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How to Say Good Bye to Heavy Metals - P2 InfoHouse

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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
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.
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
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
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
What Is Covered
All Packages
unit package, intermediate package
shipping container, crates, trays
wrappers and wrapping film
bags and tubs
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
A- 1
A- 2
Supplier B
Supplier C
Supplier D
D- 2
E- 1
P&G-5, etc.
E- 2
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.
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
Regulatory Compliance
Packaging Standards and Specifications
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
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.
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
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
As planned, copies of the certificates were sent to each of the business
units. These organizations now have responsibility for the on-going CONEG
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
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.
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.
Attachment I
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 “ 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.
Certified by:
(Rcv. 5/31/91)).
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