We take responsibility for minimizing the human health and environmental impacts of our products throughout their entire life cycle.
Our approach to product stewardship is multi-faceted.
Our Product Stewardship Management System, which includes product stewardship implementation tools, is the bedrock of our process. To ensure sustainable business practices, the management system’s nine elements cover the full scope of the product life cycle – from product development through hazard communication, chemical regulatory compliance, transport of dangerous goods and customer response to end-of-life requirements.
We conduct an annual management review in each business to drive continuous improvement and ensure that any critical gaps are closed by a robust action plan. We supplement this process with compliance assurance audits that focus on key business risk. All business units are audited on a three- to five-year cycle.
We continued to conduct extensive benchmarking with industry peers in 2019, and we incorporated significant learnings into our Product Stewardship Management System and review/audit processes.
Our centralized Global Product Stewardship (GPS) system manages the data required to author hazard communication documents.
This starts with one global hazard evaluation process to assess and approve raw materials used to manufacture product in terms of human health, physical and chemical properties, environmental impact and compliance with global regulations and PPG policies. Product formulas are automatically transferred to this system, which then provides an on-demand safety data sheet (SDS) and hazard warning label for all languages and regulatory jurisdictions where we do business.
Our automated email distribution for SDS is based on customer orders placed for our products sold around the world. Known as STAN (SDS Transmission and Notification), the system supports region-specific SDS distribution while offering increased functionality. This includes the ability to distribute an SDS for non-PPG manufactured products, automated distribution for the latest SDS after a major version change, and distribution of an SDS to multiple email addresses for customers.
We leverage the GPS data to support many other compliance and customer requirements. These include chemical inventory, PPG and customer restricted substances lists, and customer requests to support their sustainability programs. Using the global data allows us to quickly respond to customers and identify any potentially problematic or concerning substances.
The system is used frequently by our toxicology, product development and sustainability teams.
Chemical Inventory Compliance
To ensure compliance, we maintain a robust central management system for notifications to the regulatory authorities, including those that oversee Registration, Evaluation, Authorisation and Restriction of Chemicals in Europe (EU-REACH), the Act on the Registration and Evaluation of Chemicals in Korea (Korea REACH), the Toxic Substances Control Act (TSCA) in the U.S. and many more.
During 2019, we completed all of the pre-notifications required under Korea REACH ahead of the June deadline. We also successfully completed seven low volume exemptions (LVEs) and five pre-manufacture notices (PMNs), which cover 20 substances. The LVEs and PMNs are required under TSCA/Frank R. Lautenberg Chemical Safety for the 21st Century Act (LCSA). One PMN was still under review at the end of 2019.
All granted PMNs have been subject to significant new use rules (SNURs) for chemical substances, and we are working closely with our customers to manage the implementation of these restrictions.
Much of our technical leadership is based on the development of polymers. Our regulatory team works closely with our polymer chemists, advising them on the “design of polymers for regulatory compliance” and providing support at all stages of the development process.
This early involvement allows us to complete the registration process in any of the nine country inventories that require polymer notification well ahead of product launch, getting our products to market faster.
New polymer notifications continue at a high level, especially in China. We welcome the regulatory simplifications proposed in China to remove the requirement for research and development (R&D) notification and greatly simplify the process for those polymers recognized as non-hazardous.
Regulatory and Emerging Issues
In parallel to our GPS system, we maintain a simple-to-use matrix that details regulatory requirements for all countries where we do business. This is supported by detailed procedures for compliance, including customer use requirements. Examples include food contact, restriction of hazardous substances (RoHS), volatile organic compound (VOC) emissions and items intended for use by children.
Continuous monitoring of emerging issues and regulatory changes along with a project management process to implement changes to our compliance procedures ensure that we have no business interruptions. We recently launched a new tool to facilitate the early identification of issues with regulatory and financial impact to our businesses and provide a way to prioritize those that are most impactful. Combined with improved workflow management and close linkage with the research and development community, this tool will further position us as a proactive business partner for our customers.
