By Josh Hendry, senior consultant, PE INTERNATIONAL
This is the first in a list of questions to which mining operations need to be able to answer yes and truly understand the important ramifications for each.
If products are hazardous or toxic, companies need to be able to demonstrate that they know how to manage them, and some sectors are further down the line than others. Organisations that work with lead, for example, have had to deal with this issue for years and capture a high percentage at end of life.
There are a growing number of downstream standards that are focused on hazard and toxicity, such as health product declarations. The EU’s REACH Directive has pushed the industry towards formal risk assessment for all materials and companies put a lot of time and energy into that. Now there are new issues and challenges to deal with. Many metals and other materials are hazardous or toxic in certain forms but not in the forms frequently found in products. Yet some downstream sectors are focused on the hazard of a material rather than the risk it presents as part of a product, which might be negligible.
For example, it was recently reported that consumers were in danger because most leather used in shoes is treated with chromium VI. However, the industry says that “based on current scientific knowledge, there is no reason that any consumer should face a toxicity risk from Cr(VI) when simple guidelines and recommendations are followed.”
Often the industry reaction to such reports is frustration that accusations that appear not to be based on sound science can happen. But companies need to go beyond that and be prepared to explain when a rating scheme or consumer group says a product is hazardous and it is not the case. Even though industry often has extensive and credible scientific studies on various risks associated with their materials, it can be difficult to ensure that the right people see them at the right time. Even when they are conducted by independent researchers, these studies are sometimes still perceived as ‘industry-funded’ and therefore face challenges in being accepted by some users. “It is important not to belittle or even hide risks and dangers,” says the International Union of Leather Technologists and Chemists Societies, in relation to the chromium VI issue. “However, if a risk is manageable then we should ensure that all are correctly and accurately informed so that no false hysteria is generated.”
It is also important to acknowledge that miners and manufacturers have to be transparent about what they produce because downstream users need to be aware of what is in their products.
Materials producers increasingly need to explain the proportion of certain materials in products to ensure customers know they do not exceed safety thresholds or to highlight their toxicity.
There is a growing number of regulations and standards for companies to comply with, but while compliance is an important issue, it is just as important to work with customers, if not more so. With compliance, there is typically a lead-up before any new regulations are rolled out and there is often several months or years to prepare for any changes. But customer requirements can change really quickly in the face of a crisis or scandal, so it is important to understand the challenges. Customers may also have to react quickly to changes in consumer preferences.
One danger is of sending out mixed messages. Companies whose products contain materials of concern often offer ranges free of these materials alongside their standard ranges – but what kind of message does this send out? Are these substances safe or not? If not, then the company is showing a reckless disregard for the safety of its customers. And if they are safe, are they doing anything other than profiteering? If concern grows over particular ingredients, the industry may need to find alternatives at short notice or face disruption to their operations.