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Regulatory Compliance

Consistent with the Trinseo EH&S Policy, Trinseo supports the development of laws, regulations, procedures, and operating practices that are science-based and safeguard workers, plant communities, customers, and the environment.

To facilitate this commitment, Trinseo has implemented a comprehensive approach for monitoring and complying with relevant industry standards and government regulations globally.

This approach includes the use of internal expertise, third-party consultants, regulatory databases, and industry associations to:

  • Develop and adhere to internal standards that ensure Trinseo’s products can be produced and sold globally while also complying with local requirements
  • Monitor and document compliance to existing regulations and industry standards
  • Implement compliance approaches for newly enacted regulations
  • Identify emerging regulations and industry trends
As stated in Trinseo’s EH&S Policy, “Health, safety, and protection of the environment are Core Values which are a part of everything we do.” Our focus on these Core Values, which include regulatory compliance, provides assurance that our products can be used safely in intended applications across the world, including sensitive end uses such as food contact and medical applications.

EU REACH 

Trinseo remains vigilant in its efforts to comply with global chemical laws, such as REACH (Registration, Evaluation and Authorization of Chemicals). REACH is the single regulatory system for chemicals management in the European Union (EU). REACH requires that EU manufacturers and importers of substances to the EU (starting with quantities of one metric ton per year) disclose information on the properties of their substances, including the risk to humans and the environment associated with use. Information on appropriate risk reduction measures must also be provided. 

  • Trinseo recognizes and fulfills the EU REACH registration requirements for the relevant substances it manufactures in (or imports into) Europe. In addition, Trinseo remains engaged in addressing the registration requirements for purchased substances by engaging in direct discussions with SIEFs, consortia, and direct suppliers. 
  • Trinseo conducts “downstream use assessments” and utilizes the exposure scenarios associated with substance registrations to ensure our operational activities are REACH compliant. Trinseo fully supports the objectives of REACH and the responsibility the legislation places on all members of the value chain to manage the safe use of chemicals. We believe it represents a significant opportunity for chemical manufacturers, their suppliers, and customers to work together to protect the environment and preserve the future of the chemicals industry in Europe. As other nations consider similar regulations devoted to chemicals management, Trinseo will support these efforts and implement appropriate compliance solutions. 

Trinseo is duly fulfilling its obligations resulting from the publication of the ECHA Candidate List for Authorization. Information on Trinseo products containing substances on the Candidate List (SVHCs) above reportable limits can be found in the Safety Data Sheets. Trinseo proactively sends these updated data sheets to all customers currently purchasing concerned products. 

Next Steps 


For further information about REACH, visit the REACH section on the European Chemicals Agency (ECHA) website: http://echa.europa.eu/web/ guest/regulations/reach 

Trinseo Maintains Responsible Care Certification

Having passed its Responsible Care® Management System audit in August 2013, Trinseo can use the designation of “a Responsible Care® company” on a global basis.

To maintain the voluntary certification – which is above and beyond what is legally required in most countries – an audit is administered every three years by a third-party auditor approved by the American Chemistry Council. The audit focuses heavily on operating discipline management systems, policies, and chain of authority.

Comparing us to other companies, the audit recognized Trinseo for strengths including:
Outstanding plant housekeeping especially for a top-tier chemical company
Detailed and practical site emergency plans
Comprehensive and best-in-class product stewardship programs

Trinseo’s next Responsible Care® Management System audit will be in August 2016.

Responsible Care® is a registered service mark of the American Chemistry Council in the United States.

EH&S Audits

As part of its commitment to sustainability, Trinseo conducts audits of its manufacturing and research and development facilities every three to five years. The purpose of these audits is to verify the status of Trinseo facilities with respect to meeting external authority and internal company environmental, health, and safety criteria. To assist with these audits, Trinseo retained ENHESA, a global environmental, health, and safety (EH&S) consultancy, who provide regulatory compliance assurance support to industry worldwide, to perform these audits. 

Audit teams are composed of experts in various disciplines such as environmental, personal safety, process equipment safety, transportation, security, and management systems. 
 

Keeping Pace with Global Regulations

In the past eight years, regulatory growth has nearly doubled around the world. This created a tremendous challenge to stay up to date on all the laws and regulations affecting operations in the 20 countries where Trinseo manufactures, and more than 40 countries where we ship product to customers. 

To meet this challenge, in 2015, Trinseo manufacturing sites around the world implemented a new compliance management tool that tracks current and new laws and regulations at the country, regional, province/county, city and local level, and sends a notification of new laws that affect the company. It provides comprehensive and timely information about regulations and laws related to air emissions, water management, waste management, chemicals management, hazardous materials management, safety, emergency response and preparedness and occupational health. 

The tool allows each manufacturing site to assess if Trinseo is in compliance, and if not, identify what actions are needed to get into compliance. 
 

Five Certified as EH&S Auditors

In 2015, five employees received EH&S Auditor certification following their completion of the Trinseo EH&S Auditor training program. With their certification, these employees, from the Netherlands, Finland, China, Belgium, and Germany, join a group of more 60 auditors from every country that contains Trinseo manufacturing sites. 

The Trinseo EH&S audit program is staffed 100% by volunteers—individuals within EH&S, Manufacturing, Research and Development, and Quality organizations with recognized EH&S skills, the desire to share and learn more about Trinseo technologies, and personal dedication to making sure the company is in compliance and delivering strong EH&S performance. 

Trinseo teams conducted 11 EH&S audits during 2015, at locations in China, Hong Kong, Taiwan, Germany, Sweden, Italy, Indonesia, and the United States.