CM Framework - KNOW-HOW

FINAL
FOR PILOT
April 22, 2013
Chemicals Management Framework

“KNOW-‐HOW” (Guidance)

Primary Information Resources,
Guidance Key Terms Defined Examples and Templates
Objective Tools & Services
There are numerous local, national and Chemicals used in manufacturing Information Resources
international laws and regulations that dictate processes vs. chemicals in products.
how retailers, brands and suppliers should Free newsletters on chemical
manage chemicals used in manufacturing The term chemicals used in regulations, e.g,: Actio:
processes and in products; and these laws are manufacturing processes refers to all compliance news
constantly changing and increasing. chemicals used in the manufacturing
of a product, including chemicals that Regulatory Databases
Every retailer, brand and supplier needs a may or not reside in the final product.
reliable system for tracking these regulations Companies can quickly
and for determining how their chemical This is best understood by an determine whether chemicals
management programs need to respond to example: An industrial cleaning are currently regulated by
these requirements. product (a mixture of chemicals or a government agencies around
formulation) that is used to clean a the world or have been
CM-‐1.0
In-‐house tracking of global regulations is metal part before it is painted or otherwise designated (but
Regulatory
typically done only by the largest companies, plated. The cleaning product is rinsed not currently regulated) as
Awareness &
and many of these large companies turn to third off the part prior to plating or painting chemicals of concern. The
Compliance
party service providers to assist them. and is not intended to be part of the GreenScreen List Translator,
finished product. While the chemicals an abbreviated version of the
There are several strategies that brands and in the cleaning product are not part of full GreenScreen method,
retailers can employ to require that their the product, and may not pose a risk screens chemicals based only
suppliers adhere to the “most stringent” to the consumer, they may pose a risk on government agency lists.
requirements, including: to workers in the factory where the The names and links to these
-‐ Supply agreements that require suppliers to cleaning product is used and to the government “red lists” can be
comply with the “most stringent” country’s environment when the cleaning accessed for free on the CPA
regulatory requirements. product is discharged from the website. If a company wants
-‐ RSLs that are pegged to the “most stringent” factory. to check if a chemical in their
country’s regulatory requirements (see 2.0 product or used in their
below). The term chemicals in products refers manufacturing process
to chemicals that are intended or appears on one of these lists,
© Outdoor Industry Association 2013 1

20130422_CM Framework_KNOW-‐HOW.docx
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anticipated to be part of the finished it is suggested that they use
product. Examples would include PLUM or Pharos (described to
dyes, silicone finishes, screen printing, the right)
inks, labels, a durable water repellent
chemical formulation, and other The SUBSPORT -‐ Substitution
chemical enhancements. Another Support Portal contains some
example is a chemical plasticizer government lists as well as
added to a plastic product or several corporate restricted
component. substances lists.

Some chemical mixtures used to make Service Providers
a product fall into both categories. A There are numerous
screen printing ink has some companies that provide
components that will become part of compliance assistance.
the garment and some that will not. Suggested internet search
The pigments and resins will remain string: chemical, compliance,
on the printed garment. The solvent service.
is used as the carrier for the other Contract service provides may
ingredients of the ink and will include companies like 3E,
evaporate (or be driven off) from the The Werks, Sitehawk, and
garment after the printing process is others.
complete.

