1. Product Stewardship at Dow Corning
Applying Chemical Industry Voluntary
Initiatives to go Beyond Compliance
EDC Construction Workshop, Cardiff
29th November, 2011
2. Dow Corning is …..
A global leader in silicones and high purity
silicon
More than 7,000 products/services
Approx 25,000 customers
Approx 11,500 employees
Strong and healthy financially: $6 billion
sales 2010
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3. The silicone technology pioneer…
A joint venture of
The Dow Chemical
Company and
Corning Incorporated
Organised to explore
the potential of the
silicon atom in 1943
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6. Presentation Summary
• Setting a strategic direction for Product
Stewardship
• Product Stewardship network & interfaces
• Product Stewardship strategic drivers
• Product Stewardship Management System
• Life-cycle approach to Product Stewardship
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7. Responsible Care ®
Responsible Care® is the chemical industry's global initiative for continuous
improvement in environmental, health, safety and security (EHSS) performance.
The program aims to drive results in the following key areas:
• Community awareness and emergency response: Assure emergency preparedness and foster a
commitment to openness and community dialogue.
• Security: Further enhance security of facilities, communities and products.
• Distribution: Reduce the risk of harm posed by the distribution of chemicals to the general public; to
carrier, distributor, contractor and chemical industry employees; and to the environment.
• Employee health and safety: Protect and promote the health and safety of people working at or
visiting company work sites.
• Pollution prevention: Achieve ongoing reductions in the amount of contaminants and pollutants
released to the air, water, and land from company facilities.
• Process safety: prevent fires, explosions and accidental chemical releases
• Product stewardship: Make health, safety and environmental protection an integral part in
designing, manufacturing, marketing, distributing, using, recycling and disposing of our
products
Employees throughout the world serve as stewards of Responsible Care® and are critical in supporting
Dow Corning’s commitment to the initiative.
8. Corporate Priority:
Engage entire organization in stewardship
Dow Corning is uniquely positioned to apply
our expertise in the science of silicon-based
technology to benefit everyone, everywhere.
We need to understand stewardship in terms
of people, planet, profit, regulatory
compliance, ethics, safety, security, and
more.
– As good stewards of this company, we have a personal
responsibility to ensure sustainable operations as we
grow through innovation.
– Ensure our culture of stewardship perpetuates as we
grow to safeguard our company and our world .
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9. Product Stewardship
• Product Stewardship is the shared responsibility for
understanding, managing and communicating the
impacts to human health and the environmental
through the life cycle of chemical products.
• This life cycle involves the development, production,
use, distribution and end-of-life management of
products.
• Thus, companies and their partners are better
enabled to develop and promote safe and sustainable
use of their products.
10. What is the role of Product Stewards
Dow Corning Internal Business
Processes
External Regulatory Key translator of External
Environment opportunities and threats into
business actions
Rapidly
Changing
Environment
11. Product Stewardship at Dow Corning
Prod Safety &Reg
Operational EHS
Compliance
• Raw material & int.
• Safety data sheets
• Process safety
• Health/Env. opinion
• IH & Env. regulations
• Registration
• Storage & transportation
• Regulatory compliance
Business Units
• Product development
• Product claims
• Product use
• Customer service
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12. Product Stewardship at Dow Corning
PS&RC
Operational EHS • Safety data sheets
Product Stewardship
• Raw material & int. • Health/Env. opinion
• Process safety• Voluntary initiativeRegistration
•
• Responsible Care®
• IH & Env. regulations
• Beyond • Regulatory compliance
• Storage & transportationcompliance
• Risk management
• External perception
• Global Product Strategy
Business Units
• Product development
• Product claims
• Product use
• Customer service
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14. Product Stewardship Management System
Policy/Leadership
• High level strategy
• Vision
• Key policies
PLAN
ACT DO
CHECK
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15. Product Stewardship Management System
Policy/Leadership
PLAN
• Stewardship goals
• Issue identification
• Aspects &ImpactsACT DO
registers (RC14001)
CHECK
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16. Product Stewardship Aspects & Impacts Matrix
5 Red: This represents risks
that Dow Corning does not
want to accept as part of
normal product life cycle.
These risks are generally not
4 acceptable and the risk must
CONSEQUENCE/SEVERITY
be reduced. These risks may
Potential for: be accepted for limited
- Negative health/environmental Impact duration with appropriate
justification and authorization
- Litigation by an Executive Committee.
