Читать книгу Patty's Industrial Hygiene, Program Management and Specialty Areas of Practice - Группа авторов - Страница 125
3.3 Fundamental Program Elements for Product Stewardship
ОглавлениеIn reviewing the abovementioned definitions, common elements and principles do become clear. PS is about the SHE aspects of products throughout their life cycle. PS requires that a company manage its products from their inception to disposal, commonly referred to as “cradle to grave.” When implemented it is designed to make health, safety, and environmental protection an integral part of the design, manufacture, distribution, use, recycle, and disposal of products. As such PS has clear links to occupational hygiene and overall pollution prevention efforts.
So what are the stages or specific activities in the PS concept? They include the following:
Product Design and Development. This stage includes bench‐top research as well as the markets or uses anticipated for the product being developed. Depending on the region of the activity it can include some elements of compliance. More often it requires sound professional judgment on the possible hazards of a product, developing appropriate handling procedures based on the known and suspected hazards of the products being developed and the development of appropriate hazard communication documents when full information on the product may not be available. This stage also requires consideration of possible use conditions as they relate to potential use and exposure scenarios.
Purchasing. Obtaining services and products, feed stocks, and processing supplies should be considered as an important part of the life cycle of a product and included in PS practices. These practices should include assuring you are doing business with companies with good SHE practices, assuring your service providers are doing business in an environmentally sound matter and obtaining appropriate information on the products you buy.
Manufacturing. This is the stage most familiar to occupational hygienists. It is the activity involved in the product manufacturing and handling facilities. This is the stage of PS with many regulatory requirements that benefit PS. It is the stage where classic industrial hygiene is practiced.
Distribution. Once a product leaves the manufacturing location, the direct ability to control the risks of the product begin to decline. This phase in the product life cycle includes transit, in transit storage, packaging/repackaging, and other distribution activities. There are regulatory requirements for transportation of specific defined hazardous materials that define container specifications and some elements of hazard communication, but for complete PS all products need to be considered commensurate with the hazard and risk.
Marketing. This includes the applications and uses that the company intentionally sells to, marketing literature on applications, and the representations made by the marketing personnel. It is important that marketing literature does not conflict with technical literature and is appropriately descriptive of the hazards and handling needs for a product without becoming a substitute for an material safety data sheet (MSDS).
Use Conditions. Being aware of customer uses and commensurate with the hazard of the product, the customers' ability to handle product safely is key to accomplishing good PS goals. Having a formal system in place to respond to customer questions and indications of misuse are also integral to a good risk management program. Considering the feedback you have received in the ongoing development of your hazard communication or handling documents for the customer can result in improved risk management and communication.