Consider a step-by-step approach to eliminating hazards
Guest Columnist: Lauren Heine, Ph. D., Principal of the Lauren Heine Group, LLC
I spend my time these days working with non-governmental organizations (NGOs) and consulting with companies, large and small, about greening their chemical inventories. In the early days of my career, while working as a Fellow with the Green Chemistry Program at the U.S. Environmental Protection Agency (EPA), I heard something that has stuck with me. I think it can benefit anyone whose company uses hazardous chemicals but would like to move toward safer, more environmentally friendly alternatives. The head of the Design for the Environment Program at EPA told me, “Environmental engineering is about end-of-pipe cleanup, but the future is about design.”
To me, that makes sense: Why treat problems when we can prevent them through good design? That’s what green chemistry is all about.
All of us are chemical users because we purchase and use chemical-intensive products. Some of us are chemists who make new molecules. Many people in industry are chemical choosers: people who select chemicals for use in making their company’s products, or for facility maintenance, repair and operations. Based on my experience partnering with companies that seek to be sustainable around chemicals, I categorize the journey that choosers go through in greening their chemical inventories into three phases.
Phase 1: Chemicals of Concern
In the first phase, choosers identify chemicals of concern: those to be eliminated from a company’s inventory. Some companies develop restricted substances lists (RSLs) based on national or international regulations or policies. RSLs are often specific to an industry and may include non-regulated chemicals that are undesirable (i.e., carcinogens or PBTs).
Examples of successful corporate RSL programs include a multibillion-dollar business-to-business (B2B) office equipment/computer supplier with a gate-keeping policy excluding 2-butoxyethanol in their cleaning product formulations. Likewise, a number of the world’s largest manufacturers of consumer food, beauty and household products have excluded nonylphenol ethoxylates (NPEs) from their products based on their risk assessment work. Additional tools like U.S. EPA’s PBT Profiler and third party B2B “product selector” software help companies identify chemicals of concern and the products that contain them.
Phase 2: Consider Alternatives
Phase two in going green entails looking for substitute chemicals or processes for chemicals you want to eliminate. You will want to be sure that the alternatives are indeed safer, and that they don’t bring other concerns. At this point you are likely to be faced with uncertainty in at least two dimensions: data gaps and the need to make tradeoffs between hazard characteristics.
While a chemical may not be a “chemical of concern,” it may not be entirely hazard-free. It might represent a tradeoff (i.e., an irritating chemical vs. an aquatically toxic one). And you may not have all the data needed to make an informed comparison. There are, however, a variety of tools to support decision-making in this phase, and arrive at valid product comparisons across all hazard endpoints. A growing number of companies and organizations offer green-screening methods/software. The EPA’s Design for the Environment Program helps chemists find safer, effective chemical alternatives for product formulations. And it goes without saying that E.U. REACH legislation will provide much of the missing data.
Phase 3: Decide What Constitutes “Green”
Choosers know they’re getting closer to greening their inventory when they ask, “What does good look like, and how can I measure it?” At this point you may decide to set a positive vision and start thinking in terms of desirable chemical hazard characteristics, instead of individual chemicals of concern. You’ll want to know what the attributes of a green chemical are—what makes it green overall, or green for its application–and key criteria for measuring whether a chemical has these characteristics.
Some companies in the U.S. have already positively defined criteria for product efficacy, safety and environmental health through product development standards. And there are online resources to select greener chemicals for cleaning product formulation.
With the growing public awareness of chemicals of concern and more availability of resources and data, it pays for choosers to be choosy. When it comes to going green in industrial chemicals today, you will find your way forward is open to innovation and that there is much to gain.
Lauren Heine Ph. D., is Principal of the Lauren Heine Group, LLC, a Senior Science Advisor for Clean Production Action and a Senior Fellow with Green Blue Institute. She is based in Bellingham, Washington.
Resources:
PBT Profiler: www.pbtprofiler.net
Dolphin Green Product Selector: www.dolphinsafesource.com
Green Screen for Safer Chemicals: www.cleanproduction.org/Green.Greenscreen.php
SCJ GreenList: www.scjohnson.com/community/greenlist.asp
DfE Partnership Programs: www.epa.gov/oppt/dfe
DfE Formulator Program: www.epa.gov/dfe/pubs/projects/formulat/formpart.htm
Coastwide SEGC 114: www.coastwidelabs.com/Technical%20Articles/Sustainable%20Earth.htm
CleanGredients: www.cleangredients.org
From Compliance Side Total Chemical Management Today, Vol. 3. No. 1 2006