Data Management for Stewardship Programs
Product stewards have to know what’s in their products, for a number of reasons. The most obvious is regulatory compliance, but market drivers also play a role. For instance, some industries require companies to back their claims of ‘greenness’ with disclosures, even if not required by law.
An effective way to meet regulatory and market demands is to build a regulatory data program. Angela Wutz, assistant general manager at Pace Analytical Services, offered advice on how to build one during the presentation Stuck in the Middle: The challenges of getting and sharing regulatory data at Stewardship 2015.
Communicating with the supply chain is perhaps the most challenging part of building a data program. That means building relationships with suppliers, which sounds simple but is actually difficult, said Wutz. It means identifying the person who has the information you need and connecting with them personally, even if that means picking up the phone. From there, start by explaining why you’re asking for the information and how you want to use it.
A complementary method is to request 100 percent disclosure when you create POs with new suppliers. If they balk at the request, then you have to evaluate the business risk tied to working with them. Ultimately, try to work with suppliers who want to help you, said Wutz. A good time to start the information-gathering process is during product development.
She recommended that product stewards create an attribute database built on composition disclosure, compliance certification, substance disclosure, and safety data sheets. It helps beforehand to consider what customers are asking for. “This is a big process, and it’s not necessarily a straightforward process,” said Wutz, but it’s a prerequisite to moving forward with a program.
To gather the information, product stewards should create and follow a consistent process for collecting and organizing the information. Wutz pointed out that fewer questions on the form mean someone is more likely to fill it out, so don’t ask for more information than you need. If you know a product is only going to be sold in the U.S., for instance, don’t ask suppliers about Japanese regulations. “Ideally your form should be really user friendly,” said Wutz.
Once the information is gathered, store it somewhere electronic. “This seems really obvious, but you need to put it all the data in the same place,” said Wutz. “You want to make it searchable and if possible link to your other product stewardship activities.” The next decision is how to share the information and with whom? “If you share something, it might no longer be private,” said Wutz, so consider whether the information should be available in an SDS, through a customer-only web portal or some other means.
Finally, keep the information up-to-date. Wutz suggested adding a clause to purchasing contracts that requires suppliers to notify you if they change the product. Another clue that something has changed is when suppliers send new SDSs, because they don’t usually change unless the product has changed.
Done right, a data management program can be a risk mitigation strategy for a company, led by its product stewards, said Wutz, but only if you can state with confidence that you’re in compliance and monitor products for emerging issues. And you can only do this if you know what’s in your materials.