PowerPoint-Pr

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Never change a running process?
Key factors for substitution decisions in complex
products and production processes Presentation
at Substitution and Alternatives Assessment
Methodologies Workshop Univ. of Massachusetts
Lowell December 2-4, 2004 by Lothar Lißner Dr.
Joachim Lohse
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MAJOR SOURCES FOR OUR PRESENTATION

• Report 1 Substitution of Hazardous Chemicals
  in Products and Processes
  Report compiled for the EU-Commission,
  DG Environment Hamburg, March
  2003 by Ökopol and
  Kooperationsstelle Hamburg
• Focus onCompilation of policies, legislation
  and public activities in the EU and the EU-Member
  States Case studies for certain chemicals in
  products and processes

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CASES IN THE EU-STUDY
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MAJOR SOURCES FOR OUR PRESENTATION

• Report 2 Options for the design of innovation
  systems for the successful
  substitution of hazardous
  substances S u b C h e m
• Research report for the German Ministry
  for Research and Technology
  (BMFT) Hamburg,
  September 2004,
• by University of Applied
  Sciences, Ökopol and
  Kooperationsstelle Hamburg
• Focus on Substitution as innovation process
  Case studies in certain industriesInterviews
  with actors from all areas enterprises, public,
  scienceNational workshops on issues as Guiding
  principles, Management systems

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SELECTED CASES IN GERMANY
FIELD OF APPLICATION CONVENTIONAL CHEMICALS AND POSSIBLE SUBSTITUTES
Industrial cleaning of metal surfaces Water-based cleaners vs. organo-halogen solvents
Softeners in plastics DEHP vs. alternatives as DINP or DIDP
Mould releases (concrete separating agents) Petrochemical products vs. esters based on renewable vegetable oils
Fibres in automotive silencers Conventional man-made mineral fibres vs.. biosoluble fibres
Mineral fibres in automotive catalytic converters Ceramic fibres vs. biodegradable fibres
Cutting fluids Petrochemical oils and biocidal additives versus minimum quantity cooling lubrication
Automotive series coatings High solvent coatings vs. low solvent coatings
Cement Chromate cement vs. cement with additives to reduce skin diseases
Stripping agents Methylene dichlorid vs. MDC-free stripping agents
Printing inks in packaging printing Solvents vs. UV-drying
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SUBSTITUTION STANDS FOR A VARIETY OF CONCEPTS

• Policy level Substitution as a general policy
  guideline without specific instrumentation.
  Substitution is obligatory, wherever it is
  possible
• Policy level Substitution as a causal argument
  for a market restriction aiming at relative risk
  reductionSubstitution as policy instrument with
  high priority
• Enterprise level Substitution as an integrated
  part of a management system on the enterprise
  levelSubstitution as a permanent part of the
  risk analysis
• Enterprise level Substitution as a continuous
  duty for producers to evaluate the used
  substances and alternatives and assess / compare
  the evaluated riskSubstitution as a permanent
  highly important part of the risk analysis and a
  measure with a high priority

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SUBSTITUTION AS KEY ELEMENT IN POLICY AND
LEGISLATION

• Substitution is a key concept in the EU Strategy
  for a Future Chemicals Policy (COM200188)
• Legal Obligations for EU Enterprises as -
  Chemical Agents Directive 1998- EU Biocides
  Directive on placing biocidal products on the
  market, 1998
• A legal obligation for German enterprises to
  substitute exists since 1986 in the Ordinance on
  Hazardous Substances

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SUBSTITUTION AS KEY ELEMENT IN POLICY AND
LEGISLATION

• Germany Ordinance on Hazardous Substances, 1986.
  16, Para. 2 The employer must check whether
  substances, preparations or products with a lower
  health risk than those he intends to introduce
  are available. If it is reasonable for him to use
  such substances, preparations or products and if
  substitution is necessary to protect the life and
  health of employees, only they may be used.
• EU Council Directive 98/24/EC of 7th April 1998
  on the protection of the health and safety of
  workers from the risks related to chemical agents
  at workArticle 6 (1) The employer shall ensure
  that the risk from a hazardous chemical agent to
  the safety and health of workers at work is
  eliminated or reduced to a minimum.(2) In
  applying paragraph 1, substitution shall by
  preference be undertaken, whereby the employer
  shall avoid the use of a hazardous chemical agent
  by replacing it with a chemical agent or process
  which, under its condition of use, is not
  hazardous or less hazardous to workers' safety
  and health, as the case may be.

