Building a Robust Chemicals Policy and Program from the Ground Up: An Interview with Paul Ellis
Gain valuable insights on customer-centric policies, prioritizing chemicals, and effective communication with brands. Learn Kingfisher PLC’s sustainable chemistry approach from Paul Ellis.
Scivera had the pleasure of talking to Paul Ellis, the former Head of Sustainable Chemicals at Kingfisher PLC. While there, Paul instituted a robust chemicals policy and program from the ground up, which helped him gain invaluable insights into how retailers can effectively coordinate sustainable chemistry goals with brands and their suppliers. Here’s what he had to say:
1. DEVELOP YOUR CHEMICALS MANAGEMENT PROGRAM WITH YOUR CUSTOMERS IN MIND.
“Retailers are hindered by the absence of a global transparency standard. And as such in Europe, retailers typically see REACh as the bar to achieve, but this is short-sighted, as we know that REACh is slow in application and evidence of hazardous chemicals is growing faster than REACh can deal with. Kingfisher agreed that a better program than just following REACh regulations was necessary, so we started to develop a policy. We asked real customers what they expected from retailers in regards to chemical management. They said that they trusted retailers to take action on hazardous chemicals and to protect them from the effects of toxic chemicals. They said they wanted to live a toxic-free lifestyle and expected retailers to deliver this. So we developed a chemicals policy, based on consumer, environmental and worker protection.”
2. DEFINE THE OBJECTIVES OF YOUR CHEMICALS MANAGEMENT PROGRAM TO KEEP EVERYONE ON THE SAME PAGE.
“At Kingfisher, the objectives of the chemicals management program were to:
- Define which hazardous chemicals we would focus on
- Define scope—which included the finished product—including the environmental impact and how to manage chemicals used in the factory environment
- Define the plan and how long we needed to phase out the hazardous chemicals we prioritized”
3. DON’T LET THE NUMBER OF CHEMICALS OVERWHELM OR DETER YOU. CONSIDER A “HOTSPOTTING” STRATEGY TO GET STARTED WITH KEY CHEMICALS OF CONCERN.
“To start, we assessed which chemicals we should focus on, we called this “hotspotting,” and the assessment was performed by an external 3rd party. The assessment included:
- Learning the majority mix / type of materials present in our products
- Mapping by material, which hazardous and non-regulated chemicals might be present -Calculating volumes, sales, SKU, and where possible weight of SKU
- Ranking chemicals by sales, and risk profiles (REACH, CLP , NGO views, upcoming regulations, consumer concerns if they existed)
- Creating a shortlist of chemicals and looking at alternatives for each targeted chemical. (This is an important point here, the alternative needed to be commercially available and suitable to make the proposition commercially acceptable.
- Looking at “what other leading retailers and brands” were focused on, because we wanted to be aligned with the leaders, and it allowed us to seek collaboration opportunities when phasing out, because we would likely use the same suppliers at 1st, 2nd or 3rd tier.”
4. HAVE A STRATEGY FOR COMMUNICATING ABOUT YOUR CHEMICALS MANAGEMENT PROGRAM WITH BRANDS AND SUPPLIERS.
“We created a “Roadmap” to communicate how long it will take to phase out and which product ranges we would target and in which order.
We would speak to the suppliers at the earliest stages of product development and conduct an assessment on their ability and attitude to make a positive change. We knew “data” and the granularity of data would be a challenge, because the market typically calibrated to the “regulatory” level, which fell far short of what we needed. Because there is no common standard across the globe, we looked at what data is collected by others (retailers, manufacturers and leading brands) and systems that existed to support automated data collection.
Ultimately, we knew the priority was greater granular transparency and an ability to speak to the supply chain, and have the ability to set standards for all levels of the supply chain. We focused on high-risk materials and priority supply chains/ products, where we required a higher level of transparency compared with regulated chemicals.
Data is by far the most important element to a successful chemicals management system, and on the other hand intellectual property protection was the biggest concern voiced by brands. In my opinion, transparency isn’t to be feared, it’s an enabler to using safer alternatives as well as managing regulations. It also makes chemical management more efficient and less costly in terms of controls.”
*PS: We wish we’d been around when Paul was working on this; SciveraLens allows for data sharing while protecting brand and supplier IP!*
5. KEEP EYES SET ON THE OPPORTUNITY TO STAY AHEAD OF THE CURVE.
“Retailers have the power to make change happen in the value chain, but only if the retailer sees the consumer and brand risks as being the driving force for change. At the end of the day, in order to gain commercial support in buying decisions, there must be a clear benefit. This can be sustainability led and used to meet certification demands, or something that the product can be marketed as. Either way, it’s about explaining the reasons for change, what the hazards and risks are, and then working with the commercial stakeholders to affect a change.”