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Friday, December 30, 2022

Principle Of Product Stewardship




Products and/or services of the organization 

Background

Company XXX is a global manufacturer of polymeric medical grade components and systems for injectable drug delivery, including stoppers and seals for vials, and closures for the healthcare industry.

In view of Company XXX product manufacturing requirements, substantial amount of flammables and hazardous substances were employed in Company XXX operations where this emergency response plan is developed to mitigate the consequences and severity of the foreseeable emergency situations applicable to Company XXX  

Identification of relevant principle of product stewardship in accordance with Company XXX Organizational Procedures

The International Council of Chemical Associations define Product Stewardship as the practice of making health, safety and environmental protection an integral part of the life cycle of chemicals

It is an integral component of the global chemical industry’s Responsible Care® initiative and includes evaluations of risks and the development of actions to protect human health and the environment commensurate with those risks

Product stewardship is a shared responsibility between chemical producers, their suppliers and their customers. It requires the development of close working relationships with suppliers, customers, and others in relevant value chains

The close relationships enabled these parties to share information up and down the value chain to ensure that chemicals are used and managed safely throughout their life-cycle. 

And by doing so, they will also help companies and their partners meet the increasing demand for safe and environmentally-sustainable uses of chemicals.

The benefits of Product stewardship are; it can provides the platform for companies to identify risks at an early stage and manage those risks along the value chain, thereby enabling adequate protection of human health and the environment.  This can result in increased customer loyalty as well as expand the positive impact of product stewardship down the value chain.

Evaluation and avoidance of risk reduces the potential for harm and potential liabilities, making product stewardship a “value added” business proposition

The relevant principles of product stewardship applicable to Company XXX include:

  • Responsible and pro-active management of the environmental ,health and safety aspects of products throughout their entire life cycle;
  • Compare and contrast relations with sustainable development, and corporate social responsibility;
  • Life-cycle considerations for products;
  • An integrated business process involving all, not just a team of specialists;
  • Systematic management of risk at the earliest opportunity in an alert, pro-active, interested and open fashion;
  • A commitment to continually improve EHS performance of its operations;
  • Open communications with interested parties;
  • A means of competitive advantage;
  • Strategic differentiation, leading to enhanced reputation with the authorities, customers, employers and the community at large;
  • Minimize product liability and likelihood of severe adverse issues or publicity

However, in this post, i will briefly explained the principles associated with responsible and pro-active management of the environmental ,health and safety aspects of products throughout their entire life cycle and a commitment to continually improve EHS performance of its operations

Responsible and pro-active management of the environmental, health and safety aspects of products throughout their entire life cycle

This principle require the top management commitment in the reduction of the environmental, health and safety impacts of products throughout their entire life cycle, which would requires a thorough life cycle assessment from manufacture of parts and products to transport, use by customers (e.g. reduced power consumption) and final disposal.

A system has to be established to clarify the environmental, health and safety impact of products throughout their life cycles. This include tracking the total life cycle costs such as the costs of purchasing, transporting, storing, treating and disposing of materials, the loss of man hours and loss workdays due to recordable injury recorded as well as the compensation to employees for their occupational diseases arising from work and the insurance premiums paid by the organizations under the Work Injury Compensation

Collection of information relating to number of occupational diseases as well as the number of recordable injuries rate reported in the manufacturing site as well as the CO2 emissions and energy and resource consumption at each stage of the life cycle

With the availability of these information, it would enables Company XXX to identify products and stages with high environmental, health and safety impacts, clarify improvement priorities and prepare the HSE goals, objectives and targets. And this would in turn assist WPSS  to monitor the environmental, health and safety impact of all its products.