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SUBSTITUTION AS KEY ELEMENT IN POLICY AND
LEGISLATION

• EU Directive 98/8/EEC on placing biocidal
  products on the market
• 10 (5) (i)
• An entry of an active substance in Annex I
  (positive list of allowed active substances)
  ..... may be refused or removed, ...if there is
  another active substance on Annex I for the same
  product type which, in the light of scientific or
  technical knowledge, presents significantly less
  risk to health or to the environment. When such a
  refusal or removal is considered, an assessment
  of an alternative active substance or substances
  shall take place to demonstrate that it can be
  used with similar effect on the target organism
  without significant economic and practical
  disadvantages for the user and without an
  increased risk for health or for the
  environment...

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MAIN STRATEGIES TO REDUCE RISKS FROM HAZARDOUS
CHEMICALS

• Hazard reduction approach Substance-oriented
• Emission control approach Risk-oriented
• Personal protection approach Exposure-oriented

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MAIN STRATEGIES TO REDUCE RISKS FROM HAZARDOUS
CHEMICALS
Substitution Type 1 Replace hazardous by a less
hazardous substance while maintaining technology
/ product functionality
Substitution Type 2Use a less hazardous or
non-chemical solution by changing the technology
/ product functionality
Substitution Type 3 Use a less hazardous or
non-chemical solution by changing the work
organisation / product use pattern
             
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APPROACHES OF SUBSTUTIONEXAMPLE REDUCING LOSSES
FROM CONSUMER PRODUCTS PLASTIFIER IN FLOOR
COVERINGS
Approach 1 Substitution by less toxic
plastifyers Approach 2 Substitution by less
mobile plastifyers Approach 3 Emission control
by chemical containment Approach 4 Meet same
functionality with alternative material
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OUR FINAL DEFINITION OF SUBSTITUTION

• Substitution means the replacement or
  reduction of hazardous substances in products and
  processes by less hazardous or non-hazardous
  substances, or by achieving an equivalent
  functionality via technological or organisational
  measures.

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SUBSTITUTION DEFICITS IN PRACTICE

• Most enterprises do not follow the most simple
  rulesCited from BAUA Federal Institute for
  Occupational Safety and Health in Germany All
  in all it can be assumed that around 70 of
  commercial users of hazardous substances do not
  (or cannot) observe the statutory requirements of
  employee protection.
• HSE In approximately 1.3 million British
  companies chemicals are handled. When questioned,
  only 16 of these companies were able to state
  the applicable law for handling chemicals or the
  limit values for these substances at the
  workplace.
• The European Agency for Safety and Health at Work
  states in a laconic way There is a need for
  monitoring compliance with legislation .
• By way of reaction to the evident deficit in
  implementing the differentiated
  chemicals/hazardous substance legislation in
  Europe, the authorities responsible in all EU
  Member States set up the CLEEN network (Chemical
  Legislation Enforcement Network).

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SUBSTITUTION CASE STUDYFAÇADE CLEANING
Substitution from chemical façade cleaning to the
use of mechanical cleaning with water (high
pressure cold and hot)
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SUBSTITUTION CASE STUDYFAÇADE CLEANING
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SUBSTITUTION CASE STUDYMETAL SURFACE CLEANING
ORGANOHALOGENS
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SUBSTITUTION CASE STUDYMETAL SURFACE CLEANING
PETROCHEMICALS
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SUBSTITUTION CASE STUDYBROM. FLAME RETARDANTS
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SUBSTITUTION OVERVIEW OF INFLUENCE FACTORS
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RESULTS ENTERPRISES

• Enterprises with superior interest in innovation
  to replace dangerous chemicals to substitute -
  are few. Cases with purely market driven
  substitution are rare.
• Main arguments encountered are
• too time-consuming task
• "no one takes the lead
• "unclear interests, roles and responsibilities
  of potential co-operation partners
• - problems occur immediately, success is only
  expected
• Co-Evolution with other actors of the supply
  chain is necessary but does often simply not
  happen due to insufficient communication.
• Public forces become influential where chemicals
  are under public concern or discussion.

