Technology and compliancy

REACh
Stahl supports the objective of the REACh regulation for improving the protection of human health and the environment when using chemical substances at all stages in the value chain. Stahl expects that REACh will enhance the competitiveness of the chemical industry by fostering innovation. Stahl fully endorses the REACh objectives. These are entirely consistent with Stahl’s own SHE policy (Safety, Health and Environment) which, among others:

  • Gives first priority to safety, health and the environment;
  • Obeys all laws and is a responsible corporate citizen;
  • Identifies hazards and establishes appropriate controls for risks, potential adverse environmental impacts and regulatory requirements in the invention, manufacture, sale and use of its products;
  • Provides customer care with all products throughout the supply chain;
  • has established the goal of eliminating all injuries, occupational illnesses and environmental incidents;
  • Requires all employees to accept personal responsibility for their own safety and health and that of their colleagues.


Stahl informs and shares data with the suppliers of raw materials, as well with its customers from whom a description is expected on how they use Stahl products on their sites. These communication requirements by REACh should avoid interruptions of the supply between suppliers and customers. As an organization within the supply chain in different REACh roles and responsibilities (manufacturer, importer, supplier, distributor and end-user) Stahl receives an increasing number of requests for information. Stahl ensures that all information required for its REACh compliance is made available on a timely basis.

Stahl anticipates a potential loss of raw material, because the company is dependent upon suppliers’ competence, ability to absorb costs of registration and upon identification of Stahl’s uses.

Coordination of all REACh related actions within the Stahl organization world-wide is guided by a Steering Committee, consisting of the global managers of the various business units, Purchase Department, R&D and the Product Stewardship Department (PSD). PSD coordinates and prepares for the registration, which is supported by a defined IT structure. This system also contributes to collecting and sharing information with suppliers and customers on the use and exposure of substances. Safety Data Sheets are generated and new labels according CLP are prepared by the system.
 

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ISO 9001
Accreditation to ISO means that effective management controls are in place that are clearly defined in writing. These controls include the management of authority, responsibility and the ability to take corrective action to resolve problems. The ability exists to demonstrate that planning and review of equipment and personnel skills are adequate and maintained to a standard which ensures that contract requirements are met and preventive actions are made before manufacturing begins.
1. Work Instructions
These include all operating procedures, product formulations, physical test specifications and quality assurance procedures.
2. Corrective Action
Records will be kept of all corrective action taken and state when and where a problem has occurred. The reason for a failure is analyzed, determined and recorded to ensure future consistency of compliance.
3. Records
Records are kept to demonstrate that systems are working effectively and are available for inspection at all times.
4. Change Controls
All procedural changes are controlled to ensure that the latest reference document is available and used at all times.
5. Inspection
It can be demonstrated that controls of inspection, measuring and test equipment are not only suitable for purpose but are regularly calibrated to ensure consistency.
6. Manufacturing Control
Manufacturing is carried out under controlled conditions. Production control systems are in place which identify equipment at all stages and provide a means of recording compliance/non-compliance. A mechanism is in place to pinpoint training requirements in special skills, retraining needs and a review of inspection standards at all stages of manufacturing. Established controls at each stage of production mean that the end product meets both the supplier's and the end customer's quality standards.
7. Raw Material Procurement Control
There are controls in place for the purchasing of raw materials. Chosen suppliers are issued with the precise product specifications and goods-in inspection means that only those raw materials which conform to an agreed specification are used.
8. Inspection and Testing
All finished products will be tested and inspected prior to delivery to the customer to ensure that they meet agreed specifications. When products are reworked they are always re-inspected and re-tested to ensure compliance.
9. Inspection Status
Controls are in place to ensure that records of quality checks have been carried out and that it can be distinguished between inspected and non-inspected material.
10. Sampling Procedures
A control system exists for the preparation of samples and sampling procedures are in place to ensure that the sample taken for inspection is representative of a complete batch of material.
11. Control of Non-conformance Procedures
Non-conforming material is identified and segregated from conforming material. A Material Review Committee will make a decision whether to scrap or rework the material in order to bring it within compliance.
12. Handling and Storage
All products and raw materials will be controlled throughout the manufacturing process. They will be stored in conditions which will protect them from deterioration and damage and they will be handled correctly. They will be correctly identified using the appropriate labelling in compliance with SHE legislation and delivered to the customer in a satisfactory condition. The company will, at all times, provide access and facilities to visiting Quality Assurance representatives.
13. Training
All personnel whose work affects quality will have the appropriate training. A record of their training will be kept and will be regularly reviewed and updated as required.
14. Review
All systems will be reviewed and evaluated frequently by the implementation of regular internal audits. The purpose of these audits is not only to ensure that the company remains in compliance with the set procedures but to strive for continual improvement in efficiency.
 
