What is Product Stewardship, Exactly?

What does product stewardship mean in the business world, exactly? Sometimes it seems to indicate product end-of-life measures, specifically regarding electronics or e-waste policy. Sometimes it is defined as a person to make sure a product is RoHS compliant or otherwise is clean of toxic chemicals such as lead, cadmium and mercury.  Other times it seems to mean a more Sustainability Manager type of role. The fact is that product stewardship can contain all these things and more.

We recently came upon this job description for a Product Stewardship position. We’re running it here to show specific job requirements.

Product stewardship job description. DuPont defines product stewardship as “a principle that directs all participants involved in the life cycle of a product to take shared responsibility for the impacts to human health and the natural environment that result from the production, use, and end-of-life management of the product.”

DuPont, for instance, and this is not atypical, approaches product stewardship through the American Chemistry Council’s Responsible Care program. DuPont sees product stewardship as an “inclusive effort that considers the interests of all important stakeholders, including customers, regulators, academics and advocacy groups.”

Product stewardship software. Product stewardship software is more or less a “steroid infused” chemical counter — or substance audit platform — with the added twist of:

  1. Automating chemical data collection from suppliers.
  2. Screening materials and B.O.M.s against regulatory lists vis a vis REACH, RoHS, WEEE, Prop 65.
  3. Functions such as MSDS distribution.
  4. Other document and agency reporting management.

Increasingly, product stewardship personnel is required to have expertise with related software, just as Finance Administrators are required to have familiarity with financial systems.

DuPont’s Product Stewardship Job Description
DuPont says its vision is to be world class in Product Stewardship and Regulatory efforts and to be recognized as a key contributor to DuPont business success through the development and management of safe, sustainable products.

The average product stewardship annual salary is said to be around $85,000 by Glassdoor.com, but if the regulatory compliance piece is taken seriously it is often higher, into the low six figures. The salaries are respectable relative to other “fields of green,” but there is still some insecurity around how long companies will nurture the stewardship side of manufacturing — so the tenure of these positions, like the tenure of so many positions these days, is indeed a question mark.

Product Stewardship Focus Areas and Responsibilities

  1. Provide a variety of consulting services to the businesses in areas such as the determination of product misuse, product safety, health hazards and potential environmental impacts. Other areas may include advising the businesses on appropriate labeling requirements; facilitating the auditing process at toller, manufacturer and other partner locations and the analysis of public perceptions and reactions to the businesses products.
  2. May oversee implementation of the Responsible Care Management System and Corporate Product Stewardship standards.
  3. May obtain, organize and assemble data and information from various internal personnel, databases, external sources, etc. to enable global regulatory submissions.
  4. Understanding regulatory requirements and the purpose of submissions to ensure compliance with national and state submission requirements.
  5. May Prepare forms, letters, labels and other documents necessary for regulatory submissions.
  6. May develop MSDSs that comply with local standards.
  7. Assisting in the preparation of responses to inquiries from regulatory agencies, customers, internal DuPont personnel, and others.
  8. Assisting in the management of products and/or regulatory projects, including the independent management of sub-projects.
  9. Monitors and analyzes regulatory trends and positions of industry and stakeholder groups.

Job Requirements

  1. Strong networking and leadership skills.
  2. Chemistry, Biology, Science, Public Health, Occupational Health, Toxicology, Environmental Science degrees preferred.
  3. Outstanding problem solving, analytical and interpersonal skills.
  4. Excellent writing/verbal communication and presentation skills.
  5. Accomplished computer skills including Microsoft office and applications and database experience.
  6. Strong work ethic and the ability to work in cross-functional teams to deliver concrete project deliverables in a timely manner.

DuPont says it is an equal opportunity employer, and as of now this job is posted here but these posting come and go so don’t be surprised if the link is broken. We’re not in DuPont’s HR department; we just want to illustrate what product stewardship looks like.

E-Waste: Track Me If You Can

Last October, US EPA Administrator Lisa Jackson visited Giuyu, China, arguably the world’s most famous e-waste site.  Following the visit, attention to the issue of global e-waste has been intensifying.  So has talk of end-of-life product stewardship and regulations thereof.  Such regulations would have huge impact on supply networks in the US and elsewhere.

So far, end-of-life regulations in America have been on a state-by-state level.  Increasingly, there are murmurings of federal, even global, restrictions on disposal. EPA’s end-of-life regulations for electronics would be similar to WEEE but US-based.

Tracking and managing all these moving parts — literally in terms of components and figuratively in the form of data — is poised to become the next great supply network data management challenge.  Keep an eye on waste management facilities and services in the coming four quarters; likely to see new products and services there as well as M&A activity.  This activity comes down to scrambling for product stewardship management and associated dollars.

EPA awards $2.5 million towards e-waste tracking. In March earlier this year, Chelsey Drysdale wrote in PDC&F that environmental groups have been urging the White House Council on Environmental Quality (CEQ) to issue a policy requiring federal agencies not be permitted to export used electronics to developing nations.

