Product stewardship

Elkem defines Product Stewardship as an integrated business process for identifying, managing, and minimising the health, safety, environmental and regulatory risks through all the stages of a product’s life in the best interest of society.

Proactive management of use of chemicals and the protection of the environment and the human health are fundamental pre-requisites for conducting our business and securing our licence to operate.

The Elkem product stewardship policy.

Product regulatory compliance

The manufacturing and sales of chemicals are widely regulated around the world. The ability to follow-up on the regulatory development is pre-requisite for business compliance and plays a key role when ensuring the product safety for customers in the value chain and for other stakeholders. Compliance with chemical product regulations include product registrations, product authorisations, safety data sheets and product labels. There are also application-specific regulations that Elkem complies with, for example for products that are in contact with food and water (packaging) or health care (band aid/wound care).

With a portfolio of more than 4,000 different products that are used in a multitude of applications, regulatory and product compliance is key for Elkem. The document management system OSCAR has been implemented in the Silicones division and ensures that compliance, certificates and regulatory statements are easily available for distribution to customers.

Elkem is committed to ensure product safety and to comply with international regulatory requirements and provides safety data sheets (SDS) for all products in accordance with the UN Globally Harmonized System of Classification and Labelling of Chemicals (GHS).

Product substance management

Elkem works to ensure safe handling, use and disposal of our products. Product stewardship is thus the responsible and proactive management of health, safety and environmental aspects of a product throughout its lifecycle.

In all markets where Elkem’s products are promoted, the products must meet specific requirements and comply with certain technical, regulatory, health and environmental standards. We make sure to stay up to date with any REACH obligations for all our products to ensure a high level of protection of human health and the environment. Article 33 of REACH requires suppliers of articles (manufacturers or importers) to inform European downstream users about the presence of substances of very high concern (SVHC) when their concentration exceeds 0.1% (w/w).

Elkem regularly monitors its product portfolio for SVHC substances that are subject to existing or future regulatory requirements or that are associated with particular concerns. We review our management plans regularly defining the specific risks associated with each identified SVHC substance. We review all possible options to mitigate identified risks including possible substitution where possible, phasing-out any substance posing an unacceptable risk to human health and/or the environment or limiting the exposure of the SVHC substance if substitution is not deemed possible. In addition to comply with all chemical production regulations, the Silicones division is a signatory of the Responsible Care Global Charter of the International Council of Chemical Associations (ICCA).

Elkem has three main product areas where SVHC occur:

• In carbon products: high temperature coal tar pitch (CAS no. 65996-93-2) is used as an intermediate in the production of Söderberg electrode paste.
• In silicones: D4, D5 and D6 are key intermediates in the production of silicones-based polymers. In addition, some other and essential SVHC substances are used under strict conditions in a limited number of products.
• In silicon products and ferroalloys: those are made from natural raw materials such as quartz, coal, and iron oxide that often contain trace amounts of heavy metals. Cadmium and lead are listed as SVHC but their concentrations in Elkem’s products are far below the generic threshold limit value of 0.1 % w/w and do not trigger regulatory action.

Elkem is committed to minimise the use of all substances of very high concern (SVHC) and actively seek to replace substances and assess safer alternatives in the product portfolio.

Chemical safety

Through participation in the Responsible Care programme, Elkem is committed to manage chemicals safely throughout the life cycle. This includes both proactively identifying and managing chemical risks and concerns throughout our operations and replace substances in the portfolio that pose unacceptable risk to human health, safety and the environment.

As such Elkem is committed to the following principles:

• COMPLIANCE: comply with all applicable chemical regulatory requirements in the countries where we either manufacture and/or sell chemicals.
• PROACTIVE: perform regulatory compliance reviews for all New Product Development as well as all product launches.
• LIFE CYCLE MANAGEMENT: assess regulatory compliance, human health, safety as well as environmental protection aspects from raw materials sourcing through production, use and disposal.
• REACT/MONITOR: proactively identify and manage chemical risks and concerns throughout our operations.
• REDUCTION or SUBSTITUTION: To replace or reduce raw materials and products in the portfolio that would pose an unacceptable risk to human health, safety or the environment within a reasonable amount of time.
• COMMUNICATION: To share information with our stakeholders about the health and safety aspects of products and to ensure that our customers can safely use our products.