What Benchmarks Should a Product Steward Audit Against?

As more companies adopt product stewardship programs and processes, they’re confronted with a new question: Are we sticking to them?

If that question were about facility or corporate-level EHS processes, companies could find the answer through an audit process with established criteria, benchmarked against mature regulations and requirements. But the regulations impacting stewardship efforts are still relatively new and constantly evolving. As such, the audit process is also evolving.

When you do a product stewardship audit, you really need to evaluate everything from cradle-to-cradle,” says Maryann Sanders, senior regulatory compliance specialist at Haley & Aldrich Inc. “You need to know the regulations associated with not only your jurisdiction but where you're selling your products, and if you want to have a new market, you need to make sure that your products are compliant in those new markets as well.”

One good reason to conduct audits is to avoid supply chain disruption. “You may not be able to get supplies to make your product because your supplier may not be able to produce their product due to non-compliance to the regulations in their country or because those products may not meet your countries regulatory requirements,” says Sanders.

Sanders and Cheri Kedrowski, senior technical manager at 3M Medical Department, will lead a discussion about product stewardship audits and best practices during Scope and Process for Performing a Product Stewardship Audit at Stewardship 2016. As part of the discussion, they’ll emphasize the importance of cooperation between departments. “You'll have to talk to sales to find out where they're sending things to. You need to talk to marketing to make sure they don't make false label claims. A lot of regulations are based on volume, so you also need to talk to procurement,” says Sanders. “When you're doing a product stewardship audit, it really involves a lot of people.”