Environment, Health, Safety, Security and Stewardship (EHS³)

Topics in this section:

• Safety
• Product Stewardship
• Risk Management
• Afton Completes REACH
• Regulatory Affairs

Today, that commitment is focused by an EHS³ management system and our ongoing initiative to improve performance. Our company-wide vision is simple: we have a “Vision of Zero” with no injuries, accidents, incidents, or harm to the environment.

To guide us toward that goal, we rely on our management system to helps us:

• Meet legal requirements in all EHS³ areas 
• Meet our targets and goals 
• Address interested parties’ concerns
• Continually improve our EHS³ system capability and performance

Afton’s executives and employees realize that we’re members of the communities in which we operate. We work with advisory panels and other public forums and communicate with our neighbors and other interested stakeholders about our operations and progress in the areas of EHS³.

Afton Chemical voluntarily reports a set of uniform, industry-wide metrics that measure individual company and industry performance. These metrics help us to identify areas for continuous performance improvement and provide a means for us to communicate to the public about our EHS³ performance in issues such as environment, health, safety, security, product risk, and economics.

Our Chemical Management System

Our chemical management system gives us a structure to effectively carry out specific activities regarding the environment, health, safety, security, transport safety, product stewardship, outreach, and emergency response.

Key components of this system include: 

• Policy, planning and goal setting 
• Definition of responsibilities 
• Measurement 
• Corrective action 
• Continuous improvement

Our company-wide work under this system is regularly audited and certified to industry standards.

Safety is a Core Value at Afton

 

All Afton employees take responsibility for their safety and the safety of their coworkers. We are all actively involved as a team to prevent accidents and demonstrate safety excellence through intervention and personal example.

Because safety performance is an indicator of our overall company performance, we have developed a health, safety, environmental protection and security (EHS³) management program that we embrace on every level of our company.  We adopted the Responsible Care^® program, developed by the American Chemistry Council, and follow its Guiding Principles to manage our operations and products effectively.

Since implementing the program, our safety record has been widely recognized for reducing and preventing injury.

In addition to promoting safety in the workplace, we extend this commitment to the communities in which we operate.  Afton works hard to make continuous progress toward our "Vision of Zero" - “no injuries, accidents, incidents, or harm to the environment,” and publicly reports our global health, safety and environmental performance. We believe strongly in ethical leadership that will increasingly benefit society, the economy, and the environment.

Safety Goals

• Provide a safe work environment

• Maintain a workforce committed to safety 

• Promote a culture of safety in the communities in which we operate

• Embrace a safety-first mindset in how we serve our customers and turn chemistry into solutions  

Product Stewardship

Afton is fully engaged with the definition of Product Stewardship as the “responsible and ethical management of chemicals throughout their life cycle.”

Our Global Business Directors are ultimately accountable for the safe development, manufacture, distribution, use and disposal of Afton petroleum additives. 

On a worldwide basis, Afton divides its petroleum additives business into two distinct segments: Fuel Additives and Lubricant Additives. Also, in most cases, the product manager acts as the Product Steward. 

Afton primarily communicates the hazards of its products to its customers by its Safety Data Sheets and its Hazard Communication Labels. These documents and labels are produced by carefully evaluating the hazards of the raw materials which constitute the products as well as a separate evaluation of the hazards of the products themselves.  

We support the principles of the Globally Harmonized System of Classification and Labeling of Chemicals (GHS) and have written GHS documentation to meet the regulatory timescales of various countries who are implementing GHS.

Further information and Product Stewardship Summaries for high-priority products are available upon request by contacting Afton’s EHS³ Product Stewardship Group (804) 788-5800.

View Product Stewardship Summaries Here

Product Risk Management

Managing risk – to our employees, customers and their end-users – is a responsibility Afton Chemical takes very seriously. We have formalized our proactive approach to a company-wide Product Prioritization & Risk Characterization Process.

Product Identification

First, we define our products as purchased raw materials and produced components, which are sold or blended into Afton products. We collect all relevant data on the product from internal and external sources, including product use, chemical composition, purity, physico-chemical properties, etc.

