Policies & Certifications
At Berry, safety is our number one priority. Through our investments in safety equipment and training, we have lowered our incident rating to one of the lowest in the industry.
It is the policy of Berry Global Group, Inc. and its subsidiaries to conduct business in accordance with the highest ethical, moral, and legal standards. In so doing, Berry Global will conduct its business efficiently, in good faith, with due care, and in the best interest of the Company, its employees, and its shareholders. To read more, or to browse the governance documents and committee charters, view our Corporate Governance page.
Employee Health & Safety Management System
We track our total recordable incident rate as our key performance indicator for this disclosure. Our recordable incident rate is calculated using U.S. OSHA's classification criteria.
Industry average is based on the incident rate of nonfatal occupational injuries and illnesses for Plastics Product Manufacturing (NAICS 3261) as published by the United States Department of Labor's Bureau of Labor Statistics:
*2019 industry average data is not yet available. 2018 data was used as an estimate.
Berry Global maintains the highest possible standards of product stewardship to ensure the safe and responsible utilization of materials in enhancing the quality of life through design and development. For further information, please refer to:
Product Stewardship Policy
Berry has an active and robust product safety program. All newly proposed raw materials are subjected to a regulatory review screening process. This involves collecting safety documents and detailed regulatory disclosures from the manufacturer/supplier of the raw material, including completion of our Raw Material Information Form (RMIF). Click here to see an example. Prior to purchase, every proposed raw material is subjected to regulatory screening to identify regulatory constraints, EHS concerns, freedom to operate, compatibility with other raw materials and suitability for intended end uses. The results of the screening are used to make purposeful decisions regarding purchase. Many proposed new raw materials are rejected each year and do not become part of the raw material portfolio. Raw material product literature is loaded into systems where all Berry employees can access as needed. Regulatory information for each approved raw material is linked with the assigned raw material item number and loaded into the Enterprise Resource Planning (ERP) system.
Berry actively monitors regulatory activity, which could affect Berry operations and products. Berry uses subscription-based service, participation in trade associations, list server notifications, weekly newsletters from regulatory agencies and regulatory alerts from law firms to stay aware of proposed and new regulatory rules. This allows Berry to assess the potential business impact from new regulations, an opportunity to comment on proposed legislation and implement actions required to assure compliance. In cases where new regulations have an impact on existing products, Berry works with its suppliers to identify alternate raw materials and/or develop new products, which meet the new requirements. Berry often reaches out to suppliers requesting reformulated raw materials to eliminate certain regulated chemicals or move to chemicals that reduce the overall environmental and social impacts of Berry products.
Berry Finished Goods
Berry provides product regulatory information on-demand for any finished good in Berry’s portfolio. Berry uses regulatory information collected from raw material suppliers for each raw material present in the composition and provides regulatory information for the finished good(s) of interest. Berry has partnered with many customers to reformulate existing products to remove specific substances. This work improves consumer safety and reduces regulatory risk for both Berry and our customers. In some cases, Berry has recommended changed proactively. In other cases, changes were driven by a customer’s Restricted Substance List (RSL) or Substances of Interest (SOI) list.
Berry conducts testing, as needed, to verify product safety and demonstrate regulatory compliance. Examples include: Biocompatibility testing for nonwoven products used in healthcare and hygiene applications Food and drug contact compliance, on multiple continents Consumer Product Safety Commission (CPSC) testing for child resistant closures.
Berry holds numerous product registrations/certifications across our many product lines and broad geographical footprint.
Management of Change
Berry has an active Management of Change (MOC) program to assure that changes to finished goods meet all regulatory requirements, customer specification and contract conditions, product functionality, performance equivalence, and safety. Our MOC program minimizes the likelihood of risk when changes are made.
Chemicals of Concern Case Studies
Historical Case Studies
Berry Global manages chemical substances within plastic products to help companies meet their goals. Below are some examples of how we have optimized our customers’ plastic products through chemical management.
Berry removed Pigment Green 7 from all plastic products sold by a multinational consumer goods corporation due to an impurity of hexachlorobenzene that was linked to cancer and developmental toxicity.