A commitment to continually improve EHS performance of its operations

This principle would require the top management leadership and accountability to ensure it’s business units commitment and involvements to continually improve EHS performance of it’s operations which include:

  • Management demonstrates that EHS issues rank amongst the highest priorities and maintains a commitment to continuous improvement.
  • Business units to defines its Product Stewardship plan with appropriate targets and performance measures which are reviewed at least annually to maintain continuous improvement. Performance measures are broken down to annual employee target setting.
  • Establishment of appropriate systems and procedures to manage EHS risks throughout the product life cycle, collecting information on the product's EHS hazards, assessment of employee and Customer EHS exposure
  • Provision of training to employees and customers where the training scope may include the job function, with the objective of safe development, manufacture. storage, handling, transport, use and disposal of products.
  • Communicate openly and honestly with employees and the public and be anticipative and responsive to their concerns about the potential hazards and impacts of products.
  • Enforce the application of the Product Stewardship principles to all organization activities and to comply with all local EHS legislation and participate proactively in the development of local laws and regulations in all countries in which the Company has business activities

Audit CAPA Implementation

 

TRACKING /MONITORING THE IMPLEMENTATION OF CORRECTIVE AND PREVENTIVE ACTIONS

To track the effectiveness of implementation of the WSH audit corrective and preventive actions , the auditors use an excel spreadsheet as the tracking mechanisms to track the closure of the corrective actions and preventive actions

Required information to be track may include:

·         Responsible person

·         Target completion date of corrective measure implementation

·         Status

·         Proposed corrective/preventive actions

·         Audit findings

The SHMS audit criteria is based on the Singapore Standard SS 506 Part 3 : 2006 Occupational safety and health (OSH) management system – Requirements for the chemical industry, and in accordance with the relevant WSH legislation and guidelines set out for each industry

S/N

SHMS Element

Audit Findings

Proposed Corrective /Preventive Actions

Person Responsible

Target Completion date

1

Safety policy

Company XXXX Safety Policy is an adoption of its parents company Safety Policy in US and hence the policy may not be appropriate to the nature and scale of its Singapore operation and its workforce culture

To establish a safety policy which  is appropriate to the nature and scale of its Singapore operation, its workforce culture and comply with Singapore Standard SS 506 Part 3 : 2006 Occupational safety and health (OSH) management system – Requirements for the chemical industry

Chief Executive Officer, Mr XXXX

End Dec 2013

 

2

Safe work practices

Established risk assessment is done by individual department with no cross functional collaboration to ensure no hazards/risks is left unidentified

Company XXXX  should establish a risk assessment team which is made up of cross functional employees with different background, knowledge and experience with the objective to ensure that no hazards from any aspect are left undetected and adopt a 5x5 risk assessment matrix to better classified its risk levels.

Equipped the risk assessment team with the relevant practical knowledge on risk management and to formulate the safety rules and regulations taking into consideration the current WSH behaviour of its employee, the WSH performance and changes in the WSH regulations and other related legal requirements

XXXX, CEO

YYYY, Senior management level staff

KKKK HR Training Manager

WSHO Willy Lee

End Dec 2013

3

Safety training

No training budget to improve current WSH performance

WSH Training needs of west managers level staffs were neglected

Company XXXX  CEO to set some money aside as the HSE training budget ,establish the training needs analysis of its managers by conducting an internal training survey , analyse the results and collaborate with its WSHO to identify the training needs of it’s manager level employees by referencing to the Factories ( Safety Training Order) Regulations  and the WSH training for managers may  include

a)Safety and Health Management system audit

b)Quantitative Risk Assessment

c)Project Management

d)Behaviour safety management  etc

XXXX, CEO

 

YYYY, Senior management level staff

 

KKKK, HR Training Manager

 

WSHO Willy Lee

end Dec 2013

4

Group Meeting

No training budget to improve current WSH performance

WSH Safety Committee team members are not trained and not competent to assume their roles as WSH Safety committee team member

Company XXXX  to define the serving period of its nominated WSH safety committee team members

 

Company XXXX  CEO to set some money aside as the HSE training budget , establish procedure in analyzing the training needs of their WSH Safety Committee team and  to provide them with the relevant training to build their attitude ,skills and knowledge to make them competent to assume their role as WSH safety committee team members helping west to proactively manage its workplace WSH.

