For industrial hygienists, our job descriptions can sometimes feel like an uncharted map, constantly expanding beyond our core health and safety responsibilities. One area that often ambushes us is product stewardship—the cradle-to-grave management of a product to minimize its environmental impact. Taking this on can feel as overwhelming as being handed a rocket manual when all you signed up for was paper airplanes. Yet, as complex as it may be, establishing a solid product stewardship program is not just a job duty, it’s a mission with far-reaching benefits for both the company and the planet.

BACK TO MY HUMBLE BEGINNINGS During a lively session on sustainability at the 2022 AIHA conference, I overheard a participant ask the speaker, almost whispering, “How do I even start a product stewardship program?” That question hit home, taking me straight back to my early, sweat-inducing days on the job. Picture it: during my first week, bright-eyed and clueless, I attended an automotive industry conference packed with experts who practically spoke in IMDS code. IMDS, or the International Material Data System, is used to track parts and materials down to their chemical makeup. I scribbled notes with the intensity of a student before finals, and yet, when the conference ended, I felt like I’d been handed a foreign language dictionary and told to recite poetry.

The anxiety reached new heights when I returned to work. I stood in front of my team, notes clutched like a lifeline, and gave a vague summary that could have doubled as abstract art. Thankfully, no one asked questions, sparing me from inventing answers that would have ventured into science fiction. That experience taught me a vital lesson: product stewardship isn’t learned overnight. It’s built step by step.

Connecting the dots between previous experiences and new challenges is one of life’s most vital lessons. In my prior role within the mining industry, I found myself navigating red-flag zones like the Democratic Republic of the Congo, where conflict minerals—mined substances sold to finance armed conflicts—are a heated topic. Working at a mine extracting copper and cobalt was intense, and the transition to my current employer, where cobalt tracking had become imperative under the new 3TGC (tin, tantalum, tungsten, gold, and cobalt) framework, was equally daunting. But even with firsthand exposure to these product stewardship concerns, the intricate interconnections in my new role were still a blur.

That’s because the scope of product stewardship is vast—it’s a symphony where you have to ensure all sections play in harmony or risk chaos. One of my first major tests was tackling REACH (Registration, Evaluation, Authorization, and Restriction of Chemicals) registration in May 2018. Initially, I didn’t grasp that this process had to be managed on two fronts: overseeing our product lines and ensuring compliance for the chemicals used in European Union (EU) production. This endeavor felt like assembling a puzzle without knowing if I had all the pieces or if I was building an image of a kitten or a spaceship.

HOW TO SUCCEED AT PRODUCT STEWARDSHIP Through these experiences and with the benefits of hindsight, I’ve identified eight keys for building a successful product stewardship program:

1. Understand product stewardship. Product stewardship isn’t just a fancy term for compliance. It’s the responsibility to minimize your product’s environmental footprint at every stage. It’s about going from “I hope we meet regulations” to “Our products are proactively sustainable.” I learned this the hard way when I asked a team member to print out a substance list for me, and I stared at it like it was a map to nowhere. It dawned on me then that I needed to grasp how Substances of Very High Concern (SVHCs) are captured and reviewed. SVHCs are defined in REACH as substances with serious health consequences. The SVHC designation triggers hazard communication obligations for suppliers. I needed to up my game to ensure that our product didn’t slip into regulatory quicksand.

2. Know your product lines and markets. Understanding what your company sells and where it’s sold is crucial. This is where IMDS and the meticulous review of Bills of Materials (BOMs)—comprehensive lists of everything needed to build a product—became my lifelines. Digging through component details to confirm compliance felt like mining for gold: tedious yet rewarding. Each part fed into IMDS must meet regulatory checks, and once the BOM is validated, the system can reveal whether the product complies with key requirements.

To make this work smoothly, I adopted a two-prong approach: feeding the part numbers into IMDS and ensuring that chemicals used in our EU plants were REACH compliant. This method was replicated for other regions too, employing systems like CAMDS—the Chinese version of IMDS—for China’s specific regulatory framework. This multilayered review not only saved time but also provided comprehensive assurance that our global compliance strategies were aligned.

3. Have a chemical approval process. If your company doesn’t have one, get ready to add it to your to-do list. For me, it was a game-changer. The system we used was the global chemical management system for all our sites. It allowed me to oversee chemicals from approval to usage and flag potential compliance issues before they escalated. Picture it as having a friend who knows the ingredients in the mystery punch at the office party—it kept me from unwelcome surprises.

