PRODUCT LIFE CYCLE STAGES
1. BUY STAGE
System controls in our South African procurement process, continue to limit the risk of any inadvertent non-compliant purchases of controlled chemicals without the necessary authorisation and permits in place. This Sasol product registration process also assists with ensuring supplier compliance with the promulgated Regulation for Hazardous Chemicals Agents (RHCA) in South Africa, which is aimed at domesticating the Global Harmonized System (GHS) for product SDS & labelling. Sasol has also issued multiple communications to our suppliers to ensure supplier awareness and compliance with RHCA.
2. MAKE STAGE
We continue to prioritise the compliant, safe and responsible manufacturing of products through implementation of the procedure which supports compliance with chemical control legislation. In early 2023 we embarked on an update to this procedure, which coupled with an update to our Enterprise Resource Planning (ERP) system and provided an opportunity to review our product stewardship related businesses processes. The benefits of the streamlined and standardised business process across our businesses will support improved productivity, enhance operational efficiency, and proactively identify risks and opportunities across several environmental sustainability metrics. The business process for Product Life Cycle Management and for various elements relating to product information management were developed to enable and support clear communication of product information along the product value chain. Training material on chemical control legislation and the safe handling of hazardous chemicals continued to be rolled out to targeted employees along the value chain. Sasol, an Operation Clean Sweep (OCS) signatory, considers this voluntary international stewardship programme an important instrument to promote and implement good practices towards achieving zero polymer pellet, flake, and powder loss from our polymer manufacturing sites. During FY23 we continued to focus on embedding OCS fundamentals across our polymer production facilities.
3. SELL STAGE
We implement all applicable regulatory requirements, including being proactive to developing legislation, to secure and maintain our licence to manufacture and sell products in the numerous markets we serve. In 2023, work continued to revise and update REACH registrations for chemicals we produce or import into Europe following dossier and substance evaluations by the European Chemicals Agency (ECHA) and the European Union (EU) Member States. Sasol remains committed to the signed declaration of intent to support ECHA’s and the Joint Action Plan of the European Chemical Industry Council (CEFIC) to proactively and systematically review and improve, if needed, the data previously submitted in REACH registration dossiers. New chemical notifications were also filed in the United States, Canada, China, South Korea and Taiwan, among others. In Korea the first full registrations have been filed under the K-REACH scheme. We now identify products for which registrations will be filed by end of 2024. In Turkey, all relevant substances have been pre-registered under Turkey REACH and we now work with our Only Representative in Turkey to prepare the full registrations by end of 2023, This is done to support Sasol direct customers in Turkey. Sasol has filed “downstream user import notifications” (DUINs) for all products that were shipped to UK customers in 2019 and 2020 to support the existing business. For new products/new businesses and customers in the UK we have started to file full registrations in 2022 and continued in 2023. The EU REACH regulation will be revised in the coming year hence Sasol has started initial preparations to fulfil future requirements.
4. LOGISTICS STAGE
Our Transport Indicator of Performance (TIoP) is a group-wide measure of the incident severity rate as a function of product transport distance travelled. TIoP is split into two components: the TIoP reflecting on avoidable incidents and unavoidable incident. In December 2022, The Republic of South Africa experienced an unfortunate road incident involving a road tanker which resulted in multiple fatalities. Although this was not a Sasol incident, we undertook to understand the potential incident causes in order to review and optimise Sasol’s current road product transportation critical controls so as to prevent future such incidents or mitigate similar catastrophic consequences during its transport operations. Sasol Emergency preparedness primarily is the provision of product technical support to the Incident Command structure at an incident scene. Secondary support is through our 14 fully equipped hazardous material (Hazmat) trailers strategically placed on key routes throughout South Africa to support emergency services during the incident. Sasol also facilitated stakeholder engagements on the N1 and N3 notifying the Local Emergency Services of the type and characteristics of products on these routes.
5. USAGE STAGE
Customer assessments and awareness to ensure the responsible and effective use of our products is an important contributor to Sasol’s Responsible Care. commitment. Aligned to this, Sasol Chemicals Life Cycle management provides support to customers through formalised technical assessments and site evaluations, thus providing due diligence in terms of audits, storage requirements, product hazard characteristics and usage of our chemicals. Sasol Chemicals has recently completed Life Cycle Analysis (LCA) projects at its European production sites to cover its product portfolio with carbon footprints. Over 50% of Sasol Chemicals' total production volume is now covered by either a full or simplified LCA. This information and the underlying LCA models are used to conduct hot spot analysis and further support Scope 1&2 GHG reductions related to the production steps that occur on-site. Furthermore, the work will be used to identify potential Scope 3 related GHG reduction opportunities. Lastly, the project will enable Sasol to better engage with interested suppliers and customers on the topic of the global warming potential related our products. Sasol Chemicals will continue to refine and update the LCA work as required, for instance adopting the Together for Sustainability (TfS) guidelines on how to calculate Product Carbon Footprints (PCF) within the Chemical industry. We continue to report and investigate all Product Stewardship incidents for various scenarios covered by the key undesirable event (KUE): Loss of Product Data Integrity and or Availability. Defining, identifying and updating critical controls, through incident learning’s, from this KUE risk bowties including the implementation thereof through performance criteria provided the opportunity to improve the overall risk process, thereby enhancing prevention or mitigation of similar and related potential future incidents.
6. END-OF-LIFE STAGE
Sasol supports the South African (SA) promulgated Extended Producer Responsibility (EPR) legislation that enables the effective collection and beneficial recycling or re-use of plastic waste. The plans and actions executed since the inception of EPR in 2021 continues to ensure our compliance with the promulgated South African Section 18 EPR scheme notices. We continue to collaborate with our broader industry value chain stakeholders to embed EPR and achieve the required positive intended outcomes of this scheme for SA. Sasol is well positioned to comply with the recently promulgated lubricant sector EPR notice since Sasol has been actively involved in the voluntary South African EPR lubricant scheme through our participation as a founding member in the Recycling Oil Saves Lives (ROSE) Foundation since 1994. Further we periodically review our lubricant product portfolio, to proactively identify opportunities to reduce our environmental impact.