We use three toxicology processes to evaluate and monitor substances used in our products – Early R&D (ERD) Hazard Screen, Substance of Interest (SOI) Scorecard and PPG Restricted Substances List (RSL).
Driven by committees that include cross-functional global team members, these three processes are linked to monitor and manage health and environmental risks of raw materials throughout the development and commercialization of our products.
ERD Hazard Screen
During a new product’s R&D phase, we assess the hazard of raw materials and potential byproducts using a hazard screen process. In 2019, we completed more than 40 of these early screens to guide our R&D chemists during product development. Following a product’s commercialization, we may develop an SOI Scorecard incorporating this assessment and any new hazard information to further guide our businesses.
Our SOI Scorecard is a visual “picture” forecasting the hazards, regulatory status and stakeholder concerns for substances that are critical to our businesses. Its purpose is to guide responsible product stewardship and build our confidence to further use those substances with low risk for a sustainable product portfolio.
During 2019, we developed 21 scorecards for substance families that included 39 distinct substances. At year’s end, we had 120 scorecards tracking 169 substances available for use in product development, with some scorecards monitoring numerous substances within the same family.
We continually update our SOI Scorecards with new regulatory, scientific and market developments. When updated, we review substances for placement on the PPG RSL. Linking the two processes enables our technical community to begin the process of product reformulation prior to the inclusion of a substance on the PPG RSL.
The PPG RSL establishes our current minimum acceptable requirements for restricting certain hazardous substances in our products. It follows the One PPG approach and applies to all PPG products globally, including those sold in areas of the world that lack chemical regulations.
We have a sustainable process to keep the list evergreen, including reviewing new substances for addition to the list. We also conduct, at a minimum, a biannual review to ensure there are no restricted substances in our global product portfolio.
The PPG RSL is based on the principle of controlling the health and environmental risks of commercial products by:
- Identifying specific chemicals with potential risks;
- Restricting those chemicals for specific uses or, in some cases, all uses; and
- Setting chemical thresholds based on the hazard and intended product uses.
In 2019, we had more than 990 substances that we restricted for all uses in our products and more than 450 substances that we restricted for specific uses, such as consumer and aquatic.
A good example of our progress is the elimination of lead as an ingredient in manufacturing any of our paints and coatings anywhere in the world.
We have not used lead as an intentionally added ingredient in our consumer paints and coatings for some time. In 2019, we achieved our goal of eliminating lead from the production of a small quantity of non-consumer coatings formulations that remained in our portfolio. These non-consumer products had contained lead solely to meet the unique specifications of certain customers.
We will not use lead in new formulations in the future. As part of our integration process, we will continue to develop plans to eliminate lead from products that become part of our portfolio through acquisitions.
Life-cycle analysis (LCA) is a scientifically recognized method for assessing the environmental impact of products – from the extraction of raw materials to the disposal of a product at the end of life. One of the key outputs of an LCA is the carbon footprint.
Our Life-Cycle Analysis Community of Expertise serves all business units globally, enabling each to benefit from a scientifically sound calculation of the environmental impact of its products.
Looking at the entire life cycle means we can avoid erroneously developing environmentally friendly products because of a narrow focus on their production. Products that look better from a manufacturer’s perspective because they use less energy or cause less pollution during manufacturing could actually be worse for the environment due to their impacts in other phases, such as raw materials, use or final disposal. Our LCA capabilities allow us to avoid this pitfall and consider if new developments are truly better for the environment.
An LCA also allows us to quantify the environmental benefits that are only realized in our customers operations or in the use of products by our customers. This insight enables us to develop truly customer-focused sustainably advantaged products.
We are very active in industry organizations and public forums. We also engage with customers, non-governmental organizations, government agencies and other stakeholders to ensure that we understand their requirements and they, in return, understand our position and requirements for efficient and sustainable business operations.
We track and prioritize opportunities for advocacy based on risk and financial impact. As a result of that assessment, our current focus continues in three areas where there is opportunity to work with and influence government agencies for better regulation:
- TSCA and LCSA in the U.S., including new chemical notification processes (PMN and LVE) that are fit for purpose. We have continued discussions with the U.S. Environmental Protection Agency to help it further understand the issues and agree on a path forward for mutual benefit.
