Responsibility along the Value Chain
Product stewardship for Covestro means the comprehensive evaluation of health, safety and environmental risks. We want to ensure that our products are safe throughout their entire life cycle – from research to production and marketing and for their intended use by the customer through to disposal.
Monitoring the quality of our products and their suitability for particular applications is anchored in our operational units. Safe transportation, qualification for specifically regulated applications and marketability are centrally managed at Covestro, as is the obligation to report to the Board of Management on these matters.
The safe use and application of our products has high priority. We greatly value conveying product safety information transparently and comprehensively. In addition to the documents required by law, we therefore provide supplementary information and offer training as part of the global product strategy of the International Council of Chemical Associations (ICCA). Furthermore, experts in all areas of the company work closely with suppliers, customers, industry associations and the public. Covestro aims to ensure the effective communication and observance of health, safety and environmental information along the entire supply chain.
Management of product stewardship
Product stewardship involves both compliance with statutory requirements and voluntary commitment. Here we also take into account the precautionary principle as explained in Principle 15 of the Rio Declaration of the United Nations and communication COM(2000) 1 of the European Commission. This important means of protecting consumers and the environment within the context of risk management may be used in special cases in which, according to an objective and comprehensive scientific evaluation, material or irreversible harm to people and the environment may occur, but the risk of this cannot be established with sufficient certainty. In this, we follow the general principles of the European Commission for application of the precautionary principle. These include especially the proportionality of the measures taken, examination of the benefits and costs of all relevant options, as well as the review of the measures taken in light of new scientific developments. Arbitrary decisions cannot be justified by invoking the precautionary principle.
As a contribution to the safe handling and use of chemicals, risk assessments are carried out applying recognized scientific principles such as those described by the European Chemicals Agency (ECHA) in its Guidance on Information Requirements and Chemical Safety Assessment. A determination is made based on a hazard assessment and exposure estimation as to which additional information is required for the risk characterization of a product.
All product groups at Covestro undergo a multiple-step product safety assessment process. At first, we identify chemicals that are subject to statutory regulations and document the corresponding regulations. We then examine the risk potential of our products. During this process, we also identify substances for which only limited use or marketing are permitted based on the applicable laws and regulations. These include, for example, substances classified as being of very high concern in accordance with the European Regulation on the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH) and substances covered by the European regulation on greenhouse gases. Substance compositions are checked against rules sets that would reliably indicate noncompliance with regulatory requirements. Should the assessment or new findings reveal that it is not safe to use a certain chemical, we take the necessary risk mitigation measures. Those can range from technical measures such as protective gear and revised application recommendations to the withdrawal of support for a certain application and substitution of a substance. In this case, an adequate replacement must be sought which can be produced in an economical and technically feasible way. Finally, we produce the legally required safety data sheets, technical data sheets and labeling for the chemicals, including for chemicals that are not subject to this legal obligation, thus exceeding statutory requirements.
We collect, document and analyze all information about the safe and compliant use of our products in a global information system, which provides the basis for further improvements. This includes product monitoring and reporting on product-related and compliance incidents. Our global regulations for the Group contain rules and guidance on when and how this information is to be used. For example, we have been able to improve the information on the safe handling of our products and provide customers with specific training. Furthermore, computer-based training for our employees along with workshops help embed the understanding and importance of product stewardship in the company.
For 2019, we know of no material incidents of noncompliance with regulations and voluntary codes concerning the health and safety impacts of products and services, nor of any significant noncompliance with regulations and voluntary codes relating to product information and labeling.
