SHEACO

Safety Health and Environment

Action Committee

Unilever Framework Standards - Consumer Safety

The following document details the Unilever SHE Framework Standards which relate to
Consumer Safety Management. These Unilever SHE Framework Standards are applicable to
all organisations1 within Unilever. Taken together they describe a consumer safety
management system2.

Unilever SHE Standards which are more limited in scope i.e. those which apply to a
particular type of organisation e.g. Foods or HPC, or deal with a specific business risk, will
be published separately as Unilever SHE Specific Standards.

Within Unilever, SHE Framework Standards and Specific Standards have the same status as
Unilever “Enabling Instructions” i.e. they are mandatory.

Policy

010100 - Consumer safety Policy

All Unilever organisations must prepare and document an appropriate consumer safety
policy3, which is consistent with the Unilever consumer safety policy.

The policy must include:

 a clear statement of overall consumer safety objectives,

 a commitment to the prevention of consumer safety incidents,
 a commitment to continual improvement,
 a commitment to compliance with all applicable legislation and internal
Unilever standards e.g. SHEACO, Business Group, Category and Operating
Company.

The policy must be authorised and signed by the most senior person within the organisation.

The policy must be communicated across the whole organisation to ensure that all
individuals4 working for the organisation are aware of their individual and collective rights
and responsibilities.

The policy must be reviewed annually and where necessary revised to ensure that it remains
relevant and appropriate to the organisation.

1
The word “Organisation” in this document means all Unilever Head Offices, Business Groups, Operating Companies,
Head/Sales Offices, Marketing & Sales Organisations, Business Units, Sourcing Units, Factories, Plantations, Research
Laboratories, Regional Innovation Centres, Innovation Development Units, Warehouses and Distribution Centres.
The word “organisation” as used within these Frameworks Standards does not apply to non Unilever operations e.g. third party
co-packers. Unilever SHE Standards which relate to non Unilever operations will be published separately as Unilever SHE
Specific Standards.
2
Some organisations may chose to develop their Consumer Safety Management System as an integral part of their overall
Quality Management System
3
It is anticipated that many organisations will simply choose to adapt the Unilever consumer safety policy statement or that of
their parent organisation e.g. Business Group
4
While the term “individuals” working for the organisation includes employees, temporary employees, contractors and sub
contractors, Unilever’s primary duty of care applies to its own staff. Arrangements for other individuals must be proportionate.
Unilever organisations must not take on responsibilities which primarily lie with these individuals own employers.

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 SHEACO
Safety Health and Environment
Action Committee

Planning

010200 - Consumer safety risk assessment

Each organisation must operate in full compliance with Unilever’s toxicological safety
clearance system and comply with all related Unilever Consumer Safety Clearance Specific
Standards, e.g. those published by Unilever \ SHEACO on behalf of the Unilever Categories.

In addition, each organisation must identify the hazards 5 arising from its operations, activities
and services and determine those that may impact on consumer safety.

Consumer safety risk6 assessments must then be undertaken. These must include
microbiological, chemical and physical hazards plus the routine and non-routine activities of
all individuals working for, and the facilities and equipment provided by, the organisation.

Each organisation must seek to either eliminate or control effectively any identified
significant consumer safety risk7.

Where a risk assessment indicates the need for additional control measures, the
implementation of these additional control measures must be monitored until the work has
been completed and the effectiveness of these changes has been proven.

Risk assessments relating to significant consumer safety risks must be documented and then
kept under periodic review.

Consumer safety risk assessment must form an integral part of the organisation’s
development and management of change processes.

010300 - Legal and other requirements

Each organisation must undertake a regular review to identify all applicable consumer safety
legislation and all applicable internal Unilever standards e.g. SHEACO, Business Group
Category and Operating Company.

Each organisation must develop a plan which will ensure full compliance with internal
Unilever standards within a reasonable and defined timescale, agreed with its parent
organisation, e.g. Business Group.

All organisations must operate in compliance with applicable legislation, unless a specific
exemption or exemption period has been previously agreed with the relevant enforcement
authority.

5
A danger e.g. a hot surface, which is “exposed” is a called a ”hazard”.
6
“Risk” is a function of the probability of contact with (or exposure to) a “hazard”, multiplied by the likely severity of the
consequences of that contact or exposure.
7
A “significant risk” is one where additional control measures are required to either eliminate or reduce the risk of loss to a
level which is comparable with other accepted business risks

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 SHEACO
Safety Health and Environment
Action Committee

010400 - Objectives and targets

Each organisation must establish, document and maintain a set of specific consumer safety
objectives and targets, relevant to its current significant consumer safety risks and consistent
with its consumer safety policy.

010500 - Consumer safety management programme

Each organisation must establish and maintain a written management programme

(improvement plan) for achieving its objectives and targets. The means, responsibilities and
time-scales for achieving the organisation’s objectives and targets must be clearly defined
and adequate resources provided.

The management programme must be reviewed at regular and planned intervals and revised
as appropriate to reflect changing circumstances.

Implementation and Operation

010600 - Structure and responsibility

Within each organisation, the most senior person is responsible for the implementation and
performance of the organisation’s consumer safety management system.

Each organisation must nominate a competent person(s) to co-ordinate the overall

implementation of the organisation’s consumer safety management system. This person must
have access to the most senior person within the organisation.

Each organisation must define, document and communicate individual roles, responsibilities
and authorities for the implementation, control and improvement of the consumer safety
management system and provide adequate resources.

Each organisation must establish access to a source of competent expert advice on consumer
safety matters e.g. SEAC Enquiry Service.