Trace impurities could fall into both
categories, by intent or not.
A business may create its own restricted Restricted substances lists (RSLs) are Examples Information Resources
substances list (RSL) or adopt one or several a list of chemicals -‐-‐ compiled by
that already exist, which were developed by businesses, trade groups or other Restricted substances list (RSL) Case study describing Nike’s
CM-‐2.0 another company, a trade group, a government organizations -‐-‐ which are either examples process for updating its RSL
Restricted agency or non-‐governmental organization. completely prohibited in products, in • American Apparel and
Substances & packaging, from use in manufacturing Footwear Association (AAFA) Section 5 and Appendix C of
Substances of A business may find that an RSL is adequate for processes, or are prohibited above • Marks & Spencer’s (retailer) the AFIRM Supplier Toolkit
Concern their chemical management program. However certain threshold levels (often stated publicly available RSL provides best practice
there may be chemicals of concern for which in % or parts per million (ppm). guidance on ensuring
more information is sought or that the business Templates compliance with regulatory
might want to phase out over time. In this Substances of Concern List (SoCL) is a requirements and corporate
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manner, a Substances of Concern List (SoCL) can documented list which identifies Pages 64 & 65 of Nike’s RSL RSLs, including a Model Brand
be developed wherein chemicals may be specific substances which, for reasons Guidance contain a test Program Protocol for Testing
migrated to the RSL if and when appropriate. of increasing concern for suspected request form and an RSL Clothing.
toxicity, incomplete and/or Failure Resolution Form,
insufficient toxicity information, respectively.
pending regulation, other
environmental harm and/or market
shift, are prioritized for one or more of
the following actions: demand for
sufficient relevant toxicological
information, alternatives assessment,
and/or target for replacement.
Substances on the SoCL are not
necessarily restricted by an
organization. They do, however,
indicate a need for some type of
action. For some organizations a SoCL
may simply be an addendum to their
RSL.
Documenting Suppliers & locations. The first Categories of chemical Examples Information Resources
major step toward better access to chemicals data/information, include: Factory Lists
data is to know and document the company 1. Chemical ingredient information, Example of factory list with Appendix G of the AFIRM
name and geographic location of your suppliers, including chemical name, trade location from Mountain Supplier Toolkit (page 32)
i.e., the companies that should have access to name, and CAS number of chemical Equipment Co-‐op with explanations and
the chemical data that must be passed up the ingredients in an article or chemical examples of preferred and
CM-‐3.0 supply chain from chemical supplier, to users of mixture, including known impurities. Safety Data Sheets (SDS) non-‐preferred MSDSs
Process & chemicals in the manufacture of product, to 2. Function of a chemical ingredient Example of an ANSI compliant
Product brands and retailers. in an article or chemical mixture SDS Dimethylformamide (DMF) The MSDS FAQ
Chemicals (e.g. colorant/dye, ink, special
Knowledge Retailers and brands should maintain an chemical attribution, catalyst, Examples of good SDS from the Meeting Customers’ Needs
inventory or map of the companies from which plasticizer, monomer, finishes, U.S. Occupation Safety and for Chemical Data
they purchase final product, in order to establish processing/ancillary chemical, etc.). Health Administration’s GHS A guidance document for
a source of chemical data related to that 3. Process chemical information, Document in Appendix B suppliers, Green Chemistry &
product. In the case of a retailer this inventory including chemical name, trade Commerce Council (GC3)
would be its brands. In the case of a brand this is name, and CAS number of chemicals Chemical Data Supplier
likely a garment cut/sew/finish facility or other used to make a product. Templates/Questionnaires GHS -‐ Annex 4: Guidance on
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intermediary. Retailers that are purchasing 4. Chemical hazard data, human Voluntary Product the preparation of Safety
directly from suppliers or are sourcing private health and ecotoxicological Environmental Profile (see files Data Sheets
label are considered brands. characteristics of chemical in VPEP folder) (VPEP),
ingredients and chemicals used in American Apparel & Footwear Service Providers
Suppliers to brands should maintain a similar making that ingredient, as well as Association
inventory for chemical suppliers for all chemicals their physical safety properties such Companies needing
purchased. as flammability. Customizable Letter and assistance in preparing high
5. Potential for human or Template to request chemical quality SDSs can contact SDS
Getting chemical data from your supply chain. environmental exposure to information from a supplier, authoring service providers.
The second major step is to obtain chemical chemical ingredients in an article or Green Chemistry & Commerce Suggested internet search
data. When communicating with suppliers, be chemical mixture. Council (GC3) string: MSDS, authoring
clear in specifying the types of information
needed, how that information should be Safety Data Sheet (SDS) (also called Certificates of Analysis (COA)
provided, how the information will be used, and material safety data sheet (MSDS) or See folder “Examples of
consequences of not providing that information. product safety data sheet (PSDS)) is an Certificates of Analysis” for
important component of product examples,
Some companies have developed systems to stewardship and occupational safety https://sites.google.com/site/
help their suppliers provide this information, and health. It is intended to provide oiacmframeworksupplemental
including: workers and emergency personnel docs/
• Written guidance detailing the type of with procedures for handling or
chemical information needed and required working with a substance in a safe Bill of Substances
format of the data. manner, and should include See example of a partial Bill of
• Supplier questionnaires with specific questions information such as physical data Substances built into a Bill of
addressing chemical ingredients, concentrations, (melting point, boiling point, flash Materials in Bill of Substances
toxicity point, etc.), toxicity, health effects, folder
information on chemical ingredients, etc. first aid, reactivity, storage, disposal,
• Web portals for chemical data entry. protective equipment, and spill-‐ Disclosure of chemical content
• Training for suppliers on chemical data handling procedures. SDS formats can information to a third party
reporting requirements. vary from source to source within a under NDA
country depending on national Walmart requires all vendors
