Risk Management and Communication
Risk Management and Communication in the Value Chain
Forms of communication with the value chain is dependent upon mechanism chosen for risk management which is primarily the result of the degree of risk identified.
Safety Data Sheets
The hazards and basic mechanisms for dealing with the identified hazards are communicated to all customers via Safety Data Sheets (SDSs). All Safety Data Sheets include phone numbers, email address, and physical addresses where customers can direct questions they may have concerning information provided on each product. Thus direct communication is always available on the hazards and risk of each product.
Voluntary Emission Control Action Program (VECAP)
Albemarle is committed to minimizing risk from leakage, personnel exposure and environmental impact associated with the distribution and use of brominated flame retardants. This program includes: 1) requirements of the customer in handling and using brominated flame retardants, and 2) services offered by Albemarle to assist customers in utilizing brominated flame retardants in a safe and environmentally acceptable manner. The program includes sharing the following with customers; 1) best practices for storing and unloading bags, 2) best practices for unloading tote bins, 3) customer evaluation and baseline potential emission calculations, and 4) customer service (training and design/engineering support. VECAP is a global voluntary initiative.
Distribution Risk Assessments
Albemarle has established a Distribution Risk Assessment Team (DRAT) to evaluate new and existing systems for transportation of hazardous products. The DRAT conducts Vulnerability Assessments on the distribution and value chain activities for all hazardous products. A hazard ranking process identifies both new and existing raw materials and final products to be considered for DRAT evaluation. These identified raw materials or final products are then further prioritized by exposure criteria and then combining the two to determine an overall risk ranking. The DRAT conducts an overall evaluation of the shipping process and prepares recommendations, if necessary, to the overall risk of the material shipping process.
US Significant New Use Rule Compliance
Where products in the United States are regulated by a Significant New Use Rule (SNUR), new customers are sent a letter summarizing the requirements under the SNUR. Since EPA has determined these products require some form of risk management when handled in the United States, this additional communication is provided on these products. Again these letters contain a name and phone number to contact for further information on those requirements. Again this process provides an open line of communication for the customer on these products where they have questions.
Product Stewardship Programs
For certain products or families of products, Albemarle has determine the hazards or risks of the product warrant a high degree of stewardship with downstream customers. For these products a Product Stewardship Manual is written which details the stewardship activities for each of the products or groups of products. These Product Stewardship programs are led by the Product Manager for the product and executed by different company resources depending upon the activity. The products stewardship program for the products may include equipment specifications, qualifications for carriers, customer handling and use instructions and emergency response mechanisms. Communications to customers for these products is through audits of the handling facilities at the customer locations, documentation of incidents and the investigation of the incidents, and customer visits for on-site review of the proper equipment, facilities and handling as laid out by the Product Stewardship program.