010700 - Training, awareness and competence

Within each organisation, all individuals working for that organisation must be given relevant
consumer safety training or information, as appropriate. This training or information must be
proportionate to their consumer safety responsibilities, abilities, literacy and the consumer
safety risks associated with their work, including emergency preparedness.

Specific individual or group training needs must be periodically assessed to ensure that each
individual or group is competent to perform their role within the organisation’s consumer
safety management system.

Training programmes must make clear the importance of effective consumer safety
management to Unilever as a global company.

010800 - Communication

Each organisation must periodically provide consumer safety information, as requested by

Unilever, by its parent organisation e.g. Business Group, or where legally required to do so

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Safety Health and Environment
Action Committee

e.g. by an external authority.

Each organisation must establish and maintain a system for receiving, documenting and
responding to relevant communication from external interested parties.

010900 - Documentation

Each organisation must establish and maintain an information system, in paper or electronic
form, which:

 describes the core elements of the management system and their interaction,
 provides direction to related documentation.

011000 - Document and data control

Each organisation must establish and maintain systems for the management of all statutory
and other critical documents and data relating to its consumer safety management system.

011100 - Operational control

Having established its significant consumer safety risks, see Framework Standard
“Consumer safety risk assessment”, each organisation must identify those operations and
activities where control measures need to be applied.

Each organisation must plan these activities to ensure that they are carried out under specified
conditions by establishing and maintaining:

 documented procedures and/or work instructions to cover situations where their

absence could lead to deviations from the consumer safety policy or objectives and
targets,
 specific operating criteria in the procedures, where appropriate,
 systems for the purchase and/or use of substances, goods, equipment and services and
their identified consumer safety risks,
 systems for the design and maintenance of:

 the work organisation,

 the workplace,
 process installations, machinery
 equipment,
 operating procedures

including their adaptation to human capabilities, in order to eliminate or reduce

consumer safety risks at their source,

and by communicating relevant procedures and requirements to suppliers and contractors.

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Safety Health and Environment
Action Committee

011200 - Emergency preparedness and response

Each organisation must periodically8 identify and evaluate the hazards arising from its
operations, activities and services to determine the potential for serious incidents or
emergency situations.

Each organisation must establish comprehensive emergency plans to prevent or at least

mitigate the likely consequences associated with each potentially serious incident or
emergency situation.

Emergency plans must be documented and then kept under periodic review.

Where practicable (possible), each organisation must periodically 8 practise their consumer
safety emergency plans.

Checking and Corrective Action

011300 - Performance measurement and monitoring

Each organisation must establish and maintain systems to monitor and measure its consumer
safety performance on a regular basis.

These systems must provide for the measurement of :

 the number of consumer safety incidents and complaints,

 progress in the implementation of agreed objectives and targets,
 compliance with procedures, work instructions and defined operating criteria,
 compliance with applicable legislation,
 compliance with applicable internal Unilever standards,

The recording of this data must be sufficient to enable the identification of appropriate
corrective and preventive action.

Any monitoring equipment used must be calibrated, maintained and records of the calibration
results and any equipment maintenance retained.

011400 - Incidents, non conformances and corrective and preventive action

Each organisation must establish and maintain systems for

 the reporting and investigation of:

 consumer safety incidents and complaints,
 non-conformances9
 the reporting of serious incidents to Unilever,
 taking action to mitigate any consequences arising from such events,
 the initiation and completion of corrective and preventive actions,

8
More detailed requirements, regarding this issue, will be defined in a separate Unilever SHE Specific Standard - Consumer
Safety Emergency Planning.
9
The word “Non-conformance” as used in this document is defined to mean any deviation from procedures, work instructions,
specifications, operating criteria, applicable legislation or internal Unilever standards etc., that could either directly or
indirectly lead to a significant consumer safety incident

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Safety Health and Environment
Action Committee

 confirmation of the effectiveness of corrective and preventive actions taken.

Any corrective and/or preventive actions taken must be appropriate to the magnitude of the
problem and commensurate with the consumer safety risks identified.

011500 - Records and records management

Each organisation must establish and maintain a system for the identification, maintenance,
storage and retrieval of consumer safety records, including the results of audits, performance
reviews and management system reviews.

011600 - Consumer safety management system audits

Where required by its parent organisation, each organisation must ensure that its consumer
safety management system is subjected to an independent audit 10,11 in order to determine
whether or not the organisation’s consumer safety management system:

 conforms to planned arrangements for consumer safety, including compliance with

internal Unilever standards e.g. SHEACO, Business Group, Category, Operating
Company,
 has been properly implemented and maintained,
 is effective in meeting the organisation’s policy and objectives,

The key recommendations arising from these audits must be presented to the organisation’s
top management.

The organisation’s management programme must then be extended to include the actions
arising from the audit recommendations.

The time period between independent consumer safety management system audits must be
related to the degree of perceived business risk but must be no greater than every three years.

Management Review

011700 - Management review

Each organisation’s top management team must, at least annually, review the performance
and consider the adequacy of its consumer safety management system to ensure its
continuing suitability, adequacy and effectiveness.

The management review must address the possible need for changes to policy, objectives and
other elements of the consumer safety management system in the light of management
system audits, changing circumstances and the commitment to continual improvement.

10
An “independent consumer safety audit” is one undertaken by someone from outside the specific organisation being audited.
Alternatively, personnel who work for the organisation can undertake consumer safety audits, but in these circumstances the
audits must then be verified by someone from outside this specific organisation.
11
More detailed requirements, regarding both internal and ‘independent' auditing will be defined in a separate Unilever SHE
Specific Standard - Consumer Safety Management System

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