Document Rjy1dYbz3kdmmpORgRqJdKKbz
DRAFT #5
September 29, 1992
PLEDGE GUIDELINE #4
PRODUCT STEWARDSHIP
Design, assess, manufacture, market and dispose of Monsanto's products in such a way that they meet societal needs and do not pose an undue risk to human health or to the environment during all stages of their life. Work with product stake holders (suppliers, employees, distributors, customers, consumers and disposers) to understand and reduce risks associated with a product's life.
KEY RESULTS
The principles and key elements of Product Stewardship, as specified in Responsible CARE programs around the world, are practiced by Monsanto's global operations.
Appropriate safety and handling information, including Safety Data Sheets
(SDS's), are provided to potentially exposed employees including contract
employees and product receivers.
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Work toward the goal of no undue risk through systematic risk reduction throughout a product's life.
The application of product stewardship principles adds value to Monsanto product offerings that provides a competitive advantage.
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PROGRAM
6.1 Health. Safety and Environmental Information and Risk Characterization 6.1.1 New chemical products, new isolated process intermediates, and significant new uses of existing chemical products will have adequate health, safety, environmental, and exposure information to support a preliminary product risk characterization (ER-200 or EC-201, and an R&D SDS), at the earliest practical stage of R&D and prior to offsite shipment. A product risk characterization, including an EC-202, a final SDS and a shipping classification, will be completed before new product commercialization.
6.1.2 The Monsanto process for generating and maintaining a SDS is comprehensive, and will fulfill the requirement for a product risk characterization. Whenever significant new information becomes available, it will be reviewed as part of the SDS program to satisfy regulatory and product risk characterization requirements. A SDS review / product risk characterization will be performed on a periodic basis, commensurate with product risk but no less than every five (5) years.
6.1.3
Product files or information systems will be maintained for all products or product families. The product files or information systems will contain the types of information necessary to fulfill regulatory requirements and to perform product risk characterizations and assessments, as appropriate including:
Safety Data Sheets;
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References to relevant literature or internal reports dealing with health and safety (toxicology, epidemiology, industrial hygiene, flammability, reactivity, etc.), relevant information on composition, physical properties, raw materials, manufacturing processes, principal by-products, protective measures, exposure information, energy requirements, wastes and disposal practices;
Use information, including handling, transport, packaging and storage, which will either be estimated (typically for new products) or obtained by visits or reviews of customer, distributor and consumer practices;
A critical review of health and environmental effects and exposure information, such as EC-201, EC-202, Monsanto Work-Place Permissible Exposure Guideline (MWPEG) Reviews, Health Effect Reviews and Toxicology Reviews;
Technology Risk Reviews.
Health concerns from customers, employees or the public.
6.2 Risk Management System
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6.2.1 A systematic approach to risk management will be implemented and maintained for new products. Existing products will be managed on a case-by-case basis.
6.2.2 Risk management options, where needed, will be an integral part of the follow-up to each phase of a product risk characterization,(as detailed in Section 6.1).
6.2.3 All products will be appropriately labeled for hazard or risk and will conform as a minimum to governmental requirements and appropriate consensus standards (ANSI, ISO, etc.).
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6.2.4 Examples of specific risk management actions are detailed in Sections 6.3 through 6.7.
6.2.5 Document Risk Management actions in product files.
6.3 Product and Process Design and Improvement
6.3.1 R&D materials utilized in the laboratory will be handled under to Prudent Laboratory Practices or equivalent.
6.3.2 Pollution prevention principles (Guideline #1) will be included as a review criterion in technology risk reviews for new and existing chemicals.
6.3.3 Pollution prevention principles (Guideline #1) will be incorporated into the EC-201 /202 assessments.
6.4 Employee Education and Product Use Feedback
6.4.1
Employee education for the purpose of safe handling and use of chemicals, is addressed in Pledge Guideline #2, Employees with significant customer interaction will be trained to recognize and feed back information about product use and misuse to Monsanto's environmental network.
6.4.2 Feedback systems to listen to stakeholders will be nurtured and expanded where appropriate. These systems include: commercial and technical sen/ice liaison with customers, product hotlines, poison control center relationships, etc.
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6.5 Contract Manufacturers
See Pledge Guideline No. 7 - Outside Processors
In addition, provide guidance and information for contractor personnel on the safe handling and transportation of Monsanto products.
6.6 Suppliers
6.6.1 Up to date and high quality product information, including composition data and Safety Data Sheets will be obtained from suppliers for all raw materials.
6.6.2 Suppliers will be actively engaged as appropriate, commensurate with raw material risks.
6.7 Distributors. Customers and Other Direct Product Receivers
6.7.1 Assure SDS's and other appropriate safety literature are provided to all direct product receivers.
6.7.2 As appropriate, actively involve Monsanto product receivers in dialogue and outreach regarding appropriate risk characterization, risk management and risk reduction. Where applicable, conduct Monsanto assisted audits. If improper practices involving a Monsanto product are identified, work with the product receiver to improve the practices. In cases where adequate improvement is not evident take appropriate action, including termination of product sale, if necessary.
6.7.3 Actively seek product receiver involvement as input to continuous improvement of Monsanto products, and as a means of seeking product differentiation from competition, on the basis of health, safety and environmental stewardship.
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6.8 RESPONSIBILITIES
6.8.1
Product Stewardship is the responsibility of the business units. Each operating company, free-standing division or world area will assign an individual(s) the responsibility for assuring that this Guideline program is met.
6.8.2 Guideline oversight is the responsibility of the Corporate Environment Safety and Health Staff.
6.8.3 Units of the corporate staff and business units are jointly responsible for developing information needed for product evaluations. This includes regular periodic reevaluation of new information relevant to the product.
6.9 MEASUREMENT
The following indicators will be used to measure progress against this Guideline:
6.9.1 The extent to which internal and external requirements are met for ail new product introductions, (i.e., EC 201, 202 approvals, and governmental approvals).
6.9.2 The degree to which we have determined product hazards.
6.9.3 The degree to which we know how our products are used and the resultant exposures to people and the environment.
6.9.4 The degree to which adequate HS&E data is available, and provided to the ultimate product receiver.
6.9.5 The extent of progress in understanding and diminishing the risks and environmental impacts associated with a product throughout its life.
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6.9.6 The extent to which Monsanto product are differentiated in the marketplace.
6.10 DEFINITIONS 6.10.1 Product Receiver: An entity (not an individual) to whom we transfer product. This definition is included to capture categories of product receivers (such as brokers or transporters) who may not fall into the traditional customer category.
6.10.2 Product: Chemical substances and mixtures, materials and equipment, articles, licensed technology and services related to product use that are sold, distributed in commerce or otherwise provided.
6.11 REFERENCES This Guideline supports and implements the_requirements_of industry performance standards as follows: 6.11.1 US Responsible CARE (CMA) Code on Product Stewardship. 6.11.2 UK Responsible CARE Code on Product Stewardship. 6.11.3 Canadian Responsible CARE (CCPA) 6.11.4 ANSI standards on labeling and SDS. 6.11.5 ISO 9000 standards
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6.11.6 Prudent Practices for Handling Hazardous Chemicals in Laboratories, National Research Council, National Academy Press, Washington, DC 1981
6.12 COORDINATOR J. R. Condray, ESH, Corporate, WHS, A3NA, (314) 694-8883.
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