ISO 14001
ISO 14001 sets out the criteria for an environmental management system. It maps out a framework to set up an effective environmental management system, to be used to improve resource efficiency, reduce waste and drive down costs. Using ISO 14001 can provide assurance to company management and employees as well as external stakeholders that environmental impact is being measured and improved. ISO 14001 can also be integrated with other management functions and assists companies in meeting their environmental and economic goals.
ISO 14001 assists companies in continually improving their environmental performance, whilst complying with any applicable legislation. Organizations are responsible for setting their own targets and performance measures, with the standard serving to assist them in meeting objectives and goals and the subsequent monitoring and measurement of these.
The standard can be applied to a variety of levels in the business, from organizational level, right down to the product and service level. Rather than focusing on exact measures and goals of environmental performance, the standard highlights what an organization needs to do to meet these goals.
All standards are periodically reviewed by ISO to ensure they still meet market requirements. The current version of ISO 14001 – ISO 14001:2004 is under review as of April 2012.
Basic principles and methodology

PLAN – ESTABLISH OBJECTIVES AND PROCESSES REQUIRED

An initial review or gap analysis of the organization’s processes and products is required to identify all elements of the operation and - when possible - future operations that may interact with the environmental aspects. These aspects are both direct, such as
those used during manufacturing as indirect, such as raw materials. The review helps the organization to define the environmental objectives, goals and targets, ideally measurable KPI’s, it contributes to the development of control and management procedures and processes and serves to highlight any relevant legal requirements to be integrated into the policy.

DO – IMPLEMENT THE PROCESSES

The organization identifies required resources and staff responsible environmental management and control process. This encompasses procedures and processes for operational control and to foster better management control over elements such as documentation control, emergency procedures, the education of employees to ensure competent implementation of the necessary processes and records. Communication and participation across all levels of the organization, especially top management is a vital part of the implementation phase.

CHECK – MEASURE AND MONITOR THE PROCESSES AND REPORT RESULTS

Performance is monitored and periodically measured to ensure that environmental targets and objectives are being met. In addition, internal audits are conducted at planned intervals to ascertain whether the environmental management system meets the expectations and whether the processes and procedures are being adequately maintained and monitored.

ACT – TAKE ACTION TO IMPROVE PERFORMANCE OF EMS BASED ON RESULTS

A management review is conducted to ensure that the objectives are met, the extent to which they being met, that communications are appropriately managed and to evaluate changing circumstances, such as legal requirements, to make recommendations for further system improvement. These recommendations are incorporated through continual improvement of all processes and procedures.

CONTINUAL IMPROVEMENT PROCESS

The core of the continual improvement process ISO 14001 has three dimensions:
• Expansion: More and more business areas are covered by the implemented system.
• Enrichment: More and more activities, products, processes, emissions, resources etc. are managed by the system.
• Upgrading: An improvement of the structural and organizational framework of the system, as well as an accumulation of
know-how in dealing with business related environmental issues.
The continuous improvement will make the organization to gradually move away from merely operational environmental measures towards a strategic approach on how to deal with environmental challenges.
At Stahl we strongly believe in being a responsible citizen. That includes taking responsibility in a structured manner for dealing with environmental issues. We continuously strive for ISO 14001 compliancy for all our Manufacturing Sites.