Earlier this morning, May 2, 2011, EPA announced it had awarded a grant to the United Nations University (UNU) to help curb rising pollution and health problems associated with discarded electronics.  The agency said the five-year, $2.5 million grant will help authorities track shipments of North American electronic waste and provide support to nations in both Africa and Asia coping with e-waste imports.  Those imports would include end-of-life computers, TVs, and cell phones.

Again:  tracking and managing all these moving parts — literally in terms of components and figuratively in the form of data — is poised to become the next great data management challenge. The good news is that end-of-life tracking is easier than our current challenge of supplier product ingredient visibility [see previous post, “Product Ingredients: say can you see?“].

“The electronics that improve our everyday lives often end up discarded in developing countries where improper disposal can threaten the health of local people and the environment,” said Michelle DePass, assistant administrator for EPA’s Office of International and Tribal Affairs. “EPA recognizes this urgent concern and is committed to working with domestic and international partners to address these issues.”

Is that a regulation?  No.  It is a preliminary call to action for US-based electronics manufacturers and distributors?  Absolutely.

It’s 12:00: Do you know where your e-waste is going?

Track it if you can.

Electronics Stewardship: EPA Creates Task Force

On Nov. 8, 2010, Council on Environmental Quality Chair Nancy Sutley established an interagency Task Force to develop a national strategy and recommendations for improving Federal stewardship of used electronics.  The Task Force was to be co-chaired by the US Environmental Protection Agency, General Services Administration, and Council on Environmental Quality.

Currently, regulation is done on a state-by-state basis.  The map below from EPA may help.

Universal waste regulations can vary between states; and states can add different types of wastes or modify the category.  The map (courtesy EPA) shows the states that have universal waste regulations and which of those states have added different waste categories (in green).

Universal waste is a category of waste materials deemed to be “lower risk” hazardous waste generated by a variety of people.  This waste includes CRTs which includes of course computer monitors, TVs, phones, and similar electronic devices.

Murky? It can be. The point of this federal Task Force is to, among other things, pursue federal legislation and therefore condition and possibly comb out the tangle of provincial law on electronics waste in the US.

Electronics Stewardship Task Force mission. The Task Force mission is towards American businesses, government and citizens working together to manage electronics throughout the product lifecycle — from design and manufacturing through use and eventual recycling, recovery, and disposal.  It’s a bold idea.  The deadline for the group to produce a national framework is May 6, 2011.

By May 6, the Electronics Stewardship Task Force will produce a national framework for:

  1. Directing Federal agencies to exercise all appropriate authorities to achieve the electronic stewardship goals, consistent with domestic and international law.
  2. Developing a system-based approach to the long-term design, management and disposal of Federal used electronics.
  3. Information gathering and tracking, regulatory options, and best management practices for used electronics that can be used by the Federal agencies and leveraged to the private sector.
  4. Building partnerships in the public and private sector for sustainable electronics management nationwide.
  5. Reducing exports of used electronics to developing countries that lack the capacity to properly manage them, and assess how federal agencies can improve their ability to deter these exports.
  6. Building capacity within and share best practices with developing countries, so they can improve their ability to safely handle used electronics, while promoting economic development.

Electronics Stewardship framework background. Unwanted or discarded electronics not reused or recycled represents a lost opportunity to reuse functioning electronic equipment and components, such as cellphone and computers/laptops or recover valuable resources, such as precious metals, plastics or minerals that are found in scarce or critical supply.

Additionally, used electronics may be exported to developing countries that lack capacity to manage them appropriately and result in negative impacts to human health and the environment.

The majority of electronics recyclers in the United States refurbish, repair, or pre-process (demanufacture, shred, sort) used electronics to prepare them for the final recovery step. Facilities that further recover raw materials, through smelting and refining (end-processing), are mostly located outside the United States.

Such facilities can convert electronics scrap into

  1. high grade copper and precious metals (e.g., gold, silver, and palladium),
  2. new CRTs, or
  3. new plastics

all of which can be reused in the marketplace.

The current comment period ended on March 11. There will be another opportunity to comment on the Framework developed by the Task Force after it is delivered to the Council on Environmental Quality, which, again, is slated for May 6, 2011.

Electronics Stewardship current regulation. Currently, there are no federal mandates that require electronics recycling or restrict unwanted electronics equipment from solid waste landfills in the United States.

Bear in mind that EPA does, however, control how cathode ray tube (CRT) monitors (for instance, from TV and computers) are managed domestically – especially if they are subject to hazardous waste regulation. EPA requires notifications if CRT monitors are exported for recycling.

A growing number of states are mandating collection and recycling of used electronics. In addition, there are now two electronics recycling standards and accredited certification and innovative product stewardship software programs that address the handling of used electronics throughout the recycling chain.

For more, see: http://www.federalregister.gov/articles/2011/03/01/2011-4505/solicitation-of-input-from-stakeholders-to-inform-the-national-framework-for-electronics-stewardship#p-56