Fundamentally, the optimization of products and processes is an ongoing task of the chemical industry and is integral to our commitments as part of the Responsible Care initiative. This is an initiative by the chemical industry that aims for continual improvement by companies in the areas of environment, safety and health, regardless of the legal requirements. We also participate in the further development of scientific risk assessments through our involvement in associations and initiatives. International associations such as the European Chemical Industry Council (CEFIC) and the International Council of Chemical Associations (ICCA) are working to improve the scientific assessment of chemicals and research new testing methods. Moreover, they monitor implementation of legal regulations. Covestro is actively involved in industry association activities. Furthermore, we endorse the initiatives of the World Health Organization (WHO) and the EU to improve health and the environment, for example with the further development of human biomonitoring through an alliance with the German Chemical Industry Association (Verband der Chemischen Industrie, VCI) and the German Federal Ministry of the Environment.
Implementation of regulations and voluntary programs pertaining to chemicals
Covestro adheres to the applicable regulations pertaining to chemicals, such as REACH in Europe and the Toxic Substances Control Act (TSCA) in the United States. These regulations are aimed at protecting human health and the environment from the risks posed by chemicals and shape our activities as a manufacturer, importer and user of chemicals. We have established internal regulations to adequately address the range and complexity of the relevant requirements.
Substances registered according to REACH are assessed by regulators. This can result, for example, in additional testing requirements, new risk management measures, or inclusion in the REACH authorization procedure. A number of Covestro substances are also affected by this procedure, which restricts the use of particularly hazardous substances or can lead to their substitution or prohibition. The planned restriction on diisocyanates currently being discussed in the EU committees is one example of a potential restriction. Although diisocyanates will still be available on the market, their use in the workplace will require specific training and the implementation of (risk) management measures in the future. Covestro supports this and advocates a practical and effective arrangement, for example regarding the preparation of training materials. As a member of the European chemical industry, we made a voluntary commitment to review and improve the REACH registration dossiers by 2026.
In addition, Covestro pursues the goal of completing the assessment of the hazard potential for all substances used around the world in quantities exceeding one metric ton per annum by the end of 2020. We thus exceed statutory requirements. In addition, we ensure that substance assessments comparable to those meeting the high standards of REACH or the TSCA will also be applied at Covestro sites that are not subject to these regulations. The relevant procedure is established in the corporate regulation “Product Stewardship” in the annex entitled “Substance Information and Availability.” When it comes to purchased substances, we are dependent on information provided by our suppliers. In this regard, however, we expect that the availability of data will also continue to be limited in the future, particularly outside of the EU.
Another example of our commitment to Responsible Care is the worldwide support we provide for customers for safely handling large quantities of reactive products through tank-farm safety assessments.
Covestro has also committed to compliance with animal welfare policies during toxicological and ecotoxicological testing.
We support the Global Product Strategy (GPS), a voluntary commitment by the chemical industry initiated by the ICCA. Its objective is to improve knowledge about chemical products, especially in emerging and developing countries, and thus increase safety in the handling of these products. GPS is accessible at Covestro through the Product Safety First internet portal and is available worldwide. On this website, we inform our customers and other interest groups about safety-relevant properties and the safe handling of our products.
Substances that are the subject of public debate
Covestro is following the scientific discussion about the chemical bisphenol A (BPA), a main feedstock for various plastics. Critics, but also some authorities, are concerned that risks could result for users and the environment if traces of BPA are released from products. At this time, these concerns are primarily being discussed in the context of the European chemical regulation REACH.
Based on numerous scientifically valid and high-quality studies, Covestro is confident that BPA can be safely used in all areas of application supported to date. This assessment is supported, e.g., in the case of food safety, by the latest evaluations from the responsible European and American authorities, namely the European Food Safety Authority (EFSA) and the Food and Drug Administration (FDA). By participating in regulatory processes, Covestro is actively working to dispel uncertainties and answer open questions. In addition, we continue to advocate for making the discussion more objective based on all of the scientific data and in cooperation with the PlasticsEurope association, the American Chemistry Council (ACC) and the China Petroleum and Chemical Industry Federation (CPCIF). Covestro is involved in the debate, providing information to customers and the public on this issue through associations, on the Covestro website and through direct contacts.