4. Engage key stakeholders. Building a product stewardship program in isolation is like trying to build IKEA furniture without instructions (or that little Allen wrench). Success comes from collaboration with key stakeholders in departments across the enterprise, including engineering, program managers, R&D, legal, sustainability, and the supply chain. I realized early on that program managers were the linchpins. They connected the dots between customer expectations and product specifications, and their input could make or break compliance. Engaging them early was critical, as was building a rapport with the sustainability manager to advocate for proactive regulatory planning. This teamwork paid off when we built a business case that secured budget approvals for handling regulations that address items such as conflict minerals and full material disclosures.

5. Know the relevant regulations. The specific regulations your products must comply with depend on your markets. The alphabet soup of global standards can feel overwhelming. I’ll never forget when a colleague from Brazil asked for a RoHS letter, and I momentarily panicked, wondering, Who is RoHS and why do they need a letter? A quick reality check: RoHS, or the Restriction of Hazardous Substances, isn’t a person. It’s a set of standards limiting hazardous substances in electronics.

From RoHS to conflict minerals and beyond, the regulatory landscape can be vast and varied. I learned that the best way to stay on top of these changes was to be proactive through research, attendance at conferences, and participation in professional courses to keep our team’s knowledge up to date.

6. Build a database and manage information. A comprehensive database is your holy grail. It organizes your product data and regulatory information, turning compliance into a streamlined process. These platforms are lifesavers, tracking global regulatory drafts and changes. They save endless hours of scrolling through search engines and keep your team informed of any shifts that could affect your product lines.

When our company divested one of its business segments, the IMDS database played a crucial role in splitting the data accurately. The challenge came when part numbers were shared across two business segments, requiring a shared organizational ID to maintain compliance and continuity for both companies.

7. Establish a review process. Regular review meetings are like the family dinners of product stewardship: sometimes intense, often enlightening, but always necessary. Monthly team meetings focused on updates and quarterly gatherings that delve deeper into sustainability projects keep everyone aligned and informed. At my company, this approach also helped secure buy-in from leadership and ensure funding by showing the tangible benefits of our program. Two examples from my experience illustrate the benefits of a review process.

The first example concerned an original equipment manufacturer (OEM) that needed a safer substance for lead in one of its products. An OEM is a company that uses its own facilities to transform substances into end products. The substitution process required understanding which part numbers were affected and involving stakeholders such as program managers and staff from the materials engineering department and supply chain representatives. Ultimately, the tests we performed confirmed that the new material met or exceeded the performance of the old one. The OEM accepted the new costs, solidifying our ability to meet sustainability goals and maintain compliance ahead of deadlines. This led to over $250,000 in gains for the company’s bottom line due to proactive management and negotiation on material pricing.

The second example involved a full material disclosure (FMD), which is another cornerstone of a robust product stewardship program. An FMD requires detailed breakdowns of product components, a daunting task when the product includes circuit boards with thousands of nodes. In one project, we found that producing an FMD for an average of 2,470 nodes took about 160 minutes, which put a significant strain on resources. Investing in product compliance platforms cut this process down to just 15 minutes, drastically reducing delays and improving efficiency.

Lastly, a review process can be used to prepare for upcoming changes of significant regulations within a region, such as the Conflict Minerals Regulation (EU Regulation 2017/821), which came into full force across the EU on Jan. 21, 2021. Understanding the supply chain audit and working with supply chain management along with your organization’s legal department is crucial.

8. Communicate with leadership. Leadership needs to see that product stewardship isn’t just a box to tick but a strategic advantage. To make this clear, I created a detailed procedure outlining the process, from stakeholder roles to data integration, in 2018. The procedure became the foundation for reporting updates and regulatory changes to company leaders through concise, engaging newsletters—enough to inform without overwhelming. Think of it as sending a well-crafted movie trailer rather than a full-blown documentary.

THE JOURNEY OF PRODUCT STEWARDSHIP Implementing a strong product stewardship program may feel like trying to herd cats at first—chaotic, with a lot of unexpected detours. But with patience and a clear plan, you’ll find yourself not only achieving compliance but also leading your company into a sustainable future, one well-managed product at a time.

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