Product Safety

REACH—In June 2007, new chemical management legislation came into force in the European Union. REACH—registration, evaluation and authorization of chemicals—is the largest chemical testing program ever undertaken and requires companies manufacturing or importing chemicals into the EU to provide data proving the chemicals are safe for use. The newly established European Chemicals Agency expects some 30,000 chemicals to be registered under REACH.

We began analyzing the impact of this legislation before it was finalized and have identified several hundred substances to be preregistered in 2008. Preregistration is a key step of REACH that will enable us to phase in our registrations over a 10-year period while keeping our products on the market. As with the High Production Volume (HPV) challenge program, we will work with other companies to minimize our testing costs under REACH. We do not anticipate withdrawing any products from the EU marketplace as a result of REACH.

Global Product Strategy—In addition to REACH, we began focusing on the ACC’s Global Product Strategy (GPS) in 2007. A key element in ACC’s dialogue on chemical management, GPS is aligned with the United Nations Strategic Approach to International Chemicals Management and includes risk prioritization, management and communication. Our long-standing product risk review process is consistent with GPS, and we used the process to prioritize our products as required by GPS. We are in the process of preparing product safety summaries for our high-priority products and will make the summaries publicly available.

We also continued globalization of SAP, which we use as our management system for creation and management of material safety data sheets and labels. In 2007 we completed our SAP deployment in Asia, adding China, South Korea and Taiwan to the system, which already included Singapore, Malaysia and Indonesia. Likewise SAP roll-out in Central Europe was initiated in 2007 and completed in 2008. These roll-outs have enabled us to improve consistency of the product safety information we supply to our customers.