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2 Moving Beyond Compliance: Can Industry Get Ahead of the Curve?
Pages 26-43

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From page 26...
... USING MANAGEMENT SYSTEMS TO IMPROVE PERFORMANCE IN THE CHEMICAL INDUSTRY Today the chemical industry is increasingly sensitive and responsive to the growing number of public concerns regarding the use of chemical products, said Terry F Yosie, formerly of the American Chemistry Council (ACC)
From page 27...
... Yosie noted that all chemical companies who are members of theACC -- ACC members represent about 90 percent of the manufacturing capacity of chemicals in the United States -- are required, as an obligation of membership, to participate in Responsible Care®. The Responsible Care® is tailored specifically scope of Responsible Care® is tailored to the chemical industry and includes specifically to the chemical industry such aspects as: continuous performance and includes such aspects as continu- improvement, enhanced security, ous environmental, health, and safety increased product stewardship, improved performance improvement, enhanced performance across the value chain, security, increased product steward- communication with stakeholders, ship, improved performance across integration with sustainable development, the value chain, communication with and improved chemical industry reputation.
From page 28...
... Extending Responsible Care® through the business process globally is important because, when the industry operates in a developing country, industry standards and practices are frequently well beyond existing national or local standards. With the aid of Responsible Care®, developing countries will be able to build capacity and institutions that will increase the level of skills within their population and help develop regulatory processes.
From page 29...
... Also, most of transportation infrastructure is designed for rush hour period; thus when people telework, rush hour period is shaved, and the demand for infrastructure is reduced. Challenges of Telework Despite the advantages that telework offers to employees, there are many challenges.
From page 30...
... Xerox found that product conversion developed for remanufacturing, reuse, and parts commonality right up front is a better approach. This process leads to significant waste reduction, extends the life cycle of products, and brings out new features and qualities in a product set, said Azar (Figure 2-1)
From page 31...
... This process leads to significant waste reduction, extends the life cycle of products, and brings out new features and qualities in a product set. SOURCE: Azar, unpublished.
From page 32...
... Sustainability indexes measure the performance of chemical industry cohorts that manage large sums of investment capital on the order of hundreds of billions of dollars a year. Green Chemistry Green chemistry was created by Paul Anastas from the EPA and John Warner from the University of Massachusetts as a set of principles that reduces or eliminates the generation of hazardous substances in the design, manufacture, and application of chemical products (Anastas and Warner, 1998)
From page 33...
... Thus adopting green chemistry at all phases of research and development could have a tremendous impact on the economic bottom line and the environmental bottom line for the industry, said Cue. The pharmaceutical industry is exploring the possibilities to make existing commercial manufacturing processes more environment-friendly.
From page 34...
... · The industry needs to integrate chemical synthesis and chemical engineering concepts. Cue pointed out that many companies in the pharmaceutical industry are using green chemistry principles at commercial scale, but possibly hundreds of millions of kilograms of waste could still be prevented by broadly adopting green chemistry.
From page 35...
... In 1934, Dow Chemical Company's leadership recognized the importance of safety evaluation of products' intermediates and wastes. Dow's contribution to the field of toxicology has come a long way since that time when Being a $450 billion a year enterprise, the the first toxicology studies were con- chemical business in the United States is ducted in modified 55-gallon drums, a key element of the country's economy said Bond.
From page 36...
... A company must notify the EPA prior to bringing any new chemical to market and must provide the EPA with the new chemical's identity, properties, available hazard data, anticipated production volume, by-products, use, environmental release, disposal practices, and human exposure limits. EPA scientists then determine if the chemical poses an unacceptable risk.
From page 37...
... Chemical Industry's Product Stewardship and Trends of Public Expectations Dow and many leading companies have publicly committed to operate according to local standards or company standards, whichever are stricter, around the globe (Figure 2-2)
From page 38...
... The figure illustrates the general approach to product safety taken at Dow. SOURCE: The Dow Chemical Company, 2004.
From page 39...
... The intent is to take industry product stewardship to the next level of performance, noted Bond. The policy lays out basic obligations of members to conduct product risk characterizations, to engage partners in the value chain, to understand uses and exposure, and to inform about risk characterizations.
From page 40...
... Program The realities of chemical safety and regulation are daunting, said Balbus. The first reality is that under the Toxic Substances Control Act, EPA must be able to demonstrate that an existing chemical poses a potential risk in order to require that its producer perform any toxicity testing -- a true Catch 22, since making the risk finding is exceedingly difficult in the absence of toxicity data.
From page 41...
... It was strictly a hazard data generation and public dissemination exercise. Today, about 1,900 of the original 2,800 chemicals have been sponsored, said Balbus; however, there are still nearly 300 chemicals that remain unsponsored, and some 700 have been shifted out of the US HPV program and into the OECD SIDS program, which is slower-paced (Environmental Defense, 2004)
From page 42...
... One complication of the VCCEP pilot program has been that all of the chemicals evaluated thus far have had data from all three hazard tiers available and considered in the program. While the tiers for hazard data are clearly defined, the different tiers for exposure data are less clear; the result is some confusion as to what truly constitutes a Tier 1 evaluation under the VCCEP.
From page 43...
... Of 23 chemicals identified for this pilot back in 1999, the first chemical was evaluated in January of 2003, and the EPA did not finalize their review of that first chemical until late in 2005. In conclusion, Balbus said that Environmental Defense feels strongly that well-designed voluntary programs can have an important role in speeding the pace of data generation, but they are not able to completely replace regulatory frameworks, and they demand dedication of government resources to ensure proper oversight and quality of the output.


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