How to Say Good Bye to Heavy Metals - P2 InfoHouseкод для вставки
. e ,5 *- How to Say Good Bye to Heavy Metals Dave Lennert Corporate Packaging Development, Procter & Gamble presented at Southern States Hazardous Waste Conference Biloxi, Mississippi September 23, 1992 Introduction This paper focuses on the approach we took at P&G to establish a system in order to be in compliance with the CONEG legislation. After some background, I will discuss how we saw the law affecting our business and how we implemented our program. I will conclude with some thoughts on maintaining compliance. Background Heavy metals first came under scrutiny in the late 1960s and early 1970s. Lead in gasoline was one target. As you recall, the forces to eliminate tetraethyl lead anti-knock compounds from gasoline resulted in the development of unleaded gas. This meant big changes for oil refiners and auto manufacturers and they were initially reluctant to make these changes. Lead in drinking water became a concem as did the use of lead based paints. First, it was the use of lead paints in children's toys, but then the concern spread to use in house paints and beyond. Mercury was found at low levels in lake and river fish, raising the question of how it got there. Incidents of severe mercury poisoning from industrial discharge were reported from Japan. The pictures of retarded and deformed children were heart rending. During this period we began a program at P&G to eliminate the intentional use of heavy metals. A review of our packaging materials showed that inks and pigments were the type of package material where we would most likely encounter heavy metals. We set a policy of removing those inks and pigments that contained heavy metals. As you can imagine, this involved a lot of work since art directors and brand managers did not want to give up an iota of shade or brilliance on their packages. In the past 20 years, society's concerns over the impact of human action on the environment has continued to increase. A good indicator is the difference in the number of Federal environmental laws enacted between 1900 and 1970- 14 laws in sixty years and the 28 laws enacted in the past twenty years. Solid waste disposal has been a topic of extremely high interest for the past six years. Not only is the amount of waste an issue, how it is disposed is also an issue. Leachates from landfills and effluents from incinerators are major issues. It was these last two concerns that caused the CONEG Source Reduction Council to consider the reduction of the use of toxic materials as a source reduction helpful to solid waste management. For those who are not familar with the acronym, CONEG is the Coalition Of Northeastern Governors, a vehicle for the region's nine states (the New England states plus New Jersey, New York and Pennsylvania) to explore shared problems. The Source Reduction Council was formed to address the packaging aspect of the solid waste disposal issue. The CONEG Heavy Metals Model Legislation The easiest way to describe the CONEG legislation is by answering the familiar joumalist's questions of what, where, when, etc.: Where Passed NY,CT,ME, WS,RI,NH,VT,IA,WA, MN When New York first 1/1/92; Others in 1992 and 1993 What Metals Lead Cadmium Mercury Chromium+6 What Levels Combined Totals not to exceed 600ppm 1/1/92 25Oppm 1/1/93 100ppm 1/1/94 What Is Covered All Packages unit package, intermediate package shipping container, crates, trays wrappers and wrapping film bags and tubs 2 F?j L What Is Covered All Package Components individual parts, closures blocking, bracing cushioning, strapping coatings, inks, and labels Procter & Gamble's Program Procter & Gamble's U. S. operations are divided among many business units and subsidiaries. Each business unit has many packaging suppliers. Many of our suppliers also have multiple business units. Many of these suppliers provide materials to several of our business units. The result is a matrix of P&G and supplier connections that can be shown as follows: Supplier A P&G Categories and Business Units P&G- 1 P&G-2 P&G-3 P&G-4 A- 1 A- 2 A-4 Supplier B B-1 B-2 B-3 Supplier C c-2 c-3 Supplier D D- 2 SupplierE E- 1 P&G-5, etc. A-5 B-5 c-4 c-5 D-4 E- 2 Etc. It became clear to us that with about 1000 supplier locations and 40 P&G business areas, some simplification must be made. The fundamental decision we made was that we would require onlv one certificate from each sumlier comDany and it would amly to all P&G divisions and brands. This decision was crucial. An item-by-item clearance of each packaging component P&G uses would require literally tens of thousands of certificates. It would also mean multiple requests from different P&G business units for suppliers which would generate a lot of duplicate paperwork. For example, a corrugated supplier shipping to five different P&G divisions would be required to send out five certificates. 3 The second benefit of the "single certificate" approach became apparent when we discussed the CONEG legislation with a small sample of our suppliers. Certification of compliance was not merely a P&G request. It was something that every user of packaging would need from each of their suppliers. Suppliers must certify all their packages to all their customers. It would be easiest to do this with one, general, all-encompassing certifcation document In effect, the law pushes suppliers to discontinue use of heavy metals for simplicity of operation. Implementation of the Program A requirement such as the CONEG heavy metals legislation affects may parts of a functionally organized company like Procter & Gamble. One key to successful implementation of a project which crosses many, many organizational bounds is communication among these functions. A second key to success is leadership responsibility. Someone must feel accountable for implementing the policy and correspondingly, have management support for their requests of the organization. Several functional organizations at P&G were involved. Most of these functional groups exist in each P&G business unit. They can be described as shown below: Functional Responsibilities within P&G Corporate Packaging Development Purchasing Regulatory Compliance Packaging Standards and Specifications Analytical Legal Corporate Packaging Development (CPD) is a staff function that communicates with the packaging personnel in each business unit. CPD assumed the leadership role to organize and implement a system for compliance with the CONEG Heavy Metals Legislation's requirements. By working with the Corporate Purchasing Department, a master list of all U. S . supplier addresses was compiled. A draft letter and compliance certification format was designed and pilot tested with a small number of suppliers. After revisions, the letter was sent to about 1,000 supplier addresses with copies to affected parties within P&G. The letter asked that each supplier reply with one and only one signed certificate to Corporate Packaging. 