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4.1 Product Stewardship

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Product Stewardship generally means responsibly managing the health, safety, and environmental aspects of products throughout their life cycle and across the value chain in order to prevent or minimize negative impacts and maximize value. Many industrial hygienists through their traditional work have become increasingly involved in this affiliated area of professional practice.

Product Stewardship is a significant regulatory, health, and environmental protection activity increasingly required for all commercial entities that create, market, transport, import, or dispose of commercial products of all types. Many of the major chemical manufacturing, processing, and distribution companies are committed to performance programs through their various trade associations. All of these programs define elements and expectations for Product Stewardship. The number and complexity of Product Stewardship related regulations continue to grow globally with the implementation of Registration, Evaluation, Authorization, and Restriction of Chemicals (REACH), Globally Harmonized System of Classification and Labeling of Chemicals (GHS), expanded Environmental Protection Agency (EPA) Chemical Data Reporting requirements and a growing list of participating countries implementing chemical control regulations impacting global commerce. The typical qualifications and capabilities of a professional industrial hygienist compare well with the competency requirements for the practice of Product Stewardship.

In general, there are no specific or consensus definitions of Product Stewardship. In fact, some use the term product safety to describe the same set of activities and principles. However, an analysis of publicly available documents can give a clear sense of the common elements and lead one to an understanding of the principals involved. The Product Stewardship Society uses the following definition:

Responsibly managing the health, safety and environmental aspects of raw materials, intermediate and consumer products throughout their life cycled across the value chaining order to prevent and minimize negative impacts and maximize value.

Product Stewardship has certain basic activities which are rooted in regulatory requirements:

 hazard assessment

 hazard communication

 product exposure assessments

 risk management

 product development.

Whether defined as a set of principles, a program, a tool, a policy, or a process, the focus is a safe product of acceptable risk. The risk management of products throughout their life cycle requires an integrated organizational approach. This means a close relationships with customers and others involved in the supply chain are required to make Product Stewardship principles happen in the real world. Drivers for these activities are regulatory, moral, and ethical in nature.

It is clear that implementing Product Stewardship takes a cross‐functional approach and affects many departments or functions in a company. This requires significant effort in a company to maintain an understanding of each function's role and to assure each function is performing the activities needed. Furthermore, the Product Stewardship function itself can be comprised of several distinct disciplines including Toxicology, Occupational Medicine, Industrial Hygiene, and Regulatory Affairs. If specialists in these fields are not within the Product Stewardship function of an organization, the different forms of expertise will need to be available, or those doing Product Stewardship will need to develop a working proficiency in the mentioned areas. This is a challenge which with Occupational Hygienists are familiar. It is quite normal for a hygienist to bring together engineering, management, hourly, and union personnel to solve a problem or implement a solution. These skills and experience translate well to working in a Product Stewardship program.

IH professionals practice health protection and regulatory compliance in a framework which is different from, yet closely related to, Product Stewardship. Many of the technical and experiential competencies required for Product Stewardship are commonly possessed by Occupational Hygienists.

Patty's Industrial Hygiene, Hazard Recognition

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