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LubeCaresm A Product Stewardship Program

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... with legal requirements applicable to product manufacture, use, and disposal. ... Management of the Manufacturing Environment ... – PowerPoint PPT presentation

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Title: LubeCaresm A Product Stewardship Program


1
LubeCaresm A Product Stewardship Program
  • Independent Lubricant Manufacturers Association

2
Acknowledgements
  • Cathy Barmoy ILMA
  • Carol Poole Quaker
  • John Bortak Tower Oil
  • Rich Kraska Lubrizol
  • Jeff Leiter Counsel
  • Greg Foltz Milacron
  • Lon Fanning Perkins Products
  • Dave Rankin Dover Chemical
  • Ike Tripp Etna Products
  • Gene White Milacron
  • Dan Goon Castrol
  • Keith Nykerk Fuchs
  • John Cutcher DA Stuart

3
Todays Perception of Product Stewardship
  • Confusion as to the definition, scope, purpose of
    product stewardship
  • How does product stewardship relate to all ILMA
    members?
  • Duplicate programsWere already doing that (e.
    g. ISO)
  • Compatibility
  • How do we integrate a program?

4
Confusion as to the definition, scope, purpose of
product stewardship
  • LubeCaresm defines product stewardship program
  • Definition is easy to understand
  • Product stewardship isnt just about
    toxicological testing
  • Product stewardship isnt just for metalworking
    fluids

5
The Definition of Product Stewardship Produc
t Stewardship- integrates health, safety, and
environmental considerations in the design,
manufacture, use, and disposal of products, i.e.
throughout the products life cycle. Health,
safety, and environmental considerations begin
with management of the manufacturing environment,
customer relations and communication. Product
Stewardship supports the employers
responsibility both to provide a safe workplace
for employees and to comply with legal
requirements applicable to product manufacture,
use, and disposal.
6
VisionWhat is LubeCaresm?
  • LubeCaresm is a product stewardship program
    designed to promote continuous improvements in
    health, safety, and environmental performance,
    and to be sensitive and responsive to community
    needs and public concerns by all member
    companies.

7
Objective
  • LubeCare LubeCare is a program developed by
    ILMA to help member companies integrate health,
    safety, and environmental considerations in the
    design, manufacture, use, and disposal of
    lubricant products. LubeCare is a single program
    that identifies six management practices.
  • Implementation of LubeCare Will Benefit Your
    Company LubeCare provides a systematic
    framework to assist member companies manage their
    health, safety, and environmental
    responsibilities. Implementation of LubeCare can
    benefit your bottom line by helping you manage
    workplace safety and health, insurance claims,
    liability risks, customer relations, pollution
    prevention, and product development.

8
6 Management Principles for Product Stewardship
Program
  • Management Commitment
  • Product Development
  • Health, Safety, and Environmental Considerations
  • Management of the Manufacturing Environment
  • Customer Education and Outreach
  • Accountability and Performance Evaluation

9
Management Commitment
  • Goal Commitment to provide leadership and
    resources to a process that integrates health,
    safety, and environmental considerations into the
    design, manufacture, responsible use, and
    disposal of lubricant products.
  • Adopt or Develop Product Stewardship Policy.
  • Conduct Oversight Review.
  • Provide Resource Commitment.
  • Ensure Management Leadership and Commitment.
  • Perform Annual Self-assessment.

10
Product Design
  • Goal Develop information to identify potential
    product hazards and to evaluate risks to
  • Collect supplier hazard information for
    components.
  • Identify product hazards and evaluate product
    risks.
  • Communicate practices for safe use and disposal.
  • Integrate health, safety, and environmental
    considerations into product design.

11
Health, Safety, and Environmental Considerations
  • Goal Internal company understanding of product
    hazards and risks and communication of methods
    for safe use and disposal of products
  • Review hazard communication tools for hazard
    warning, safe use, and disposal.
  • Collect supplier hazard information (i.e., MSDS)
    for components.
  • Assist customers in transmission of product
    information.

12
Management of the Manufacturing Environment
  • Goal Identify and control employee exposure to
    lubricant products and their components in
    accordance with good industrial hygiene and
    safety practices.
  • Manage the manufacturing environment.
  • Identify and control employee exposure.
  • Comply with applicable safety, health, and
    environmental requirements, notably OSHAs Hazard
    Communication Standard. 25 C.F.R.  1910-1200.

13
Customer Education and Outreach
  • Goal Communicate appropriate health, safety,
    and environmental considerations and management
    practices to customers.
  • Assist customers in product selection.
  • Assist customers in product management.
  • Establish and maintain customer relationships to
    foster safe use and disposal of products.
  • Support customer understanding of product hazards
    and use.
  • Assist customer and distributor efforts in the
    use of product stewardship information including
    customer feedback.