Hazard Assessment

Once we’ve identified a product and its properties, we determine its hazard potential through a multi-pronged approach. We gather physical, toxicological and environmental data from suppliers’ SDSs, in-house analytical data, testing, and published scientific literature. We use this information to assess the hazard potential in compliance with these regulations and benchmarks:

• OSHA Hazard Communication Standard (29 CFR 1910.1200) 
• EU Directives 
• Canadian WHMIS regulations

Afton’s Chemical Hazard Rating System

We then classify the products according to the regulations of the world regions in which they are manufactured or supplied. Finally, we publish the hazard classification for each of our products on the SDS supplied to every customer, regardless of whether the product is classified as hazardous or not.

Exposure Assessment

Another key component in Afton’s process is exposure assessment.  We consider factors such as product end-use, exposure potential, exposure routes, nature of anticipated exposure, and the amount of material involved in potential exposure. Based on these factors, we determine how much of the material a person or population may be exposed to, if an exposure were to occur, and we assign appropriate exposure ratings.

Risk Management

Risk Management is a function of the hazard of a substance and exposure to it (Risk = Hazard x Exposure). To best manage this, we take into account the relationship to applicable stakeholders, such as consumers, neighbors, and the environment. Once a product is prioritized and characterized, we develop a specific risk management strategy for the product commensurate with that risk.

Re-evaluation

This process never ends, and re-evaluations of a product’s risk characterization and management might occur for several reasons, including:

• Availability of new information through research, analytical or other sources 
• Changes to Afton’s internal production process 
• Changes to ingredients 
• Changes to applicable regulations or standards, etc.

Afton Completes its EU REACH Registrations

Afton Chemical has successfully completed all of its chemical substance registrations under the EU’s REACH Regulation ahead of the May 31, 2018 regulatory deadline. Afton’s REACH implementation project began in 2006 and has resulted in the registration of over 130 substances at a cost in excess of $10 million. These registrations ensure that both Afton and its customers can continue to import and use Afton’s products without interruption in the EU.

REACH is the European Union’s legislation on the Registration, Evaluation, Authorization and Restriction of Chemicals. REACH imposes many obligations upon chemical companies who do business in the EU, especially those who manufacture within the EU or import chemicals into the EU. These obligations have been phased in over an 11-year period. All chemical substances that are manufactured or imported into the EU at ≥ 1 MT/year must be registered with ECHA, the European Chemicals Agency which is based in Finland.

Afton has delivered numerous presentations on REACH to its customers, employees and at industry conferences. We are involved in several industry consortia and in many Substance Information Exchange Forums (SIEFs). We continue to actively help our customers meet their REACH obligations for the chemicals they purchase from Afton.

Declarations of REACH Conformance (DRCs) are provided to Afton’s customers free of charge. This is their evidence that the products that they buy from Afton are in conformance with REACH. Many challenges are being faced by the chemical industry in complying with REACH, but Afton is well placed to meet these challenges.

For further information on REACH please contact Afton’s EHS3 Product Stewardship Group on +1-804-788-5800 or email.

Regulatory Affairs

As a partner of Afton Chemical, you’ll benefit from our commitment to providing regulatory affairs guidance and support for both new and existing chemical projects. At each level of our organization, our employees are trained and committed to meeting all regulatory requirements associated with their particular job functions. Afton also works closely with government agencies and industry groups in support of safety and regulatory compliance programs.

Ways We Help Our Customers

• Monitoring global regulatory developments and communicating relevant activities
• Partnering in the development of new chemical substances and technologies
• Minimizing time to market
• Minimizing development and manufacturing cost
• Providing advanced screening for potential risk
• Maximizing the prospects for timely governmental review and approval

Internal Activities

• Auditing for regulatory compliance in R&D and plant operations
• Submitting new chemical notifications and product registrations
• Responding to and submitting existing chemicals information
• Nominating substances to developing new country inventories
• Providing acquisition due diligence and acclimation into Afton's regulatory system
• Interpreting chemical control regulations, and accessing areas of concern or interest

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