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General Approach for Chemical Management
The ACCO Brands approach to chemical management utilizes a three-pillar concept. The first pillar is the publication of the Restricted Substance List (RSL), which explains our expectations regarding chemical compliance. Global chemical regulatory activity is closely monitored through several third-party tools, ensuring that the RSL remains up to date with the changing chemical landscape.
The second pillar is communicating and monitoring supplier compliance to the RSL. Our suppliers are notified of any RSL revisions and confirm their compliance through our RSL Certification of Compliance (CoC) activity. The RSL CoC activity is managed through an online Source Intelligence portal. Historically, the RSL was communicated only to our finished goods suppliers, with the expectation their RSL CoC was based on their communication of the RSL to their second-tier suppliers. Beginning in 2019, ACCO Brands began rolling out the RSL CoC process directly to raw material and component suppliers on a market-by-market basis, with the goal of including all second-tier suppliers by 2022.
The third pillar is our chemical verification testing program, where verification testing is performed for key RSL chemical substances. We use accredited third-party laboratories with a global footprint to implement and manage our verification program.
The identification of hazardous substances in our RSL is largely hazard-based, and takes into account, among other factors, regulatory requirements, the potential for new or tighter regulation, industry practices, customer requirements and input from third-party experts. This approach allows us to concentrate on the phasing-out or elimination of key chemicals used in our product offerings.
Phthalates can cause endocrine disruption behavior and are most likely to be used in Polyvinyl Chloride (PVC) where a flexible material is needed. The use of PVC in the ACCO Brands product line is primarily in electrical products, found in cords and wires. PVC is used, to a lesser extent, in some non-electrical products.
In 2017, ACCO Brands issued a PVC Policy, with the goal of eliminating or minimizing applications of plasticized PVC, and hence regulated phthalates in our products. In many cases, the substitution of alternate polymers enabled the elimination of PVC. Power cords in electrical products presented a substitution challenge, since PVC materials possess key performance functionality; however, we successfully eliminated the use of regulated phthalates in power cords by substituting PVC materials plasticized with a family of non-phthalate plasticizers.
ACCO Brands enforces the elimination of PVC in new product development wherever possible. Where elimination is not possible, the only allowed PVC material uses non-regulated, non-phthalate plasticizers. In 2020, we released nearly 5,800 new products. PVC/non-phthalate usage was limited to eight (8) electrical product families and five (5) non-electrical product families.
The further use of PVC is discouraged in new product development, so that PVC can be eliminated in the design stage. The focus of eliminating PVC includes both products and packaging.
Third-Party Chemical Verification
We use a hazard-based approach to identify the specific chemicals we monitor directly through our chemical verification program. For each chemical category in our RSL, we identify the types of materials and/or product characteristics that may use the substances. Based on our product line and materials used, and in conjunction with third-party experts, we identify a set of chemical substances for thirdparty laboratory verification. Examples of higher risk materials are PVC, composite wood, and batteries.
Our chemical verification testing program is then implemented using a risk-based approach, dependent upon product types and materials used in the final product. Examples of higher risk products are electrical products, art materials, and school products.
In general, all own-brand products and private label products are designed to comply with the RSL and the chemical verification is applied in the same risk-based manner. Private label products, are often tested in accordance with customer requirements using the customer’s approved laboratories.
For ACCO Brands domestic manufacturing facilities, where common materials are used in a large number of final products, we employ efficiency in chemical verification testing by evaluating the raw materials and components.
We use the term “chemical-intensive products” to identify those products supplied to the consumer that are primarily composed of chemicals. These products are predominantly art materials and include markers, paints, chalks, pastels, pencils and board cleaners.
The formulation of chemical-intensive products is of critical importance since the consumer is handling, and therefore exposed to, the chemicals in the product. The safety evaluation of these products requires a higher-level of verification. The short- and long-term exposure to these chemicals is evaluated using a toxicological risk assessment performed by a board-certified toxicologist.
To assure our customers of their safety, we certify our art materials under the Arts and Creative Materials Institute (ACMI) certification program. This certification program includes a toxicological evaluation by a board-certified toxicologist for acute and chronic hazards, and additional chemical testing requirements. Although limited to U.S. requirements, the ACMI seals are recognized as a safety assessment in other countries.