Borealis’ product safety goals in 2020 were to:
During the year 2020, Borealis:
In 2020, Polyolefins:
In 2020, Fertilizer, Melamine and Technical Nitrogen
Products (TEN):
Chemical substances or products containing them can pose risks to human health and safety as well as to the environment. These include effects such as sensitisation, irritation or intoxication; physical hazards such as fires, explosions or exposure to dust; or environmental hazards, such as bioaccumulation or persistence. Borealis is committed to the principles of Responsible Care® and enforces high product stewardship standards to ensure that its products do not pose a risk at any stage along the value chain.
Borealis’ Product Stewardship department is responsible for ensuring product safety and puts stringent measures in place across the entire life cycle. In addition, it makes sure that all products are legally compliant in all the countries in which the Group operates and sells.
The Group also ensures it understands and anticipates consumer and market needs and concerns as well as the development of legislation concerning chemicals, their applications and the environment, so it can apply a precautionary approach, take measures where needed and ensure continued compliance. Borealis also sees the proactive substitution of chemicals of concern as an opportunity to gain market share and be the first to market with an alternative solution.
Making plastics more circular is one of Borealis’ main goals. The Product Stewardship department supports the Group’s work to maintain product safety while using mechanically recycled post-consumer waste. A defined mix of testing and risk assessment as well as looking at the waste stream and the sorting and cleaning processes, provides the basis of compliance of recycled products to different application areas.
Product safety is mainly handled by the Group Product Stewardship team, supported by local product stewardship experts in the production locations. Group Product Stewardship reports to the Director Health, Safety, Environment and Quality (HSEQ). The team consists of members focusing on incoming chemicals and members who ensure that products comply with general chemical legislation, such as REACH and the Classification, Labelling and Packaging (CLP) of substances and mixtures regulations, as well as application-related legislation, such as food contact or health care applications.
The Product Stewardship Council addresses chemicals of concern in a proactive way. It is chaired by the HSEQ Director and brings together experts from across the Group, including areas, such as Product Stewardship, Sustainability, Ethics, and Innovation & Technology, as well as all of Borealis’ business sectors and operations. This range of competencies ensures that the Group’s risk assessments take a holistic perspective and consider market needs, legal and technological requirements, and stakeholder views.
The Group has adopted a hazardous chemicals strategy. This follows the precautionary principle of continuously assessing the risk potential of all substances used in Borealis’ products to identify critical chemicals whose use needs to be stopped or that need to be replaced by safer alternatives. This includes all substances which were already classified as SVHCs according to REACH and other comparable legislation outside the EU, or which fulfil the criteria to be considered as SVHC in the future. Examples include raw materials based on cadmium salts, octylphenol or nonylphenol compounds or many poly-halogenated organic compounds.
The risk evaluation utilises a tailor-made tool which ranks the substances according to their overall risk. It considers related health, safety and environment (HSE) risks and regulatory aspects, evolving stakeholder concerns, the technical feasibility of substitution and the financial consequences of doing so, such as the required innovation costs, approval costs and modifications to technical equipment. Substances with the highest identified risk are further assessed by the Product Stewardship Council. The council selects the substances to be evaluated using the Borealis Risk Matrix, which is a proprietary ranking tool to evaluate risks in detail. These assessments enable Borealis to identify, mitigate and manage the risks posed by hazardous chemicals. One example of the outcome of this proactive process is the launch of the world’s first chemically-foamed, high-density polyethylene grade for cables that is free of the heavily scrutinised chemical azodicarbonamide.
In addition, the Product Stewardship Council updates the Borealis Banned Substances List which contains more than 220 substances and substance groups that the Group has banned for use in its production processes and products. In 2020, 8 substances were added to the Banned Substances List.
In addition, Borealis has established the Compass, which is a method for assessing the sustainability of its product portfolio. Product Stewardship assesses the Group’s polyolefin products in two categories of the Compass: “Chemical hazard and exposure across the life cycle” and “Global regulatory trends”. This assessment is performed for both current products and innovation projects. Any finding, opportunity or threat is followed up using Product Stewardship’s established processes.
Borealis’ product safety procedures cover the HSE aspects of a product throughout its life cycle, from raw material sourcing, through the production process, conversion and use, to its recycling, recovery or disposal.