For chemical products that you are purchasing requirements. SDSs typically contain a of consumer chemical
from your suppliers, use a Material Safety Data section for product ingredients; products*, over the counter
Sheet (MSDS) or SDS as a starting point however, this information is often products, and batteries to
to get an initial view of chemical ingredient incomplete. disclose all intentionally added
information. If the ingredients listed on the chemicals and
MSDS do not total 100%, ask your supplier to Glossary of terms related to SDSs their percentages for every
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provide complete ingredient information. You product supplied. This
can use one of the templates suggested in this Certificate of Analysis (CoA) is a information is submitted
document. document that a chemical supplier confidentially to a third party
may generate for each run or batch of organization called the Wercs
SDSs are important documents for tracking and a product shipped. A COA provides through an electronic data
communicating information about chemicals business customers with information portal called WERCSmart. The
and products and their potential hazards and related to product quality, purity, and vendor’s Tier 1 and higher
use instructions in a standardized format. conformance to product suppliers are able to upload
However, you should be aware of the requirements. They may contain a list their chemical ingredient
shortcomings of SDSs and common errors. See: and percent composition of active information, if the vendor’s
“2 slides on shortcomings of MSDSs re chemical ingredients, and results of suppliers In turn, do not want
information” (view in PP for animation) in analytical tests that were performed to share their information with
MSDS/SDS folder on the product, such as tests for the vendor.
https://sites.google.com/site/oiacmframeworks contaminants (e.g., lead, cadmium).
upplementaldocs/ The Wercs provides Walmart
with only the information
If you are seeking chemical ingredient needed by Walmart to
information for a chemical mixture or transport and handle these
information on possible contaminants in a single products safely. To protect the
chemical or mixture, ask your chemical supplier vendor’s confidential business
if they have a Certificate of information, formulation
Analysis (CoA). information is never disclosed
to Walmart. Chemical
The importance of good quality data. Suppliers ingredient information must be
and brands providing chemical data to their provided to the Wercs before a
customers need systems to provide consistent, vendor’s product is approved
accurate, complete, detailed, and current data. in Walmart’s supplier portal.
Suppliers with robust data gathering and Walmart put this “hard stop” in
communication systems may be considered place to ensure that regulatory
preferred supply chain partners. Data gathering information needed to handle
should be combined with validation techniques the product is provided before
such as physical testing of materials, it enters the supply chain.
components, or products. Suppliers may want
to develop systems to ensure that data provided * Walmart defines a chemical
are consistently accurate, which may involve the product as a product that
use of an electronic data management system contains a flammable solid,
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with the following elements: powder, gel, paste or liquid
• A central database repository for chemical that is not intended for human
data consumption.
• A system for generating data reports to
customers Office furniture manufactured
• A system for generating data requests to by Herman Miller carries the
suppliers Cradle to Cradle and BIFMA**
• A system for checking the accuracy of data sustainability certifications.
(e.g., totalling of chemical constituents to check These certifications address
for 100% reporting for chemical mixtures, the chemical safety of the
components or products) product. The certifying
• A system for updating data when changes organizations require
occur upstream in the supply chain information on the chemical
Appendix D-‐3 from this GC3 document contains content of the products in
descriptions of software systems for chemical order to determine whether
data management. the products meet criteria for
chemical safety. Some
Quality data may be hard to obtain. Some suppliers to Herman Miller
chemical suppliers do not have the technical disclose the chemical content
expertise to understand or provide the desired information directly to Herman
information. And many times chemical Miller, under an NDA, and
suppliers do not know the source of their Herman Miller shares the
feedstocks, all of the ingredients, and/or the information with the certifying
impurities that might be present. A critical organizations, also under an
aspect of this step is to evaluate chemical NDA. Other suppliers do not
suppliers to ensure they are capable of meeting want to share the information
the data quantity and quality needs. directly with Herman Miller.
These suppliers enter into an
Overcoming obstacles related to a suppliers’ NDA with the certifying
desire to protect intellectual property organizations and provide the
(IP)/trade secret information/confidential information directly to them.
business information (CBI)
Suppliers may not want to share chemical MBDC can and does work with
ingredient information or chemical hazard companies (suppliers and
information out of concern that they may customers), that are not part of
disclose information that could harm their their formal Cradle to Cradle
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competitive advantage. In some cases, brands certification program, to collect
or retailers may drop suppliers that are information from a supplier
unwilling to provide this information, (under an NDA) and assess the
particularly if the brand or retailer needs the information to determine
information to ensure regulatory compliance, whether the material or
to meet the requirements of a product product satisfies the
certification program or of its own public customer’s chemical criteria,
disclosure/transparency program, etc.. without disclosing the chemical
content information to the
Suppliers may be concerned that if they share customer.
chemical ingredient information, a competitor
might obtain the information and copy their
product, or that when their customer learns of
the chemical content, that they will seek out a
cheaper source of the chemical or material and
the supplier will lose orders. Some suppliers
fear that by disclosing chemical hazard or
toxicity information for their product, this
information could allow someone to determine
what the chemical ingredients are or to figure
out how the product was manufactured. The
latter may also be a source of competitive
advantage to the supplier. When a supplier is
supplying something that they have invested a
considerable amount of money and time to
develop, this concern is understandable.