And to define the WSH safety committee team member serving period to maximum one year with the objective to expose more  Company XXXX employees  CEO to discuss with senior management level staff on the allocation of safety budget to improve the workplace WSH competency and performance

XXXX, CEO

 

YYYY, Senior management level staff

 

KKKK, HR Training Manager

 

WSHO Willy Lee

End Dec 2031

5

Incident investigation and analysis

No training budget to improve current WSH performance

Incident investigation team not trained on basic investigation skills and the use of investigation tools

Company XXXX  CEO to set some money aside as the HSE training budget , establish procedure in analyzing the training needs of their Incident investigation team and  to provide them with the relevant training to build their attitude ,skills and knowledge to make them competent to assume  their roles

XXXX, CEO

YYYY, Senior management level staff

KKKK, HR Training Manager

WSHO Willy Lee

 

6

Safety Inspection

No training budget to improve current WSH performance of the WSH Safety Committee team

 

Company XXXX  CEO to discuss with senior management level staff on the allocation of safety budget to improve the workplace WSH competency and performance and   Company XXXX  CEO to set some budget aside as the HSE training budget

XXXX, CEO

YYYY, Senior management level staff

KKKK HR Training Manager

WSHO Willy Lee

 

7

Hazard Analysis

No cross functional risk assessment team formed to assess west departmental risk assessment

 

Company XXXX  CEO should look into establishing and formation of a risk assessment team which comprises of employees across cross functional department to ensure no hazards/risks are being oversight or left unidentified

Adopt a 5x5 risk assessment matrix to better represent the identified hazards /risks associated with their manufacturing  and equip the risk assessment team members with the relevant practical knowledge in risk management            West CEO to discuss with senior management level staff on the allocation of safety budget to improve the workplace WSH competency and performance

XXXX, CEO

YYYY, Senior management level staff

KKKK, HR Training Manager

WSHO Willy Lee

 

 




TARGET SCHEDULE FOR COMPLETION OF ACTION ITEMS

The target schedule for completion of action items have been established after consultation with  the  Auditee management representative and it’s responsible persons following up on the action items and also after taking into consideration audit findings that have a high or critical associated risk rating, or lower

 Schedule for completion of action items are tabulated below

PERSONS RESPONSIBLE FOR ACTION ITEMS

For an organization Safety and Health Management System to be effective, it must have the commitment from the top management and the commitments from different level of employees within the organization hierarchy

Based on this principle, the persons responsible for following up on the action items have been established and tabulated as follows:

Name of Auditee : Company XXXX

Date of Assessment: 20 Jul 2013

Audit Team Members: Lead Auditor XXXX, Team Auditor YYYY

 

SHMS Elements

Corrective Action

Preventive Action

Responsible Person

Safety Policy

To establish a safety policy which  is appropriate to the nature and scale of its Singapore operation, comply with Singapore Standard SS 506 Part 3 : 2006 Occupational safety and health (OSH) management

system – Requirements for the chemical industry

 

 

Development of the safety policy shall taking into consideration the

current WSH behaviour of its employee, the WSH performance and changes in the WSH regulations and other related legal requirements and establish realistic and measurable WSH goals, objectives and target

 

Identify one senior management level staff to oversee the development and establishment of the safety policy and reporting periodically the progress and achievement

XXXX, CEO Company XXXX

Safe Work Procedure

Company XXXX t should establish a risk assessment team which is made up of cross functional employees with different background, knowledge and experience with the objective to ensure that no hazards from any aspect are left undetected and adopt a 5x5 risk assessment matrix to better classified its risk levels.

 

Equipped the risk assessment team with the relevant practical knowledge on risk management and

to formulate the safety rules and regulations taking into consideration the current WSH behaviour of its employee, the WSH performance and changes in the WSH regulations and other related legal requirements

Company XXXX CEO to discuss with senior management level staff on the allocation of safety budget to improve the workplace WSH competency and performance

 

Identify one senior management level staff to oversee the formation of cross functional risk assessment team

 

Setting of KPI on employee WSH competency and prescribe WSH goals, objectives and target to stimulate WSH performance

XXXX, CEO Company XXXX

YYYY, Senior management level staff

 

WSHO Willy Lee

Safety Training

Company XXXX to set some money aside as the HSE training budget ,establish the training needs analysis of its managers by conducting an internal training survey , analyse the results and collaborate with its WSHO to identify the training needs of it’s

manager level employees which may  include

 

a)Safety and Health Management system audit

b)Quantitative Risk Assessment

c)Project Management

d)Behaviour safety management  etc

Company XXXX CEO to discuss with senior management level staff on the allocation of safety budget to improve the workplace WSH competency and performance

 