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RESULTS ENTERPRISES

• In order to avoid problems regarding process
  integration and product quality, companies
  normally prefer to
• take small steps towards less hazardous
  chemicals instead of big steps (e.g. metal
  parts cleaning HC development).
• apply emission control or protective measures
  rather than undergoing changes in process or
  product performance itself
• Large companies assembling a product from a large
  number of supplied components like electronic
  or car industry have developed their own
  substitution rules (strict control, internal
  black and green lists etc.).
• In some branches green and ethic considerations
  have an increasing strategic impact.

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RESULTS PRODUCERS OF CHEMICALS
Often the producers of chemicals offer a range of
products (with different hazard properties) to
meet a certain technical demand(e.g. metal parts
cleaning, facade cleaners, mould releases, wood
preservatives, loss lubricants, etc.) In some
areas producers are locked in to a special type
of chemicals and have limited choices to offer
alternatives (producers of chlorinated solvents,
NiCd-batteries) One producer (or few) is
successful on the market with an innovative and
less hazardous product (competition)
(Rechargeable energy storage, printed circuit
boards, metal parts cleaning) Traditional
resources become more expensive (or are
anticipated to become more expensive) (loss
lubricants, NiMH batteries).
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RESULTS IMPORTANT OTHER INDUSTRIAL ACTORS

• The suppliers (traders) between producers and
  users play an important but underestimated role.
• They can function as
• strong propagators (big retail chains in the
  textile industry)
• - or as a real barrier (Metal parts, Mould
  releases).
• Equipment producers potentially play an
  innovative role, because a change of chemicals
  often includes the opportunity to sell new or
  additional equipment (emission control and
  substitution.)

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RESULTS AUTHORITIES
Authorities as substitution promoters Authorities
present more and more guides to industry in form
of reference cases, descriptions of substitute
chemicals or easy-to-use assessment methods. Some
authorities use their influence to start
dialogues in a certain sector to initiate a
substitution development or a better
communication between the good and the bad
companies (KEMI dialogue projects). Authorities
as substitution strategists Authorities develop
more and more models and strategies to clarify
and fix their own substitution policy (e.g.
Sweden - New Guidelines on Chemicals Policy,
Netherlands - Quick Scan in SOMS).
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CONCLUSIONS AND RECOMMENDATIONS
INCREASE OF TRUST IN FUNCTIONAL EQUIVALENCE OF
SUBSTITUTES Dissemination of successful pilot
and reference applications in companies in the
sector via branch organisations, trade journals
or databases. In special cases public support
can ease the burden of first users. Test of the
substitutes in less sensitive areas step by step.
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CONCLUSIONS AND RECOMMENDATIONS

• FULL PICTURE OF THE ECONOMY OF THE SUBSTITUTE
• When comparing the current situation with a
  possible alternative situation, economic
  considerations should include factors as
• Price / performance ratio
• Man hours connected with the use of the
  substance or preparation
• Investment costs for technical equipment
• Energy consumption
• Price of freshwater and waste water treatment
• Environmental protection costs (air, soil and
  water)
• Health and safety protection costs
• Waste management and disposal costs and
• Accident and fire protection incl. insurance
  costs.

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CONCLUSIONS AND RECOMMENDATIONS
AUTHORITIES AND THE MARKET To promote
substitution efficiently authorities should try
to act as goal setters and negotiators of
substitution (strategy development, sector
policies and guidelines, research policy,
dialogue with the concerned parties). The
development of financial instruments must be
strengthened. The market might be more
effectively influenced via financial advantages
than via detailed regulations.