3
- Fines or imprisonment
- Bans on commerce
- Adverse public perception
Orange: These activities
2 are only acceptable if all of
the following are met:
- Risk control measures at
least meet industry standard
practices
1 - Additional control measures
have been sought, evaluated
and implemented where
available.
1 2 3 4 5
Level of Business at risk White: These risks are
generally acceptable. In the
OR Probability for a defect to occur spirit of continuous
OR Potential for exposure improvement, residual risks
should be reviewed for
further risk reduction. All in-
EXPOSURE/PROBABILITY
place mitigations must
remain.
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17. Product Stewardship Aspects & Impacts Matrix
5 Red: This represents risks
that Dow Corning does not
want to accept as part of
normal product life cycle.
These risks are generally not
• Business Unit A&I Registers focused
4 acceptable and the risk must
CONSEQUENCE/SEVERITY
be reduced. These risks may
Potential for: be accepted for limited
- Litigation
3
on business-specific risks
- Negative health/environmental Impact duration with appropriate
justification and authorization
by an Executive Committee.
- Fines or imprisonment
- Bans on commerce • Corporate A&I Register for horizontal
- Adverse public perception
2
product stewardship processes Orange: These activities
are only acceptable if all of
• Early risk recognition and mitigation the following are met:
- Risk control measures at
least meet industry standard
1
• Basis for auditing and improvement of practices
- Additional control measures
have been sought, evaluated
product stewardship processes and implemented where
available.
1 2 3 4 5
Level of Business at risk White: These risks are
generally acceptable. In the
OR Probability for a defect to occur spirit of continuous
OR Potential for exposure improvement, residual risks
should be reviewed for
further risk reduction. All in-
EXPOSURE/PROBABILITY
place mitigations must
remain.
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18. Product Stewardship Management System
Policy/Leadership
• Standards & processes
PLAN
• Stewardship tools
• Training curriculum
ACT DO
CHECK
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19. Product Stewardship Management System
Policy/Leadership
PLAN• Stewardship metrics
• Self-assessments
• Internal & external audit
ACT DO
CHECK
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20. Product Stewardship Management System
Policy/Leadership
PLAN
ACT DO
• Management review
• Improvement portfolio
• Projects/initiatives
CHECK
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22. Product Stewardship at early stage
8 Tools available for Commercial Excellent Project
Export Control Screening Tool 8 Eco-Design Principles tool
Life Cycle Screen
Substance of Concern database
Sustainability Profile Guide
EHS Risk Char. Tool
EHS Issues and Risk Mgt Plan
Global Regulatory Checklist
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27. Construction: Sustainable Building Design
Lower façade U-values than
Airtightness Automated ventilation control and
mechanically fixed façades lighting control using natural light
Photovoltaic energy
Rooftop planting
Double-skin façade Lighting control using
Evergreen plant shield Double- or triple- active façade motion detection sensors
against sun and wind pane low-e glazing
Window installation system
Higher energy efficiency with
bonded doors and windows
28. Waste Challenges
• Global issue with local nuances
• Several thousand tpy of silica based waste
• Hazardous classification
– Reduce at source
– Re-use internally
– Recycle partners
• External collaboration: Academia and Industry
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29. In Summary
• Product Stewardship should be a key element in a company’s
chemical risk management strategy
• Global industry initiatives such as Responsible Care® and Global
Product Strategy provide companies with a strategic framework to
drive Product Stewardship performance
• For a Product Stewardship program to be successful it must have
visibility and be regarded as a company priority
• To drive continuous improvement in Product Stewardship it must be
recognized as a Business Process and have a Management System
• Product Stewardship should be deployed throughout the product life-
cycle through the application of formal business processes, policies
and standards
• Product Stewardship delivers societal benefits, enhances a
company’s reputation and makes good business sense
• Waste challenges: Continually seeking external partners.
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Notes de l'éditeur
Add Symbol R to R. Care
Change the photo to something more forward looking, innovative and colourful – move the Hyde photo to the section on innovation
Responsible Care is a key chemical industry voluntary initiative aimed at driving improvement across the chemical industry in 7 key areas of Environment, Health & Safety. It sets a high level strategic direction for the industry as a whole and for companies that subscribe to Responsible Care it helps set a framework within which to drive continuous improvement in each of the 7 areas. Product Stewardship is one of the 7 key areas of focus for Responsible Care.
At Dow Corning we have established Stewardship as one of the four key corporate priorities. This send a clear message that Stewardship is important and will help embed stewardship within the company culture.Stewardship – broad word covering several different topicsSustainability (4-quadrant model / People, Planet, Profit)Social responsibilityEnvironmental care and safetySecurityRegulatory compliance – Cyclics issue –– protecting the Silicone categoryLife-cycle management, product stewardshipCultureAnd moreStewardship points to our corporate values – who we are and what stand for – differentiates us – must perpetuate our culturePersonal ownership and accountability – keepers of the world, company, family, communitiesSustainable company platform on which to grow competitive advantage
There are many different definitions of Product Stewardship but this slide summarizes the key elements. Responsibility for Product Stewardship does not rest solely with the chemical manufacturer but is shared throughout the value chain from raw material suppliers, through distributors to downstream users and retailers to the consumer. Product Stewardship is about assessing , understanding and managing the risks associated with chemical products and ensuring effective communication throughout the value chain and throughout the life-cycle of a product; from development through manufacture & distribution to product use and responsible management of that product at end-of-life. Effective product stewardship throughout the values chain and throughout the product life cycle enhances the sustainability of everyone’s business.
Product Stewards are THE key interface between our Business Units and our Compliance groups. They help the Business Units manage risk associated to the dynamic external regulatory environment and public/customer perception. An effective Product Stewardship network not only manages risk but also helps the Business to leverage the external trend and turn threats into business opportunities. An effective Product Stewardship program adds significant business value.
There is no one standard approach to Product Stewardship and within some companies the Product Stewardship organization can very broad and inclusive whereas in others it can be more narrowly defined and specific. At Dow Corning we differentiate Product Stewardship from Product Safety and Regulatory Compliance (PS&RC) where we handle legal compliance aspects such as safety data sheets and chemical registrations etc. Similarly for our Operational EHS responsibilities these are managed at the production site level to ensure safe use of raw materials, that our processes are run safely, that we meet local industrial hygiene and environmental regulations and that we’re storing and distributing our products appropriately and according to local regulations. Although we do have Product Stewards organizationally aligned to our business units overall direction for Product Stewardship functional excellence is driven from our Governance organization to ensure there is a degree of independence from the influence of the Business Unit leadership to ensure that Product Stewardship decisions can be taken without business consideration playing too influential a role.
Product Stewardship really sits at the centre of these three key areas with significant overlap with each and helping to bridge the gap between each to achieve the best outcomes for all. Product Stewardship , unlike our legal regulatory obligations, is a voluntary initiative. It goes beyond compliance. As covered earlier Responsible Care provides a broader, voluntary strategic industry initiative under which Product Stewardship fits. A key element of Product Stewardship is Risk Management – most chemical companies produce and handle some chemicals that are intrinsically hazardous; we apply product stewardship to ensure the risks in the way the chemicals are handled and used are well understood and managed to minimize potential for harm to human health or the environment. Product Stewardship is key to improving external perception of chemical companies and the industry as a whole; to demonstrate that we responsible corporate citizens bringing the benefits of chemistry to the world in a safe and sustainable manner. The Global Product Strategy initiative is a further enhancement of the chemical industry’s drive towards greater sustainability through effective Product Stewardship.
Product Stewardship should be regarded as a key Business Process and as such should be deployed through a Management System approach to drive continuous improvement towards Operational Excellence. This is the well known PLAN/DO/CHECK/ACT cycle that can be leveraged as a means towards continued improvement of Product Stewardship within a company. Let’s take a look at what’s covered under each of the sections in a bit more detail.
It is essential to identify where Product Stewardship fits within the overall company strategy and its degree of importance. This is where subscribing to Responsible Care and having a Corporate Priority around Stewardship can really support an effective Product Stewardship program and ensure it has the resources and visibility it needs to be effective. A Vision Statement should be established for your Product Stewardship program; where do you want to take it? What should it look like and be delivering in 5 years time? Key Corporate Policies should be established that embed the principles of Product Stewardship into the culture and work practices of the entire organisation.
With high level direction set it is then key to establish a regular planning schedule that scrutinizes your Product Stewardship procedures and processes to identify areas of weakness . These areas can then be the focus of improvement initiatives/projects and will develop into your Product Stewardship goals. At Dow Corning we have a formal annual planning process for Product Stewardship that is then evaluated and updated on a monthly basis as the year progresses and situations change. Central to this planning process are our Aspects & Impacts (A&I) Registers. This is a similar approach to Aspects & Impacts used within our Operational EHS Management System and adapted to be more effective and appropriate for Product Stewardship.