All new or modified products undergo mandatory HSE assessments and continuous monitoring to ensure they are suitable for use in the countries where they are being sold, and that they comply with all applicable legislation. This includes chemicals management legislation, such as the Toxic Substances Control Act in the United States and REACH in the EU. This comprehensive and stringent regulation targets the safe use of chemicals which must be proven by the participants in the chemicals value chain. Over the last couple of years, the quality of REACH registration dossiers has been challenged by non-governmental organisations and some EU Member State authorities. CEFIC has therefore established a REACH dossier improvement programme that Borealis has signed up to and is fully supporting. The aim is to have all existing dossiers updated and improved by 2026. Each year, the Group’s progress needs to be reported to CEFIC.
Other relevant legislation and regulations include the Globally Harmonised System (GHS) for the classification and labelling of hazardous chemicals, CLP and, depending on use, any application-related legislation, such as the EU framework regulation on food contact materials.
Borealis also closely monitors emerging legislative initiatives, so it can anticipate and take measures to maintain its products’ legal compliance. In line with the REACH principle of “no data equals no market”, this is essential to sell any product worldwide. Borealis therefore incurs the significant costs of registration fees, data creation and external consultancy to ensure compliance. In 2020, the main focus of these activities was to meet the pre-registration deadline for Turkey REACH (KKDIK) and to collect all necessary data to apply for polymers of low concern (PLC) exemptions for the REACH-type legislation in South Korea. A prerequisite to perform necessary notifications and registrations for these emerging legislations is to know the annual volumes per chemical substance shipped to the relevant country. PO products are typically mixtures of several different substances. To be able to track these volumes on a continuous basis, a powerful IT tool is required that combines information on product deliveries with product recipes. In 2020, the Group therefore implemented the SAP SVT tool for the EU, Turkey, South Korea, Taiwan and the UK.
For the Fertilizer, Melamine and TEN business, there are two new key regulations coming into force in the next two years. These are the Regulation (EU) 2019/1009, laying down rules on making EU fertilizing products available on the market, and the Regulation (EU) 2019/1148 on the marketing and use of explosives precursors. Internal implementation projects have been launched and followed up to assure future product compliance and explore potential opportunities.
Borealis’ activities regarding the circular economy and exploring sustainable feedstock also bring along new aspects to be considered and solved with regards to product safety and compliance.
The existing and planned legal framework, for example, following the EU Commission’s “Green Deal”, is asking industry and brand owners to use post-consumer recycled (PCR) materials for their products. The Borealis Product Stewardship team is providing support by generating an overview of applicable legislation and available industry standards to produce a risk assessment and analytical testing strategy to be able to confirm compliance and the suitability of Borealis’ circular economy solutions portfolio.
Moving from fossil to renewable feedstock is another important aspect of the Group’s sustainability journey. Using this type of feedstock from animal and agricultural waste, however, raises other product safety challenges that needed to be tackled. After a thorough analysis of the related aspects, the messages on Kosher, Halal, animal and genetically modified organisms origin, and vegan status, have been revised in the statement on raw material origin for the PO products concerned.
Before they are approved for use, all incoming chemicals used in Borealis’ products are assessed using a thorough incoming material process. Group Product Stewardship performs an initial assessment, to ensure legal compliance. Product Safety teams in the countries where Borealis operates then perform additional assessments at each plant, to ensure the chemical meets plant-specific requirements and complies with national or community related legislation.
This system ensures that Borealis’ procurement department does not purchase any substance before the Product Safety team has controlled and approved it. Once materials are approved for purchase, they are subject to Borealis’ quality control to ensure they continue to comply with the agreed material properties.
All materials are documented based on Borealis’ knowledge of the exact composition of the raw material and on detailed information about the material’s hazardous constituents. Proper documentation of the raw materials used is a key element of high-quality Borealis product compliance statements, such as safety data sheets (SDSs), application-related statements, such as medical use, food contact and drinking water, and other statements such as on raw materials origin.
Borealis also regularly audits its raw material suppliers for compliance with, for example, their legal and hygiene requirements. However, in 2020, due to the COVID-19 restrictions, only one virtual raw material supplier audit was held. The Group requires its suppliers to provide documentation for each raw material and to keep it up to date, including the information required by national chemical inventory control laws, the CLP and REACH. This enables Borealis to issue the respective SDSs for its customers.