Berry removed Phthalates from a consumer goods corporation’s hygiene product line containing Polypropylene. This corporation’s informed decision to remove these phthalates inspired a multinational oil and gas corporation to act similarly. Within 18 months of this discussion, this oil corporation began offering phthalate-catalyzed and non-phthalate catalyzed polypropylene resin.
Berry removed NMP (1-methyl-2-pyrrolidinone) from tape adhesive in products with concentrations exceeding 0.3% in substances. The impacted tapes have been completely reformulated without the NMP.
Berry removed Solvent Yellow 93 from all food packaging products after it was newly characterized in 2018 by ECHA as a reproductive toxin. All Solvent Yellow 93 containing color concentrates have been reformulated, and Berry has added Solvent Yellow 93 to its Prohibited Pigments list to prevent its future use on any product.
Ongoing Case Studies
Berry continues to manage and eliminate potentially hazardous chemicals from our customers’ products lines. Here are several of our ongoing chemical management projects:
A multinational personal care corporation has created a Restricted Substances List (RSL) for their products and packaging. Berry is actively working with this corporation to satisfy their need for PFAS elimination.
A multinational consumer goods corporation recently added talc to its list of Substances of Interest (SOI). Berry is actively working with this corporation to satisfy their request to eliminate talc from their entire product line.
A multinational consumer goods corporation has recently detected iso-nonylphenol on products shipped in stretchwrap. Iso-nonylphenol is a degradation product of Tris(nonylphenyl) phosphite (TNPP), a common additive used in PE films. Berry is actively working with this corporation to remove TNPP from the stretchwrap used for their products.
A global supply chain management corporation maintains a Restricted Substance List (RSL) for packaging. Berry is working diligently with this corporation to develop and provide ink systems which do not contain RSL substances.
Berry established internal product policies including:
Implant and Fluid – Tissue Contact Application
California Proposition 65
Pesticide (ingredients and products)
Additionally, the following documents are available externally:
Restricted Substance List (RSL) Policy
CTSCA – Global Acquisition and Accountability Policy
Modern Slavery Act Transparency Statement
Code of Business Ethics
Supplier Code of Conduct
Terms and Conditions
Scope of Social Supplier Standards
Berry Global Group, Inc. our affiliates, divisions, and subsidiaries strive to conduct business in a responsible manner. As we expand our business activities abroad and work with suppliers globally to meet customers’ needs, it is important to preserve our collective commitment to human rights in the workplace as well as to a safe work environment.
In order to continue to honor these values and principles, we have decided to conduct business only with suppliers who share a similar commitment. We have created a Supplier Code of Conduct to outline what we expect from our suppliers with respect to labor and employment rights, environmental health and safety, ethics and social responsibility, and global trade practices. Suppliers are expected to adhere to our Supplier Code of Conduct and must operate in full compliance with all applicable laws and regulations.
When local laws and regulations are less restrictive than our Supplier Code of Conduct, we expect suppliers to adhere to our principles. Failure to comply with internationally recognized standards and the standards set forth in our Supplier Code of Conduct may result in the termination of our business relationship. Berry may conduct on-site audits to ensure compliance with our Supplier Code of Conduct.
At Berry, we expressly prohibit discrimination, harassment, and retaliation based on race, color, gender, sexual orientation, gender identity, pregnancy, religion, creed, national origin, veteran status, disability, age, or any other category protected by law. Berry prohibits any actual or attempted reprisals or retaliation against an employee who raises a concern that this policy has been violated or who cooperates in related investigations. Berry takes all allegations of discrimination, harassment, and retaliation very seriously and is firmly committed to ensuring a workplace free of those discriminatory activities. Anyone engaging in discrimination, harassment, or retaliation is subject to disciplinary action up to and including termination.
Collective Bargaining Agreements
As of the end of fiscal year 2019, we employed approximately 47,000 employees with approximately 20% of those employees being covered by collective bargaining agreements. The collective bargaining agreements covering a majority of these employees expire annually and as a result, are due for renegotiation in fiscal 2020. Our relations with employees under collective bargaining agreements remain satisfactory and there have been no significant work stoppages or other labor disputes during the past three years.