re doing it and whether you can move to a different supplier that will give you what you need.
- From this information, produce a list of the chemicals that are used in your product.
- Prioritize the chemicals in terms of toxicity, potential for exposure, amount, and potential for future regulation.
- Understand why those chemicals are used.
- Understand what it would take to replace these chemicals in your product.
- Assess any marketing or competitive value this could have for your company.
- Make a plan for what to replace, how, and why. [I would argue you should also consider whether it is worth it to try to defend the use of the chemical. He seems to be in the "just bail" club.]
- Get it funded and move ahead.
You need explicit and fairly sophisticated systems (including people) to keep up with it all unless you just sell one or two simple component products. Will the exponential growth in public chemophobia and complicated regulatory schemes (e.g., REACH) result in product manufacture being done by only the really big companies that have the resources to cope? The best a little guy can do is try to find or hook up with big guys in his supply chain and hope they will help him.
EHS Strategies, Inc. can help you get your product stewardship program in shape.
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- Product Stewardship