Product Stewardship: Responding to Regulatory Requirements
Our product stewardship efforts have expanded in recent years to meet growing regulatory pressures on both nickel and cobalt. Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH) regulations have defined chemical management programs for refined metals in the European Union since 2006. The regulatory landscape is an ever-changing, fast-growing arena with market requirements becoming more stringent. Global markets are increasingly turning towards REACH-equivalent programs. In the past three years, our organization has expanded from one REACH registration in the European Union to two additional REACH registrations in the U.K. and Korea, with more on the horizon, including India and Taiwan. Every program has its own requirements for classification and labelling; retaining access to these markets is key to our longevity and growth.
Sherritt’s products are assessed on their whole product life cycle and include customer assessments, legal reviews, logistics and form of transportation, hazardous materials and emergency response, contracts and financial rate of return. Maintaining compliance with all product regulatory requirements in relevant markets involves assessing the hazards of the products of mining according to the United Nations Globally Harmonized System of Hazard Classification and Labelling of Chemicals, or equivalent relevant regulatory systems, and communicating through safety data sheets and labelling as appropriate.
In 2020, major engagements related to product stewardship included engagement with the Nickel Institute (NI) and the Cobalt Institute (CI), of which Sherritt has been a member since 2016. Sherritt contributes to the environmental and health hazard research for both nickel and cobalt to ensure that our classifications remain relevant and accurate. Sherritt is currently acting on various task forces and is represented on the boards of directors for both organizations. Sherritt has contributed to many REACH and scientific studies, including upcoming participation in a sampler comparison project from Safeworks British Columbia.
Other major achievements for 2020 included improving our nickel steel-grade product purity specification, publishing online versions of our specification sheets, performing a risk–benefit analysis of eliminating wooden pallets from some of our shipments, initiating a routine sampling campaign for radioactivity, piloting a crush and screen operation to improve our by-products, and double stacking our by-products to improve shipping efficiency. Continual improvement to satisfy our customers’ requests and anticipate their needs is Sherritt’s highest priority.
Product Life Cycle Assessment
Sherritt participated in the 2014 Cobalt Life Cycle Assessment (LCA) led by the Cobalt Institute, and the 2017 Nickel LCA led by the Nickel Institute, and is currently participating in the 2020 Cobalt LCA study led by the Cobalt Institute. Sherritt is also in the process of reviewing the 2017 Nickel LCA dataset to improve environmental performance throughout the value chain and promote the responsible use of our products. This includes research to support the energy-efficient and environmentally sustainable production of our products.