This next slide is a schematic of our risk matrix which is the output of the exercise to “measure” the risk associated to product related activities falling under the umbrella of Product Stewardship. The Y-axis plots the potential consequence related to an activity with no risk mitigations in place. These range from 1 – relatively minor impact, up to 5 – where the impact can be extremely serious including public outrage, substantial fines or imprisonment and product bans etc…The x-axis takes into account the current risk mitigations in place and plots the probability for a process defect to occur or, in the case of an event-driven risk (such as an impending ban on a chemical contained in a range of products) the size of the business at risk. Activities are then plotted on the matrix and those falling in the “red-zone” are prioritized for corrective actions. There are other ways to highlight and prioritize areas for improvement and this is just one example but it is key to have a systematic means for doing this as it is fundamental to an effective management system for continuous improvement.
At Dow Corning we use Risk Registers both at the Business Unit level to highlight business-specific activities that might expose us to risk (use of an unsustainable chemical, selling into a sensitive application…) and at the Corporate level focused on the Product Stewardship processes, workflows and procedures deployed horizontally across the company. Use of the registers promotes visibility and early recognition of product-related risks to enable proactive risk mitigation and minimization of negative business consequences. The Corporate register also provides the basis for highlighting those horizontal Product Stewardship processes most in need of tightening and provides the basis for determining the process auditing schedule.
Under DO we have the Product Stewardship standards, workflows and processes. This is HOW we deploy Product Stewardship and it is key that these processes are formally documented as Business Standards. This is the way we DO Product Stewardship. Along with the processes are the key tools used in support as well as the training programs used to educate Product Stewardship across the organisation.
Under CHECK we establish metrics that track Product Stewardship performance in selected key areas. This can be something of a challenge as Product Stewardship measures are notoriously hard to put in place but the Corporate Risk Register should provide the basis for the key processes that can provide measures that track whether improvement objectives are being met or not. A key step in any continuous improvement management system is self-assessment and formal audit. At Dow Corning we have just started down this path with Product Stewardship, whereas other areas such as Operational EHS have been audited for many, many years. The auditing process can be very revealing and somewhat painful but is essential for an honest and neutral appraisal on how Product Stewardship is being deployed within the company and to elevate the issues that need to be addressed.
Under ACT we review progress of the improvement projects and initiatives on a regular basis to ensure they are on track and make adjustments as needed. An active portfolio of improvement projects is maintained and a formal Management Review held once a year to transition from the portfolio of the current year to that of the next.
Let’s take a look at how Product Stewardship is deployed at Dow Corning at various stages throughout the product life-cycle. At the very outset during product development it is essential to make the right choices to maximize a product’s sustainability and ensure risks associated to the handling and use of the chemicals within the product are well understood and can be managed. To do this effectively we have developed a series of tools to be used by our product development teams during the commercialization process. The tool is a checklist that prompts the team (including the involvement of certain specialists where required) to evaluate the following areas for the product being developed: Human health and environmental impact of the product Selection of raw materials Process considerations and product disposal Handling and transportation Liability exposure Regulatory assessment Downstream product use Public perceptionIn addition our life-cycle screening tool evaluates each stage of the product life-cycle through production and use to assess sustainability and highlight any aspects of concern.Application of these tools by product development teams is essential to ensure a product, when first launched, has maximized potential for sustainability and that any potential issues can dealt with during the commercialization phase and not subsequent to product launch with all the potential for negative cost and impact that might entail.
With the dynamic global regulatory environment, as well as ensuring the chemicals we use to develop new products are sustainable, it is essential to manage, on an ongoing basis, the chemicals contained in current products. Over the product life cycle, chemical classifications can change as more tox. And ecotox. data becomes available and chemicals that may have been deemed sustainable when a product was initially commercialized may no longer be acceptable. Having an effective process to track and monitor regulatory developments and take proactive risk management measures well in advance of regulation can help your company and its customers avoid business disruption due to last minute reaction to regulations. Substitution of a priority chemical is just one potential risk management measure that can be deployed, others include switching customers to an alternative product chemistry that exists in your product range or even restricting use of that substance to applications where safe use can be demonstrated and controlled.
When we market our products we make performance claims ; some based on hard data others based more on perception and/or market experience. In order to avoid mis-leading customers and potentially exposing the company to litigation it is important to be able to demonstrate a clear substantiation trail to back up claims. Our claim substantiation process provides an auditable trail of data to substantiate all claims we make in our product literature with Product Stewards playing a key role in ensuring the claims are robust.