4 ,-4 . " Corporate Packaging would later copy the returned signed certification and distribute it to each P&G business unit which was supplied by that supplier. A copy the certification form is appended. Regulatory Compliance personnel were asked to set up a system in their categories. In the system, the certifications would be kept up to date as new suppliers and new materials from current suppliers were qualified in the future. Also, the line divisions would institute their own quality control measunnents. Personnel who write Packaging Standards and Specifications were asked to include the requirements of the CONEG law in the master general specifications for packaging materials and to specify any analytical requirements. A team of analytical chemists from the different categories did some research and testing to determine the appropriate analytical techniques and guidelines for each of the major classes of packaging materials P&G uses - paper, plastic, glass, aluminum and steel. Guidelines for analysis were assembled. Results of the Program Initial letters were mailed July 1, 1991. The letters requested that the certificates be retumed by September 1, 1991. All P&G intemal activities were scheduled for completion by Nov. 1,1992. This allowed about two months to deal with any materials or suppliers which could not comply. By September 1,1992, we had received certifications from about 40% of the 570 supplier companies. Suppliers were agreeable to signing the certificate and maintaining basic responsibility for documenting the heavy metal content of items they sold to P&G. Interestingly, we found that heavy metals had been phased out and were not a usage issue for our packages. In fact, many suppliers indicated they were currently able to meet the 1994 requirement of lOOppm total heavy metals content. We also found that many suppliers who were listed were no longer doing business with P&G. With a lot of follow-up, we had reduced the number who had not responded in one way or another to about 40 by the end of December. 5 As planned, copies of the certificates were sent to each of the business units. These organizations now have responsibility for the on-going CONEG compliance. Critique and Improvements Overall, this program has been very successful. A few aspects of it were essential to this success. First was the decision to use one certificate per supplier versus a certification for each aqd every package component. Second was the fact that accountability for implementation resided in one person. Also, adequate time for response and implementation was allowed- about 6 months. A couple of things could have been done better. The supplier lists received from the business units were outdated in that we were not currently doing business with about 110 of them. This led to a waste of mailings and follow-up. The responsibities for the sustaining system were negotiated category by category. More and earlier communications among categories about this would have facilitated implementation. Sustaining System Based on our experience, the following three points should be emphasized in maintaining an accurate compliance file: Include the heavy metals specicifcations in the screening: qualifications for new materials. Companies already screen new materials for human and environmental safety. These requirements should be added to the exisitng procedures. Write the CONEG leFislation requirements into the master speciifcations. Companies already have a set of general specifications that are policy items and apply to all materials. It is sometimes referred to as "boiler plate." The CONEG specfics should be added to this document. Set UD an intemal monitoring Dropram. While the supplier is legally responsible for documenting the heavy metal data,it is good procedure to set up a monitoring program. Spot checks of the received material can validate that the suppier's procedures are accurate. 6 9 Closing Setting up a compliance program has been an extensive effort. We allotted about eight months to achieve completion. This gave us enough time to react to any complications. We were pleased with the acceptance of this requirement by our suppliers. We were also pleased that our packages were already in compliance. It is good to see this program in place and to know that heavy metals usage is not an issue for our brands. 7 Attachment I I Certification, We cemfy that all packages and package components sold in the United States to The procter & Gamble Company and/or its subsidiaries comply in all respects to the package requirements for heavy metals of the CONEG Model legislation; namely, that the sum of the concentration levels of lead, cadmium, mercury and hexavalent chromium present in any package or package component shall not exceed the following: 600 Parts per million by weight Effective January 1,1992 250 Parts per million by weight Effective January 1,1993 100 Parts per million by weight Effective January 1,1994. All packaging and packaging components shall be subject to this title except 1) those made or delivered prior to January 1,1992,2) those containing the вЂњ l s . i n mdcr.a,comply with federal h d t h and safety r c q ~ n t for s which thereis no pradkal alternative, 3) those that exceed the limits because of the addition of post consumer mat&& but only until January 1996, and 4) any glass container intended for rei2l.mreuse but only until January 1,1994. We will maintain adequate documentation of this certification, including that of any exemptions permitted by the legislation. Documentation will be madc available for inspection. mMPANYNAME: .. ADDRESS: Certified by: (Rcv. 5/31/91)). (certificaton) .. .