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Safer Chemical Alternatives: Reasons for Action
Table of Contents
Background and Overview
Reasons for Action
Identifying Chemical Hazards - Labeling Systems
Related Efforts, Tools, and Resources
Case Studies and Examples
Where to Go for Help
Complete List of Links

Essential Links:

Pharmaceuticals and Personal Care Products as Pollutants (PCPP)
Information on PPCPs, their environmental impacts, ongoing research, and environmental stewardship o...


Of the tens of thousands of chemicals in use today, many of which are used in high volumes, most have not been fully evaluated for safety and health effects. In 1976, when the Toxic Substances Control Act (TSCA) passed Congress, it grandfathered as many as 60,000 chemicals without testing. This law put onus on government, not industry, to prove the safety of any newly marketed chemicals. The U.S. Environmental Protection Agency (EPA) was not able to assess most of the grandfathered chemicals, partly due to the sheer volume of substances.  According to the Campaign for Safe Cosmetics, within the cosmetics industry alone, 89 percent of the more than 10,000 chemicals used in cosmetic products have not been evaluated for safety.

Full disclosure of chemical composition or additives in products are not legally required on all product labels or on material safety data sheets (MSDS) when an ingredient comprises less than 1% of the formulation for most ingredients, and 0.1% for carcinogens and certain other toxicity endpoints. Further, the Confidential Business Information (CBI) provision of TSCA allows companies to hide their chemical formulas if they provide sufficient reason to believe that making the information public would put them at a competitive disadvantage – aka “trade secret” status.

This lack of strong toxics regulation and standardized labelling requirements, along with the trade secret protection, and weak disclosure rules, make it difficult for the non-scientific community to clearly understand the type and hazard potential of chemicals used by industry and contained within products. TSCA reform is under discussion and not making significant progress, however the U.S. EPA is reportedly making initial efforts to reign in the CBI provision for some chemicals and formulations. And, there is some voluntary progress and market pressure towards full disclosure and transparency, from governmental bodies across the globe, or via the supply chain, and/or by consumers.

These are just a few of the reasons why finding safer chemical alternatives is becoming important, as a means of focusing on solutions rather than band-aids, stimulating innovation and prevention, and minimizing risks and trade-offs.

With respect to usefulness and practicality for manufacturers, especially small- to medium-sized manufacturers (SME), and for technical assistance providers to SMEs, a major reason to ensure safer chemical use is to reduce toxic or hazardous exposure to employees, and minimize environmental releases from a manufacturing facility. Additional benefits for manufacturers may include cost savings, reduced regulatory burden, possible for increasing market share with safer products, and increased employee awareness which can motivate action to address issues and find solutions.

Discussion around these drivers and a few examples of the benefits follow.

A Safer Workplace

Employees at a facility can be exposed to chemicals through inhalation of volatile chemicals, dermal absorption, or ingestion. Eliminating a toxic chemical, or reducing use, means that employees have a lesser chance of being exposed.

Reducing the volume of volatile organic compounds (VOC) used - or the level of volatility of a compound - reduces inhalation exposure to employees, and may have an added benefit of needing a lower-intensity air treatment system.

As an example of a reduction in dermal and lead dust inhalation exposure, the AlphaGary Corporation successfully launched a Lead Reduction Pilot Program, in which they evaluated the use of alternatives to lead compounds in their products, while producing materials of equivalent or improved quality. This evaluation allowed the company to successfully incorporate these alternatives into their design process and reduce the time to bring new products to market. By 2004, the company experienced a 30% reduction in the use of lead and lead compounds, as well as reducing other toxic materials such as cadmium compounds and other heavy metals. They also worked with a packaging to redesign packaging. With these combined efforts, the company significantly reduced the exposure risk related to personnel handling of lead-based products. (Read full case study).

At times, a hazardous chemical can be reduced (or sometimes even avoided) by redesigning a product or process. As a case study example where the selected "alternative" was a process re-design (vs. a substitute product), Phillips Lightolier worked to increase efficiency of use of trichlorethylene (TCE). They replaced vapor degreasers with efficient rinsing systems, and increased drip time to reduce acid discharges. The changes yielded a reduction in over 1 million pounds in TCE use, and VOC emissions reduction from 125,000 to 12,000 pounds per year. Their air compliance costs became minimal. (See case study).

Regulatory Compliance

Many federal and state laws require compliance related activities associated with the manufacture of, use of, and waste generation or emissions of hazardous materials. Some of the federal laws are listed here. Note that states may have more rigorous versions of some of these regulations, enforced at the state level.

  • Toxics Substances Control Act
  • Emergency Community Right-to-Know Act (EPCRA) and its Toxic Release Inventory (TRI)
  • Clean Air Act (CAA)
  • National Emission Standards for Hazardous Air Pollutants (NESHAP)
  • Resource Conservation and Recovery Act (RCRA)
  • Clean Water Act (CWA)
  • National Discharge Pollutant Elimination System (NDPES)
  • Safe Drinking Water Act
  • Occupational Safety and Health (OSH) Act
  • Consumer Product Safety Improvement Act of 2008 (which incorporated the previously enacted bill, the "Lead-Free Toys Act" H.R. 3473)
  • Numerous state laws dealing with children's products safety

Elimination of regulated chemicals (or their wastes and emissions) will obviously reduce the amount of staff time needed to ensure compliance.