Although there exist clear regulations and legal obligation for the storage and transportation of chemicals for certain classes of particularly hazardous chemicals it can be prudent to go further than the legal requirements to be certain that guidelines have been followed and that customers and downstream users have understood and applied the necessary safety measures. Our business standard for chlorosilanes (a family of chemicals that are highly corrosive) transport specifies the containers approved for transport of this class of chemical including containers provided by customers and prohibits the transport of chlorosilanes by certain modes of transportation such as air shipment.Silicone hydride containing products can, under certain conditions, generate explosive hydrogen gas. Appropriate packaging and storage conditions must be applied and contact with certain classes of chemicals avoided. To ensure our customers a fully aware of these essential guidelines our silicon hydride standard establishes a block on shipments of products containing silicone hydride to customers that have not performed and confirmed that they have completed a self-audit on the handling , storage and use of the product.Both of these are examples of applying Product Stewardship to go beyond compliance to reduce risk and ensure the safe use of the more hazardous products that we sell.
Finally, applying Product Stewardship to avoid product mis-use. Although it is never 100% possible to fully control how your products are being used downstream you can minimize potential for mis-use and shield you company from liability exposure through communication of appropriate and/or inappropriate product usage in product related literature (SDS, Product Data Sheets…). However, in some cases, where the result of mis-use can be extreme, further steps to reduce risk should be implemented. Our infantcare standard specifies certain elastomeric products as those only allowed for sales into infantcare applications such as baby bottle nipples. Our Restricted Fluids Policy prohibits packaging certain silicone fluids in small package sizes and establishes blocks in our ordering system for certain categories of customer who might try to order these products (medical practices for example). The aim is avoid inadvertently selling silicone fluids to those intent on illegally injecting into the human body for cosmetic surgery.
Governments around the world are starting to define requirements for sustainable buildings. Targets are being set for reductions in energy consumption and carbon dioxide emissions. Requirements are being put into place for environmentally friendly building materials that also do not have a negative effect on indoor air quality.The environmental benefits of sustainable building are what you hear most about – ‘green’ buildings use less energy or more alternative energy, which keeps the carbon footprint of the building to a minimum. The use of reclaimed or recycled materials also helps save carbon emissions, but also keeps waste from building up in landfills. The social benefits of green construction is all about people. On top of tangible impacts that Green buildings could bring to the daily life of people such as more natural light, cleaner air without Volatile Organic Compounds and odor, more comfortable temperature and less condensation, leaks and mold problems due to better insulation and sealing systems, Green Building will undoubtedly provide another stream of technology progress that will benefit the society in term of employment opportunities and economic developments. Economically, the advantages of green building are plentiful. Oftentimes, there are cost savings associated with the initial cost of the building – reclaimed materials are often cheaper than newly manufactured, for example. Operating costs are less in most green buildings as proper sealing can keep cold air out in the winter or cool air in during the summer. Also, green buildings are designed to take advantage of the sun – allowing the use of natural light which means you don’t have to have as many electricity-guzzling light fixtures. These are just a few examples of the advantages of sustainable buildings. I think you can see why leading designers and construction companies are focusing on green construction today. They’re doing it because there is a solid business case to do so. And, it is becoming more and more clear that sustainable construction is the RIGHT thing to do.While silicones and related services represent only a small part of the overall construction costs of a building – typically less than 3% of the cost of the façade – they still play an important role in enabling customers to design and construct buildings that are more sustainable.Silicones contribute to sustainability by providing:Energy efficient and durable façade systems for commercial buildings enabled by silicone-sealed insulating glass units and silicone structural glazing (this is what this presentation will focus on);Energy efficient silicone-bonded window systems (for both residential and commercial buildings) which combine high energy efficiency with lower production cost;Lower organic emissions (VOC) than organic sealant and adhesive materials.The diagram in this slide demonstrates the areas, marked in teal blue, where silicon or silicone technology can contribute to sustainable building design. I will explain some of these areas in more detail in the following slides, but as you can see, silicon or silicone technology can facilitate many possibilities.Images:Photo: AV07109 (Seneffe BTC) (approved by Sue Snow on 2009-05-15) (hidden behind graphic)Graphic: Has been purchased from Bode and we have use rights according to Hilde De Ruyck (E-mail dated 2009-05-15)