Identify one senior management level staff to oversee the conduct of the survey, analyse of survey results and collaborate with WSHO to identify the training needs of it’s manager level employees

 

Set KPI on managerial WSH training to stimulate WSH performance

XXXX, CEO Company XXXX

 

YYYY, Senior management level staff

 

KKKK HR Training Manager

 

WSHO Willy Lee

Group Meeting

Company XXXX CEO to set some money aside as the HSE training budget , establish procedure in analyzing the training needs of their WSH Safety Committee team and  to provide them with the relevant training to build their attitude ,skills and knowledge to make them competent to assume their role as WSH safety committee team members helping west to proactively manage its workplace WSH.

 

And to define the WSH safety committee team member serving period to maximum one year with the objective to expose more west employees 

West Company XXXX CEO to discuss with senior management level staff on the allocation of safety budget to improve the workplace WSH competency and performance

 

Identify one senior management level staff to oversee the conduct of the survey, analyse of survey results and collaborate with WSHO to identify the training needs of the WSH Safety Committee team members and equip the team member with the relevant training to make them competent to assume their roles

 

 

XXXX, CEO Company XXXX

 

YYYY, Senior management level staff

 

KKKK HR Training Manager

 

WSHO Willy Lee

Incident Investigation and Analysis

Company XXXX CEO to set some money aside as the HSE training budget , establish procedure in analyzing the training needs of their Incident investigation team and  to provide them with the relevant training to build their attitude ,skills and knowledge to make them competent to assume  their roles

 

Company XXXX  CEO to discuss with senior management level staff on the allocation of safety budget to improve the workplace WSH competency and performance

 

Identify one senior management level staff to oversee the conduct of the survey, analyse of survey results and collaborate with WSHO to identify the training needs of the incident investigation team members and equip the team member with the relevant training to make them competent to assume their roles

 

 

XXXX, CEO Company XXXX

 

YYYY, Senior management level staff

 

KKKK HR Training Manager

 

WSHO Willy Lee

Safety Inspection

Company XXXX CEO to set some money aside as the HSE training budget , establish procedure in analyzing the training needs of their WSH Safety Committee  team members and  to provide them with the relevant training to build their attitude ,skills and knowledge to make them competent to assume  their roles

 

Company XXXX CEO to discuss with senior management level staff on the allocation of safety budget to improve the workplace WSH competency and performance

 

Identify one senior management level staff to oversee the conduct of the survey, analyse of survey results and collaborate with WSHO to identify the training needs of the incident investigation team members and equip the team member with the relevant training to make them competent to assume their roles

 

 

XXXX, CEO Company XXXX

 

YYYY, Senior management level staff

 

KKKK HR Training Manager

 

WSHO Willy Lee

Hazard Analysis

Company XXXX should look into establishing and formation of a risk assessment team which comprises of employees across cross functional department to ensure no hazards/risks are being oversight or left unidentified

 

Adopt a 5x5 risk assessment matrix to better represent the identified hazards /risks associated with their manufacturing  and equip the risk assessment team members with the relevant practical knowledge in risk management

Company XXXX CEO to discuss with senior management level staff on the allocation of safety budget to improve the workplace WSH competency and performance

 

Identify one senior management level staff to oversee the conduct of the survey, analyse of survey results and collaborate with WSHO to identify the training needs of the incident investigation team members and equip the team member with the relevant training to make them competent to assume their roles

 

 

XXXX, CEO Company XXXX

 

YYYY, Senior management level staff

 

KKKK HR Training Manager

 

WSHO Willy Lee

 

VERIFICATION OF EFFECTIVENESS AND CLOSURE OF ACTION ITEMS

At this stage, The HSE Consultancy and Training Pte Ltd  Auditors are not able to verify the
effectiveness of the implemented control measures and closure of the action items

Follow up post audit meeting will be scheduled with West to verify effectiveness of the
implemented control measures and closure of the action items.

A)Reduced WSH risks, if not eliminated

Comparison between the residual risk level before and after the implementation of the action items will be used as a criteria in verifying the effectiveness of the action items. The comparison results should show that the after control measure implementation should yield a lower number of accident or injury or near-miss cases if the control measures implemented are effective in reducing the WSH risks, if not eliminated

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