1. PRODUCT STEWARDSHIP Code of Practice GCWellon June 2010

2. PRODUCT STEWARDSHIP Definition Product Stewardship is the shared responsibility for understanding, managing and communicating the impacts to human health and the environment through the life cycle of chemical products. This life cycle involves the development, production, use, distribution and end-of-life management of products.

3. PRODUCT STEWARDSHIP CODE

4. Purpose & Scope  make health, safety and environmental protection an integral part of designing, manufacturing, marketing, distributing, using recycling and disposing of our products

5. PRODUCT STEWARDSHIP CODE Purpose & Scope  shared responsibility; everyone involved with the product – address society’s interests in a healthy environment and products that can be used safely  employers responsible for providing a safe workplace  people who use and handle products must follow safe and environmentally sound practices

6. PRODUCT STEWARDSHIP CODE Purpose & Scope  “each company must exercise independent judgment and discretion to successfully apply the code to its products, customers and business”

7. PRODUCT STEWARDSHIP CODE Relationship to Responsible Care © Guiding Principles  6 out of 10 RC Guiding Principles are directly related to PS

8. PRODUCT STEWARDSHIP CODE Management Practices  3 general categories: o Management Leadership and Commitment o Information & Characterization o Risk Management  Total of 12 Management Practices outlined in the Product Stewardship Code

9. PRODUCT STEWARDSHIP CODE Management Practices: Management Leadership & Commitment 1. Leadership :  written policy; active participation; communication

10. PRODUCT STEWARDSHIP CODE Management Practices: Management Leadership & Commitment 2. Accountability :  establish goals; measure performance

11. PRODUCT STEWARDSHIP CODE Management Practices: Management Leadership & Commitment 3. Resources:  commit necessary resources

12. PRODUCT STEWARDSHIP CODE Management Practices: Information & Characterization 4. HSE Information:  establish & maintain information on HSE hazards; new & existing products

13. PRODUCT STEWARDSHIP CODE Management Practices: Information & Characterization 5. Product Risk Characterization:  characterize product risk using HSE information

14. PRODUCT STEWARDSHIP CODE Management Practices: Risk Management 6. Risk Management System:  system to identify, document & implement HSE risk- management actions

15. PRODUCT STEWARDSHIP CODE Management Practices: Risk Management 7. Product / Process Design & Improvement:  consider HSE impacts during design, development and improvement

16. PRODUCT STEWARDSHIP CODE Management Practices: Risk Management 8. Employee Education & Product Use Feedback:  train employees – handling, recycling, use, disposal  encourage employee feedback – uses, misuses, adverse effects

17. PRODUCT STEWARDSHIP CODE Management Practices: Risk Management 9. Contract Manufacturers:  select / work with contract manufacturers who use appropriate HSE practices  provide information & guidance – handling, recycling, use, disposal  review performance

18. PRODUCT STEWARDSHIP CODE Management Practices: Risk Management 10. Suppliers:  require suppliers to provide HSE information and guidance on their products  consider HSE practices when making procurement decisions

19. PRODUCT STEWARDSHIP CODE Management Practices: Risk Management 11. Distributors:  provide HSE information to distributors  select / work with / review distributors – use, handling, recycling, disposal; transmit information to downstream users

20. PRODUCT STEWARDSHIP CODE Management Practices: Risk Management 11. Distributors: (continued)  work to improve improper practices  if necessary improvements are not made, consider termination of business relationship

21. PRODUCT STEWARDSHIP CODE Management Practices: Risk Management 12. Customers, Other Direct Product Receivers:  provide HSE information  foster proper use, handling, recycling, disposal and transmittal of HSE information to downstream users

22. PRODUCT STEWARDSHIP CODE Management Practices: Risk Management 12. Customers, Other Direct Product Receivers : (continued)  work to improve improper practices  if necessary improvements are not made, consider termination of product sale

23. PRODUCT STEWARDSHIP CODE