Third-Party Review of Product Safety Assessment 2015
Pursuant to Dow's 2015 Sustainability Goal related to Product Safety Leadership, Dow committed to, by 2015, make publicly accessible safety assessments for its products globally, and in doing so address relevant gaps in hazard and exposure information. Dow indicated that it would continue to take appropriate action based on the assessments to protect human health and the environment throughout the life cycle. In addition, Dow also retained Risk Sciences International at the University of Ottawa in Canada (“RSI”), a leader in the field of risk assessment, communication and management, to evaluate the robustness of Dow's product safety assessment processes, including its processes for making product stewardship decisions. Dow is now reporting a summary of RSI's assessment.
RSI focused primarily on two aspects of Dow's product safety decision making:
- The various business processes that support product safety decision-making, measured against stated product safety assessment goals and process expectations, as well as broader scientific and societal expectations
- The organizational, technological and scientific capacity to meet the goals and expectations expressed by Dow's 2015 Sustainability Goals
The analysis consisted of a review of Dow's internal guidance documents and associated work processes and software tools, case studies of product safety decision processes, interviews of Dow personnel from the US and EU, including subject matter experts involved in product safety decision-making decisions, product sustainability leaders and product stewards. RSI also engaged an international panel of experts to consider RSI's findings and add additional perspectives to inform the recommendations. RSI convened nine experts in fields relevant to chemical product safety assessment, including medicine, toxicology, epidemiology, risk assessment, public health policy, and corporate sustainability. These experts represented academia, international research institutions, private consulting practice and industry and were drawn from Canada, US, England, and France.
Overall, RSI found that Dow's product safety assessment process is generally sound, and this soundness stems from a strong and appropriate governance structure, and a strong internal culture of product stewardship and product safety. In addition, RSI concluded that Dow has world class scientific expertise and the capacity to achieve excellence in product safety assessment, including demonstrated capacity for state of the art practice in toxicology, exposure assessment and risk characterization.
Against that background, RSI identified a few areas for potential improvement, to enhance and ensure consistency in the quality of product safety assessments and decision-making across Dow's portfolio of products and their many uses. RSI's analysis leads to three main areas of recommendations:
- Dow should consider separating its scientific risk assessment process from its risk management work process - i.e., establish a dedicated product safety decision-support function that is independent of, but intended to inform, Dow's business risk review process.
- Dow should consider developing a set of tiered and decision context-specific expectations for the level of intensity in various elements of product safety risk assessment practice. It is not practical or expected for Dow to conduct assessments for all products and uses and life-cycle stages at the same best-in-class product safety risk assessment level. The intent of this recommendation is to acknowledge the continuum of intensity in various risk assessment activities and to actively choose among them as a function of the decision context, as opposed to a more arbitrary selection based on the capacity, resources perceived time pressures or personal preferences of individuals.
- Dow should consider updating and expanding IT infrastructure to accommodate the scope of its product safety commitments, to increase the efficiency of product safety risk assessment, and to capture corporate knowledge for the long term. Adopting the proper enhanced infrastructure would improve efficiency in iterative product safety reviews and allow Dow to more easily substantiate its high quality product safety review processes across its entire portfolio.
The recommendations are designed both to strengthen Dow's current practices as well as provide greater assurance of the quality of product safety risk assessment and decision making across Dow's extensive product safety mandate.
In response, Dow has chartered several projects to evaluate and, as appropriate, address these recommendations. The following improvements are in the process of being implemented:
- Dow will continue to assure that risks are accurately assessed separate from business decisions related to those risks.
- To address varying levels of risk intensity and to ensure efficient resource utilization, Dow has established different types of business risk reviews (e.g. targeted, full, etc) depending upon the determined risk tier. Risk tiers are based on health and environmental hazard profiles and chemical / product exposure potential. The risk tier also defines frequency of re-assessment of risk.
- To capture corporate knowledge in a more robust and consistent manner, Dow has designed an IT infrastructure that includes a common reporting approach. These improvements will strengthen Dow's searching capabilities, retention, leadership review of findings and the ability to leverage learnings across similar reviews.
Dow is currently providing comprehensive cross-functional training on the BRR improvements and systems to key employees in all functions and businesses in Dow who participate and /or support BRRs.