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Product Stewardship Management System (PSMS) - version 2

Specifies requirements customized to Syensqo corporate policies & internal procedures and standards and the Product Safety Code of ACC.

PSMS is to be used as a self-assessment tool for the GBU in order to evaluate compliance related to Product Safety.





currently under revision v3.0

to include the last version of the Product Safety Code (S12025S1 2025)

Easy tool proposed to GBUs  for your PSMS Self-assessment  updated according to PSMS v2
**  in each GBU file below **

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titlePSMS GBUs Self assessments (Restricted access)

Training


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Key documents (to come)


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FAQ


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titleFAQ ( ! updated ! april 2020)

General :

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titleWhat is PSMS ?

PSMS means Product Stewardship Management System; it is a Syensqo Group Referential describing in 4 levels regulatory and voluntary requirements in the Product Stewardship domain.

PSMS is considered to be used as a self­-assessment tool for the GBUs, in order to evaluate compliance related to Product Safety and to give support to establish long and short term improvement plans.

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titleIs PSMS Referential aligned with internal policies or external procedures ?

The PSMS is aligned with the Solvay Corporate Product Stewardship Policy, procedures, standards and guidelines; it is also in line with the Product Safety Code of the American Chemistry Council (ACC).

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titleIs Corporate R&I included in the PSMS scope ?

Corporate R & I is not included in the scope at the time being because some requirements may not apply directly. Anyway many of PSMS requirements are included in the WEGO process used in corporate R&I.

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titleHow is the PSMS evaluation performed for a GBU operating in different zones of the world ?

For GBUs operating in different zones, the self­-assessment can be performed by zone and afterwards the scoring for the overall GBU can be calculated.

For level basic, GBU scores 1 only if each zone fulfills all basic requirements. The GBU can decide to define an action plan per zone or for the GBU WW.

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titleWhat is the minimum level to be archieved and in which timeline ?

The requirements listed at basic level (level 1) should be addressed as a minimum in all zones where the GBU operates.

An action plan with a deadline of 12 months has to be developed when the basic level is not achieved (score =1)

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titleHow to evaluate PSMS scoring ?

In order to help the GBUs to score their PSMS, a simple decision table is inserted in the self­-assessment tool.

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titleShould the PSMS self­-assesment be transmitted to PRAPS ?

The PSMS self­-assesment assessment should be transmitted to PRA/PS Product Stewardship Team in order to ensure a minimum harmonization in the evaluations and provide support and advice to GBUs for requirements which show most discrepencydiscrepancy. This information will not be publicly available and will not be used to rank the GBUs. It will also give the possibility to share good practices.

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titleIs there a tool to formalize the self­-assesment ?

Yes, a Google Sheet tool based on PSMS requirements is available on this HSE PSMS page. Each GBU has a dedicated folder with restricted access.

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titleHow to evaluate requirements refering to procedures not yet released ?

Requirements refering referring to procedures or guidance not yet released can be scored as “not applicable” until their publication.

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titleHow often is PSMS evaluation required ?

The PSMS self­-evaluation review is mandatory at least every 3 years (PSMS chapter 11 level 1) but self-evaluation is recommended every year in order to follow ­up the defined action plan.


On PSMS requirements :

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titleChapter 1.1 level 2 - “ICCA Responsible Care Global Charter and Solvay Responsible Care Policy are widely communicated to all appropriate levels involved in product stewardship”

A specific GBU PS Policy is not mandatory but should be at least included in the GBU Policy. “Appropriate levels” within the GBU means at least, to the management team of product stewardship, industrial, supply chain, business and sales, purchasing organizations...

 

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titleChapter 1.2 level 1 - “Objectives, KPIs and targets are reviewed periodically, and at least once a year, by the GBU management team.”

KPI = Key Process Indicator examples : ­

  • % REACH dossiers registered in due time ­ number of risk level 1 sheets resolved within the year ­
  • % Products priority 1 (or families) assessed in PSMP/HCRM process

  • Number of Risks level 1 identified in PSMP/HCRM assessments

  • % Safety Data Sheets < 3 years ­
  • % deliveries without SDS in spite they are needed (% due to absence of SDS / incorrect language / incorrect address) ­
  • % customer requests answered within defined timeframe (see guidelines PSMS 1.2)

  • Average score of GBU's PSMS Assessment (score between 1 and 4)

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titleChapter 1.3 level 4 - “Progress in implementing long term plans point clearly to a world class program of Product Stewardship.”

Examples of world class programs : programs which integrate life cycle assessments, circular economy,...

 

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titleChapter 2.1 level 4 - “The organization is continuously improved by benchmarking.”

Benchmarking can be internal (such as best practices in other GBUs) or external (comparaison with other companies and organisations) in the field of global organisation, interfaces, missions,...

 

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titleChapter 2.1 level 3 - “The organization is periodically evaluated and updated.”

The organization can be evaluated for example through a survey sent to internal customers followed by an appropriate action plan, or through feedbacks from the persons involved on specific topics.

 

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titleChapter 4.2 level 3 - “Means are available to develop and maintain GBU knowledge on intended uses and actual exposure.” : are all uses and exposure of all marketed products of the GBU concerned ?

The objective is to have a process to track all uses of all marketed products. Of course priority must be given to specific substances (such as CMR substances) based on product prioritization (IND-­HSE-­PRAS­-14­-PRO) and sensitive markets (such as food, food/water contact, pharmaceutical ingredients, cosmetics, medical devices) according to the HCRM procedure.

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titleChapter 5. level 2 and level 3 - “Accidents / incidents are analyzed as an input of risk assessment review”.

What is the difference between an accident and an incident ?

In the context of PSMS, “Marketed Product Accident” designates an unwanted event which involves a marketed product and which causes reversible or irreversible effect to people or to the environment.

“Marketed Product Incident” designates an unwanted event which involves a marketed product and which causes reversible or irreversible effect to people or to the environment.

According the Procedure IND­HSE­01­PRO, both terms “accident” and “incident” are interchangeable, except for Occupational Safety.

“Marketed Product Near miss” is an unwanted event which involves a marketed product and that did not result in injury, illness, or damage – but had the potential to do so.

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titleChapter 9. level 4 - “The entity proactively manages its SDSs on Internet, taking into account regulatory differences between countries and is able to anticipate future developments, including civil society and market alerts.”

Examples of “alerts coming from civil society” are publications issued by Non-­Governmental Organisms, from consumers associations,...

 

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titleChapter 11. Guidelines - “The review is based on performance data for certain product stewardship performance indicators in relation to fixed objectives”

(see question 1.2 on Key Process Indicator)

 

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titleChapter 11. level 4 - “External audits (customers, accredited organizations,..) are performed.”

External audits are audits performed by people such as customers, consultants skilled in market certifications or management system consulting firms,.. on Product Stewardship topics.


More questions? Contact the Global Registration team.