14
Accountability and Performance Evaluation
  • Goal Review performance of Product Stewardship
    Program and evaluate relevant new information to
    identify opportunities for continuous
    improvements.
  • Document product and hazard information from
    customers.
  • Evaluate customer information for product hazard
    assessment, product design, and product use.
  • Develop a mechanism for periodic hazard
    communication assessment.
  • Assess all new information relevant to product
    design.
  • Assess LubeCare on a periodic basis.

15
How does product stewardship relate to all
members?
  • While initial focus was on MWF producers,
    lessons learned show great benefit to all
    members

16
Why Have Product Stewardship Program?
  • Regulations
  • OSHA recently announced its endorsement for a
    voluntary product stewardship program by the
    refractory Ceramic Fiber Coalition designed to
    reduce workplace exposures. This program is
    similar to one adopted three years ago by three
    industry associations, which was and also
    endorsed by OSHA.

17
Environmental Regulations will continue to
Increase
  • EU very active, White Paper will result in
    rewrite of regulations putting more
    responsibility on chemical users
  • Will help get at perceived to be problematic
    smaller companies (ILMA-sized!)
  • US will be pressured to follow suit by UAW and
    others
  • ACC Chemicals Management Program will attempt to
    forestall

18
Why Have Product Stewardship Program?
  • Benefits
  • Improved risk management
  • Reduced environmental incidents/community
    complaints (Millennium Chemicals)
  • Allows quick response to public/customer pressure
    on products avoiding de-selection
  • Enhanced reputation with public, industry
    associates and customers

19
Duplicate ProgramsWere already doing that
  • Your already-existing ISO 9001, ISO 14001 or
    QS9000 program provide the perfect platform and
    system to formalize your PS program

20
Compatibility
  • Product Stewardship is complimentary to both
    quality and environmental management programsnot
    a replacement and your QS/ISO program isnt a
    substitute for your PS program.

21
How do we integrate a program?
  • For example, adding customer and your own HSE
    considerations to your already existing Design
    Control elements in ISO 9001 or QS9000 quickly
    takes care of Health, safety, environmental
    considerations

22
Implementation
  • Phased in implementation
  • Workshops for all phases
  • Mentor Program

23
Implementation
  • Review Package Contents - Interim LubeCare
    Manager is Cathleen Barmoy
  • Review LubeCare with appropriate company
    employees
  • Designate a LubeCare Coordinator
  • Submit completed Commitment/Coordinator form to
    Interim LubeCare Manager
  • Present LubeCare to all company personnel, and
    communicate management commitment
  • Use self-assessment checklist to evaluate current
    activity. Identify areas for action
  • Review LubeCare graphic standards guidelines for
    logo use
  • Attend LubeCare Workshop
  • Submit a description of implementation activities
    six months after initiation

24
ILMA Needs to Keep Pace
  • Product Stewardship will help members keep up
    with trends and to get to the next level
  • Chemicals Management-responsible users of
    chemicals
  • Sustainable Development- keep up with Ford, Shell
  • OEM chemical blacklists and health specifications

25
Why Support LubeCaresm?
  • Minimal additional cost incorporate/include
    LubeCaresm in your already-existing ISO 9001, ISO
    14001, QS9000 Program.
  • Makes good business senseLubeCaresm helps
    members
  • Manage their own workplace HSE programs
  • Improve customer relations assist your customers
    through education and outreach
  • Reduce liability risks through program management
  • Incorporate your own and customers HSE concerns
    in your product development program
  • Marketing tool

26
Benefits to ILMA and Members
  • Increased stature as a trade association
    endorsing product stewardship
  • ACC, APCA, API
  • Increased credibility of comments on government
    regulations
  • Forestall the need for regulations in ILMA
    businesses (Ceramic fiber experience)

27
Summary
  • Through the encouragement and dedication of the
    ILMA Board of Directors and the guidance of the
    MWF-PSP, LubeCaresm can integrate health,
    safety, and environmental considerations in the
    design, manufacture, use, and disposal of
    products manufactured by ILMA member companies.
  • The LubeCaresm product stewardship program can
    benefit the bottom line by helping to manage
    workplace safety and health, insurance claims,
    liability risks, customer relations, pollution
    prevention, hazardous waste, and product
    development.

28
Website Links
  • http//www.osha.gov/media/oshnews/feb02/trade-2002
    0214.html - press release 2002
  • http//www.osha.gov/SLTC/metalworkingfluids/metalw
    orkingfluids_manual.html - MWF Guide
  • http//www.osha.gov/media/oshnews/may99/trade-1999
    0518.html - press release 1999
  • http//www.americanchemistry.com/ - click on
    Responsible Care
  • http//www.nacd.com/aboutNACD/
  • http//www.chemed.org/html-index.html
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