PSM (Process Safety Management)
Product
Stewardship encompasses the care of a chemical from "cradle to grave".
The manufacturer of a product has the greatest exposure to liability
and therefore the greatest responsibility for product stewardship. The
manufacturer establishes the level of hazard communication for the
product and directs the future attitude for compliance related to the
material. The wholesaler or distributor is the
second line of defense. Distributors are responsible for ensuring the
chemicals
are in a proper condition for shipment and that the proper technical
information
accompanies the shipment. The distributor should also ensure the
material
handlers are reporting the storage of the chemicals every year in the
form
of SARA Right-To-Know forms. The distributor must also have methods to
ensure
any waste generated is handled correctly.
Although chemical distributors do
not have
the greatest liability associated with a chemical, they are the second
in
line. Regulatory agencies tend to target their fines to the company
with the
deepest pockets; therefore a small manufacturer may be overlooked if
the
distributor is a large company.
RCS, Inc. develops programs specific not only to a
company's types of products, but also to the type of business. The
product stewardship programs that have been developed for chemical
distributors include technical review of shipping information, state
and federal reporting, and proper waste handling procedures. RCS, Inc.
can also act as a representative for the chemical distributor to
discuss technical information with the manufacturer. As a third party,
RCS, Inc. is able to reduce the liabilities involved for both parties.
