It is key for Kemira that all of its products are safe to use by customers and provided to them with the appropriate registrations, documentation, and labeling.
Kemira focuses on meeting the requirements and regulations set by the Registration, Evaluation, Authorization and Restriction of Chemicals (REACH), the Classification, Labeling and Packaging of substances and mixtures (CLP) regulations in Europe, and the Globally Harmonized System of Classification and Labeling of Chemicals (GHS).
The year 2012 has been a period of preparation for the upcoming regulatory developments:
- REACH: Kemira continued preparations for its second phase-in registration deadline in June 2013. The third deadline of REACH in the EU is coming up in 2018.
- GHS: Kemira has worked on approximately 25% of its products on a global scope to determine the classifications accordingly.
- CLP: Preparations for reclassification and relabeling in the EU by June 2015 continue; Kemira's target is to have more than 50% of its products ready by the end of 2013.
In addition to the above, Kemira closely follows regulatory developments on its markets and takes action when there is any development requiring attention.
Communicating the hazards and correct handling
Kemira communicates the hazards and correct handling of chemicals mainly by product labeling and Safety Data Sheets (SDS). Kemira also voluntarily discloses safety data sheets for its non-hazardous products. Read more about product labeling in the 2011 Annual and Sustainability Report.
In 2012, Kemira registered 118 complaints related to labeling, examples of which include missing or incorrect labels. Additionally, there were 123 complaints relating to documentation, including Certificate of Analysis (COA) missing from the delivery and an incorrect product name in the safety data sheet. The complaints registered in 2012 were approximately on the same level as in 2011 (118 complaints related to labeling, 137 complaints related to documentation).
In 2012, a US subsidiary of Kemira reached a settlement with the U.S. Environmental Protection Agency regarding alleged violations of the Federal Insecticide, Fungicide, and Rodenticide Act and for other minor reporting discrepancies. While Kemira contends that the allegations of non-compliance are not valid, Kemira cooperated fully with the EPA to resolve and address their concerns. Two of the allegations related to product labeling and involved a distributor of Kemira who sold products under brand names without prior approval from Kemira. The EPA determined that none of the alleged violations ever presented any risk of harm to human health or the environment. Under the terms of the settlement, Kemira has corrected the alleged violations and has paid a civil penalty.
Compliance at the earliest stage of product development
To ensure that regulatory requirements are identified at the earliest stage, compliance reviews are required before proceeding with any New Product Development (NPD) process. The process also aims to identify less hazardous and more sustainable alternatives.
During 2012, Kemira initiated a project for a new workflow-type of system to manage its initial product safety review process in the new product commercialization phase more effectively. The implementation was postponed due to the restructuring of the company, and will be finetuned according to the new organizational structure and competencies during 2013.
Management of Product Safety
As of October 1, 2012, Kemira's product safety function was restructured and renamed as Product Stewardship and Regulatory Affairs. The function is managed globally but increasingly focuses on regional operations. Kemira aspires to develop more intelligent ways of globally managing regulatory information, the requirements for and implementation of which vary from country to country. During 2013, there will be more emphasis on fully implementing the new organizational structure and ways of working regarding product safety throughout Kemira.
In 2012, Kemira strengthened its regulatory team in Asia to better respond to the business needs in the APAC region. In South America, SAP implementation project is ongoing to integrate the safety information for the local products into Kemira's global ERP system by mid-2013.