In addition to federal and state laws, some cities and counties are enacting legislation. Here is an example of a city resolution, passed by San Francisco, to ban the distribution of toys and childcare products that contain bisphenol-A or phthalates.

A current and continually updated list of legislation around safer chemicals and alternatives assessments can be found at the Interstate Chemicals Clearinghouse Wiki.

Cost Savings

For many businesses, it remains easy and inexpensive to use toxic chemicals. And, where significant redesign of processes or products might be necessary, companies fear high implementation and re-training costs.

In many instances though, the long-term costs of replacing or eliminating a toxic chemical give a high return on investment (ROI) when the true and full costs of chemical use and management are considered. The payback is often immediate in the case of drop-in replacements.

The true cost of use of chemicals extend beyondpurchase price and hazardous waste disposal costs.. Often, a less toxic chemical or product may have higher pound-for-pound purchase price, but will cost less over its lifetime. For example, a non-toxic alternative to a toxic product costs less to transport, store, handle, permit, and discard. It also often means less training for staff, and lower probability of an accident involving a toxic or hazardous material.

Accounting tools, such as environmental management accounting, allow for consideration of true costs, including direct labor and materials, manufacturing overhead, and administrative overhead, along with non-product output (waste, emissions, expired chemicals, etc.), water and energy inputs, air treatment and ventilation, waste management (testing, handling, handling, etc.), other regulatory compliance, and product takeback (for some companies). The Chemical Strategies Partnership (CSP) estimates that chemical management costs often amount to between 10 and 15% of the chemical spend [1]. A useful resource synopsis of environmental accounting concepts and case studiesis available from the EPA Environmental Accounting webpage and a few available tools complete with online training and downloadable software include NEWMOA's Energy and Materials Flow and Cost Tracker (EMFACT) and Texas Natural Resource Conservation Commission's Total Cost Accounting Software.

As an example, ESP Lock products replaced highly volatile lubricating oils use in making key blanks, with a non-VOC lubricant. Ultra-low volume misting units were installed to apply the oil in a much more efficient manner. They achieved a $20,500 annual savings in materials purchasing, and eliminated air quality and flammable storage compliance requirements. The company also saved over $5,400 per year on hazardous waste fees, while the exemption from air permitting saves them the internal staff time plus a permit application fee of $1,100 every three years. (See full case study).

Less tangible cost savings, from eliminating a toxic chemical, may come from lower employee absenteeism rates and reduced future liability from occupational or end user exposure, and environmental spills or releases.

When calculating cost savings and payback after eliminating a chemical, or replacing it with a safer alternative, any of the applicable and quantifiable costs mentioned above should be considered to capture the full potential savings.

Reduced Environmental Impacts

Replacing or eliminating the use of a hazardous material in manufacturing means that workers are no longer exposed. This also means safer products for end-users and elimination of the environmental releases associated with product use. For example, many household cleaning products containing antibacterials, fragrances, phthalates, glycols, bleach, etc.) eventually go down the drain to wastewater treatment plants.  A safer replacement also means that the industrial non-product outputs associated with the initial toxic chemical are also diminished or eliminated, such as emissions, effluents, and hazardous waste.

Empowerment

With the increased availability of publically available toxicity data, the developing field of (and developing expertise on) alternatives assessments, and efforts towards standardizing chemical classification and labelling, employers and employees can learn more about the chemicals in use, and work towards solutions that reduce overall releases and exposure. Knowledge of chemical safety can empower employees that work with chemicals, including maintenance staff, to initiate an effort or suggestion for change.

Increased Market Share with Safer Products

From international countries, to large companies that purchase millions of dollars worth of products each year for retail or direct use, on down to individual consumers, many are demanding products that do not put them or the environment at risk, or even a perception of risk.

Consumers, watchdog groups, and research groups, have proven the power to influence brand perception and markets associated with safer alternatives. For example, Nike, Adidas, and Puma have already reduced some toxins in their products and are promising to remove more toxics over time, in response to brand threats levied by Greenpeace. Women's Voices for the Earth, the Environmental Working Group, and others are conducting research and publicizing results of consumer product content analysis for many brand name cleaners and cosmetics, increasing consumer awareness and demand for safer products..

Some examples of international regulatory efforts include the European Union's (EU) Registration, Evaluation, Authorisation and Restriction of Chemical substances (REACH), the Restriction of Hazardous Substances Directive (RoHs), and the Waste Electrical and Electronic Equipment Directive (WEEE), which restrict the chemicals permitted in products. U.S. products containing chemicals banned by any of these regulations cannot be sold in the EU, limiting export markets.

Many companies, trade associations, and consortia, such as Hewlett Packard, American Apparel & Footwear Association, Nike, Inc., and Levi Strauss & Co., have introduced restricted substances lists (RSL). RSLs include chemicals that these entities have chosen to eliminate from their products. Suppliers will maintain or increase market share if they can comply with these RSLs.

Finally, employing the best environmental practices and using the least toxic materials in manufacturing, is important for maintaining a good image with the public and other stakeholders, as well as attracting new customers and maintaining competitiveness.


[1] CMS Forum. 2004. Chemical Management Services Industry Report, 2004. (Acquired from the Chemical Strategies Partnership).


 

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Hub Last Updated: 12/29/2013