- Titanium dioxide hazard classification in Europe to avoid classification that can harm the reputation of the classification, labeling and packaging (CLP) system. We had successful multi-stakeholder interactions to modify the original proposal, and we continue to advocate for an alternative approach to manage poorly soluble low-toxicity powders.
- China’s VOC regulations to achieve environmental goals with technically feasible solutions and a joined-up process for regulations at the federal and local levels. We continue to provide input on various elements of proposed legislation, including extensive and productive engagement with authorities.
In 2019, we welcomed the decision by authorities in the Philippines to provide extensive exemptions from notification to the Philippine Inventory of Chemicals and Chemical Substances for polymers that are recognized as non-hazardous. This is consistent with the global interpretation of the understanding of polymers of low concern.
Product Stewardship Leadership Development
We have built our product stewardship resources over many years, and we continue to evolve to meet changing business expectations.
Product stewardship experts are embedded in each business unit and region, where they have an intimate knowledge of the product portfolio and business requirements. In addition, corporate centers of excellence ensure that we maintain compliance and strive for improved efficiencies of scale.
Accessible and relevant training materials are deployed for all company stakeholders (technical, marketing, leadership, etc.), with on-demand or assigned access to training modules on all aspects of product stewardship.
Our Product Stewardship Training Matrix identifies 35 training elements, and we migrated the majority to the new One PPG global training platform during 2018. We recorded the completion of 5,200 training units during the year.
To ensure regulatory compliance requirements are easy for our technical community to understand, we developed and continue to support the Chemist’s EHS Toolbox to provide easy access to the right product stewardship tools.
Through links, the toolbox offers a roadmap of the resources designed for chemists and formulators to support product stewardship needs at every level of product development – from new raw material registrations to changes in existing products – to reduce the risk of delayed product launch. In addition, the toolbox helps our chemists determine if their formulation is compliant for shipment to a particular country, find whether a substance in the formulation will likely be deselected from the marketplace and identify those substances that are causing hazard statements on a safety data sheet.
Coatings are used extensively in the building and construction market for protective and decorative purposes on the building itself and as a coating on components or machinery installed in the building.
We leverage data from our systems to produce declarations that support the requirements of green building schemes. These include the U.S. Green Building Council’s Leadership in Energy and Environmental Design (LEED®), Europe’s Building Research Establishment Environmental Assessment Methodology (BREEAM®) and the WELL BUILDING STANDARD™.
PPG Consumer Product Evaluation Process
Because we produce coatings for some of the most demanding applications, our product development chemists have a wide range of technologies that can be redeployed from high-performance applications to products that find use in our everyday lives. This enables enhanced performance benefits or features not currently available in the typical consumer product portfolio.
Technologies that require additional safety precautions, however, are not necessarily suitable for application by or near consumers. For this reason, we have the PPG Consumer Product Evaluation Process.
In this process, we assess many aspects specific to consumer products. Our experts in the fields of toxicology, environment, health and occupational safety review the particular technology, raw materials and means of application to assess their suitability for a consumer product. The results can be to continue with the development, proceed with restrictions or abandon the development. The ultimate goal is to ensure the new consumer product does not pose any threat to the environment, the health of those producing or applying the product, and, ultimately, the end users who benefit from the product.
PPG SAFEASSURE™ for Sustainable Packaging
Part of our packaging new product development process, the PPG SafeAssure program is a stringent protocol for screening both starting chemicals and those migrating into food or beverages to assure the longevity and sustainability of new platform technologies.
The program goes beyond the legal compliance requirements for packaging coatings to support the market in demonstrating food safety. It builds a dossier of key information to allow the onward supply chain to conduct appropriate risk assessments and build confidence in food or beverage products released to the market.
State-of-the-art methodologies around analytical science, risk assessment, and in-silico toxicological assessments support our responsible solutions and customers brands. We invest substantial time, cost and effort in this area to enhance the sustainability of our packaging customers.