In addition to these measures, Borealis’ production sites are subject to frequent external audits. For example:
– Sites that manufacture products with sensitive hygiene requirements are regularly audited by external expert organisations and customers. This includes products for use in drinking water, food contact, personal hygiene and medical applications, which represent about 50% of Borealis’ polyolefin products. In 2020, all mandatory third-party audits were successfully passed, some of which were conducted remotely. Voluntary second-party audits, such as customer audits, were pursued as requested. The total number of audits was lower than in 2019 due to the COVID-19 pandemic travel restrictions.
Microplastics have no place in the environment, water or food. However, increasing volumes of microplastics are ending up in the environment as a result of plastic litter, causing harm to marine life. The potential effect of microplastics on human beings is still a matter of scientific debate and much more sound scientific research is needed. Even so, the potential harm to human health is a major concern.
Borealis therefore pro-actively engages in working groups, along with Plastics Europe and CEFIC to review the current scientific literature on microplastics and identify the knowledge gaps. The Group also supports voluntary industry efforts to phase out intentionally added microplastics.
Borealis is also actively contributing to the CEFIC and Plastics Europe working groups to improve the intended REACH restriction on intentionally released microplastics, with regards to effectiveness and feasibility.
In pellet form, Borealis’ polyolefin products fall under the size definition of microplastics. Borealis is fully committed to ensuring that no plastic pellets escape from its operations or supply chain, and was one of the first signatories to Operation Clean Sweep (OCS), a programme to prevent pellet loss.
As one of the measures taken, Product Stewardship has added instructions on how to avoid accidental release to the environment to all product safety documentation such as Safety Data Sheets (SDSs) and Product Safety Information Sheets (PSIS) issued from October 2020 onwards.
One of the cornerstones of Responsible Care is open and transparent communication with stakeholders about the substances used in products. Borealis takes this obligation very seriously. Issues raised by stakeholders include substances of concern, REACH and similar developments around the world, and non-intentionally added substances (NIAS) in food and drinking water contact.
Borealis communicates with its stakeholders through a wide range of channels. The Borealis website allows anyone to find information about the Borealis Banned Substances List. The website also includes examples of successful substitutions of hazardous chemicals and some position statements regarding “hot topics”. Borealis’ Polyolefin customers can download SDSs, PSISs and other general or application-related compliance statements from the Borealis website or the MyBorealis customer portal.
When product modifications may influence customers’ safety or require additional testing of finished articles, Borealis informs customers or authorities in due time before it makes the modifications. Borealis also informs customers in advance when legislative changes have consequences for them.
In addition, Borealis offers training and education to customers. Healthcare is one of the most sensitive application segments in terms of reliability, hygiene and product consistency. Sharing Borealis’ expert product safety knowledge with value chain partners therefore makes an important contribution to helping customers continuously meet the highest product safety and quality standards. Borealis shares this knowledge via formal customer training sessions and through technical dialogues throughout the year. Due to travel restrictions during the COVID-19 pandemic, only two customer audits took place during 2020; one in a Borealis plant and one virtually. Twelve customers sent questionnaires that were completed instead. Polyolefins also took part in several customer initiatives regarding NIAS in contact with food and drinking water, identifying problem areas and proposing alternatives. In 2020, together with a brand owner, Borealis contributed to developing criteria related to product safety for PCR plastics used in hygiene products and their packaging.
In the Fertilizers area, Borealis offers education and awareness activities for farmers. This informs them about proper use of chemical fertilizers and how to avoid pollution of groundwater or soil.
Borealis actively participates in industry associations and standardisation groups to stay at the forefront of regulatory and public requirements. Borealis is a member of various chemical industry consortia and several CEFIC sector groups, including the Lower Olefins Sector Group, the Aromatics Producer Association, Fertilizers Europe and the European Melamine Producers Association. Borealis is also a member of PlasticsEurope’s working groups on food contact materials, and the “European Drinking Water” initiative which focuses on regulatory schemes for drinking water pipes and fittings.
Borealis is an active member of the Product Stewardship teams at CEFIC, PlasticsEurope and related national organisations. The Group works closely with its own experts, customers and suppliers, and engages in experience exchange at REACH conferences and other activities.
As a member of Fertilizers Europe and related national associations, Borealis takes part in discussions on draft regulations and their applications. In 2020, the relevant topics included details of the new fertilizer regulation and its guidance on labelling as well as the guideline for the new European regulation on explosive precursors.
The Group’s future product stewardship objectives are to:
