Once a product is approved, additional data are collected so the Product Safety Department can generate a Material Safety Data Sheet (MSDS). This is accomplished by researching a variety of online databases to obtain the most current information pertaining to the product or its components. These databases typically include information on the toxicology of the product, first aid recommendations, instructions for the safe transport of the product, fire-fighting measures, data on environmental fate, and regulatory information on product components.

Prior to completing/approving the MSDS, an internal review team consisting of experts in HES and other disciplines review and evaluate the information contained in the MSDS. All members of the review team must approve their designated section(s) before an MSDS can be issued. Once the MSDS is approved, additional product safety documents are developed, including appropriate labels and product fact sheets as required.

Product Stewardship Forum
During 2005, Sunoco created a Product Stewardship Forum, consisting of representatives from the business units, to provide oversight and drive continuous improvement in the product stewardship area.  A Product Stewardship Steering Committee guides the Forum by identifying product stewardship initiatives and assisting the business units with the implementation of new processes designed to address the initiatives. The Steering Committee also monitors the effectiveness and efficiency of the process and suggests improvements, as appropriate.

In October, the Product Stewardship Forum held a one-day off-site meeting to review accomplishments year-to-date. A representative from the American Chemistry Council attended the meeting and reviewed the challenges that lie ahead for the industry regarding product stewardship. 

Networking Product Stewardship
In October 2005, several representatives from Sunoco attended the first meeting of the Product Stewardship Mutual Assistance Networking Group. The group consists of representatives from over 30 different companies and provides a forum to exchange information, ideas, and discuss issues pertaining to product stewardship. Sunoco will be hosting the next meeting of the group in March of 2006.

MSDS Request Page
MSDSs are distributed to our customers based on product orders and are also available by calling an “MSDS Hotline” manned by Product Safety Specialists. These Product Safety Specialists answer technical and regulatory questions about our products and field requests for MSDSs. A large number of these calls each month were from customers who just needed an extra copy of an MSDS. To provide better service to the customers Sunoco introduced a Web-based MSDS request page in 2003 making the MSDSs more accessible.

This online request process was enhanced in 2005 to provide our customers with a list of product categories and within each category, a list of the available MSDSs.  Also included was an “Ask a Question” feature that allows customer to request information on an obsolete product or just make general product inquiries. Online MSDSs requests are downloaded into our MSDS database and are electronically distributed on an hourly basis. Requests that require input from a Product Safety Specialist are handled by the next business day.

High Production Volume Challenge Program
Sunoco has continued its participation in the EPA's "Chemical Right-To-Know" initiative that challenges producers and importers of High Production Volume (HPV) chemicals (greater than one million pounds annually) to voluntarily provide basic toxicity information to the public. Sunoco joined the HPV Challenge Program in the spring of 1999 and pledged to participate for all Sunoco manufactured chemicals covered by the program (total of 118).

Sunoco is working with both the EPA and the International Council of Chemical Associations (ICCA), which has a recognized HPV-equivalent Program – HPV Chemicals Initiative. Both programs require producers and importers of HPV chemicals to gather the same health effects information on each chemical and provide it for public review.  The ICCA Program places both existing and new information on the Organization for Economic Co-operation and Development (OECD) Integrated HPV Database Web site and the EPA does like wise on their HPV Web site.

Joining with other manufacturers of similar materials to form consortia ensures maximum efficiency, avoids duplicative efforts and enables needed studies to be completed in a timely manner. Currently, the Sunoco-related consortia have reviewed available data to assess their adequacy, produced data summaries, developed and revised test plans and distributed those plans to all stakeholders for input.

The test plans include descriptions of any needed testing using a "product category" approach whereby products representing product lines, rather than individual products, are tested which leads to less use of animal resources. Animal protection is an important factor in this process and every effort is made to reduce or eliminate research involving laboratory animals.

All the "Test Plans" for Sunoco-volunteered HPVs have been submitted to the appropriate lead organization and posted to the internet. Some Plans have been completed while others are still undergoing the review process with closure for all HPVs expected in the next two years.

Children's Health Initiative
Through consortia formed under American Chemistry Council's CHEMSTAR Product Panels, Sunoco has also volunteered to sponsor its four chemical products that are included in the pilot Voluntary Children's Chemical Evaluation Program. Information from this cooperative industry-government program is intended to enable the public, the EPA and industry to better understand the potential risks to children associated with chemicals encountered in the environment.

The "Toxicology Excellence for Risk Assessment" (TERA) organization was appointed by the EPA as a "Peer Consultation Group" of scientific experts, who have substantial specialized experience in chemical toxicity testing and exposure evaluations. In their recommendations to the EPA, each TERA Chemical Panel makes a determination of whether the potential risks from chemical exposure have been adequately addressed by the information in the consortia submission. The EPA then decides whether the reviewed chemical needs further health effects testing and/or an exposure assessment to characterize their potential risks.

Of the Sunoco-sponsored chemicals in the pilot, acetone has already been fully evaluated by the EPA and found not to need further investigation while the other three are currently in the process of being evaluated. (Click here for the current consortia submissions and the review schedules).

Chemicals Product HES Team
In 2005, Sunoco Chemicals established a cross-functional Product HES team to drive product stewardship improvements.  This team was charged with establishing a business process to evaluate HES capabilities and controls of existing and potential High Hazard Product (HHP) customers.  This team’s goal is to avoid HHP incidents by ensuring that HHP customers have acceptable and sufficient HES control systems in place.  For example, the team will ensure that potential HHP customers have acceptable controls in place prior to shipment.

The Product HES Team achievements in 2005 included:

• Developed a Product HES Business Standard defining the roles and responsibilities of Product HES Team members and Service Task Teams for each HHP. These roles and responsibilities encompassed developing assessment checklists and training modules, conducting onsite assessments, and evaluating new and existing customers pertaining to their assigned HHP.
• Conducted onsite assessments of current Ethylene and Ethylene Oxide customers. These customers were evaluated for acceptable and sufficient HES capabilities and control systems.  The final assessment reports provided the customers with input regarding their operations, including product handling and storage techniques.

Phenol customer assessments are underway as seven customers were visited during 2005 with a three-year plan for full completion.  Benzene customer assessments will begin in February 2006 while Flammable Gas customer assessment plans are currently in the development stage. Besides customers, the Product HES Team also performs assessments of motor carriers, rail/truck transfer sites, third-party terminals, and rail car repair facilities (click here for related story).

Risk Review Process
A new online process for performing risk reviews on manufactured and purchased products was implemented in 2005.  The process, which includes a 2-stage Priority Risk Review and Risk Control Assessment was developed with input from representatives from Product Safety and Toxicology Services, Marketing, Product Development, Legal, Quality Assurance, and HES.  The first stage of the process evaluates products using identified priority risk facts and Stage 2 assesses the risk control measures of selected products to assure adequacy.

Sunoco Transportation personnel and the appropriate Product Stewards are notified of any “High Hazard Products” (HHP) that are identified through Stage 1 of the Risk Review Process.  Transportation personnel initiate Transportation Management System requirements and also maintain a list of all HHPs.  The Product Steward initiates further evaluation of the product through Stage 2 of the Risk Review process, assessing that the risk controls are adequate and that customers, suppliers and third-party facilities (i.e. storage terminals, etc) are handling or using the product correctly.

The process was piloted in 2005 using eleven representative Refining & Supply manufactured products, as well as several purchased products from an R&S facility.  

An inter-active site was created on Sunoco’s intranet. This site allows Sunoco personnel to complete risk reviews of both manufactured and purchased materials and enables the Risk Review Coordinator to monitor progress on each review on a real-time basis.  Once a risk review has been completed it can be uploaded to a document library which allows all Sunoco facilities access to the information, thereby allowing multiple facilities using the same purchased product to easily share and utilize risk review data.

Refining & Supply Contract Service Providers
Communications with Contract Service Providers, third-party companies that include storage terminals, distributors, pipelines, etc., is another key aspect of Sunoco’s product stewardship. At the 2005 Annual Distributor Meeting held in Charleston, SC, Sunoco outlined enhancements being made to the Product Handling Manual, on-site assessments, the Sunoco Web site and automated MSDS system requests.   

Self-assessment forms were mailed to Sunoco’s Contracted Service Providers who handle our products throughout the United States. On-site assessments, in which Sunoco personnel review the facility and their practices relative to sufficient HES capabilities and control systems, were performed at a number of third-party facilities during 2005.

HES Glossary
view glossary.

Conversion Table
view table.

Summary Report
download PDF

Chemicals Product HES Team
In 2005, Sunoco Chemicals established a cross-functional Product HES team to drive product stewardship improvements...
read more.