We advise suppliers to take a critical look at
whether chemical data really needs to be kept
confidential. In order to gain new business
and to protect existing business, it is
worthwhile for you to closely examine which
information is critical to maintain as CBI and
which can be safely shared.
There are several approaches that are being
used by suppliers to provide chemical
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information to their customers while protecting
essential trade secret information. They include:
• Disclosure of sensitive chemical data to
customers under a non-‐disclosure agreement
(NDA).
• Disclosure of sensitive chemical data to a
third party under an NDA. The third party
can evaluate the data and provide sanitized
information to the customer to verify that
the chemical or product meets regulatory or
other requirements specified by the
customer. The third party may be an
organization that provides certification under
a green or other product standard or a
company that has a system in place to receive
the data, assess it, and report out essential
information the customer (such as a hazard
assessment or whether the formulation is
compliant with a customer’s RSL) without
disclosing the formulation or other sensitive
information.

See the Examples and Templates column for
examples of such systems.

Chemical suppliers should provide robust sets of Chemical hazard data refers to data Tools for chemical hazard Information Resources
chemical hazard data to their customers to on the human health and assessment include:
enable them to evaluate the safety/hazard of environmental toxicological • The GreenScreen for Safer Chemical Hazard Assessment
chemicals and formulations. characteristics of chemical Chemicals, is a comparative Guidance
CM-‐4.0
ingredients, as well as their physical chemical hazard assessment
Chemical
Brands and Retailers should have and use an in-‐ safety properties such as flammability. method, based on OIA CMWG and the Zero
Hazard
house system for assessing chemicals in their government agency Discharge of
Assessment
products, to understand their potential health Chemical hazard assessment regulatory lists of chemicals Hazardous Chemicals (ZDHC)
and environmental hazards, or engage a third determines whether a chemical is and toxicological/hazard Programme’s Chemical
party to do the same. capable of causing adverse effects to data, developed by Clean Hazard Assessment Guidance
humans and the environment and the Production Action (CPA). It is -‐-‐ Using Chemical Hazard
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circumstances under which these a free, publicly available Assessment
effects may occur. method but does require for Alternative Chemical
technical expertise (i.e., Assessment
toxicology, chemistry) to use and Prioritization
in its full form. Examples of (look for link to the pdf at the
full GreenScreen assessments bottom of webpage)
are available on the CPA
website. Guidance for chemical
• Column Model for Chemical suppliers on categories of
Substitutes Assessment – a data to provide to customers
tool for identification of for chemical assessment and
alternative substances. decisionmaking:
• COSHH Essentials -‐
• Technical Rules for The OECD SIDS data set is a
Hazardous Substances (TRGS) useful guide for
600 chemical/formulation
• Determination and work with suppliers, identifying
code numbered products important hazard data for
(MAL Code) downstream companies. See:
• Pollution Prevention Options Guidance for Completing a
Analysis System (P2OASys) SIDS Dossier
• Priority-‐Setting Guide (PRIO)
• Quick Scan Free, searchable databases
• Stockholm Convention with data on chemical
Alternatives Guidance hazards:

• Stoffenmanager -‐ a tool for
prioritizing worker health PLUM: Public Library of
risks to dangerous Materials – a resource for
substances. chemical and material hazard
information, UC Berkeley
The GreenScreen List
Translator, an abbreviated Pharos – Chemical and
version of the full GreenScreen Material Library, Healthy
method, screens chemicals Building Network (not free
based only on government but quite inexpensive)
agency lists. The names and
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links to these government “red TOXNET, Toxicology Data
lists” can be accessed for free Network, National Library of
on the CPA website. If a Medicine
company wants to check to see
if a chemical in their product or Free, searchable databases
used in their manufacturing of regulated and priority
process appears on one of chemicals
these lists, it is suggested that SUBSPORT -‐ Substitution
they use PLUM or Pharos Support Portal
(described to the right).
Service providers such as
The SUBSPORT -‐ Substitution Sitehawk, the Werks, 3E, and
Support Portal contains some others have pre-‐populated
government lists as well as hazardous assessment data
several corporate restricted for many chemicals included
substances lists. in their product offerings.

Coming soon – Free U.S. EPA
web portal with chemical
hazard and exposure data:
The U.S. EPA plans to develop
a public chemical information
web portal to contain
chemical hazard and
exposure information for
1,000 chemicals. Over time,
EPA says that they will include
more chemicals and more
functionality. To learn more:
http://chemicalwatch.com/13
970/us-‐epa-‐plans-‐public-‐
substance-‐information-‐portal
CM-‐5.0 All manufacturers that purchase and use Occupation health & safety Information Resources
Chemical chemicals in their manufacturing processes and Occupational Health & Safety management systems
Safety & Risk products have an obligation to use and Management Systems (OHSMS) are OHSAS 18001 is the Occupational health & safety
Mgmnt dispose/discharge those chemicals without part of a company’s risk management internationally recognized management systems
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causing harm to workers, the public, consumers strategy and are designed to promote assessment specification for (OHSMS)
and the environment. Ensuring the safe use and a safe and healthy working occupational health and safety
disposal/discharge of chemicals in your factory environment by providing a management systems. OHSAS U.S. Occupational Safety and
requires the adoption of several management framework that identifies and controls 18001 was designed to be Health Administration (OSHA)
systems, including: health and safety risks, including compatible with ISO resources
1. An occupational health & safety management chronic exposures to hazardous 9001 and ISO 14001, to help
system (OHSMS), with documented procedures chemicals, and ensures compliance organizations meet their health U.S. OSHA resources for small
to protect employees; and with legal requirements. and safety obligations businesses
2. An environmental management system efficiently.
(EMS), with documented procedures to protect An Environmental Management Environmental Management
the environment. Systems (EMS) is a set of processes Environmental management Systems (EMS)
and practices that enable an systems
In addition to an OHSMS and EMS, some organization to reduce its The ISO 14000 standard U.S. EPA resources on
manufacturers find it critical to employ a environmental impacts and increase addresses various aspects of Environmental Management
chemical inventory management system its operating efficiency. An EMS is a environmental management. It Systems
(CIMS), which is a centralized system for framework that helps a company provides practical tools for
ordering chemicals, tracking chemical use, achieve its environmental goals companies and organizations Resources for small
managing chemical wastes and chemical through consistent control of its looking to identify businesses:
regulatory requirements, as well as other operations. The EMS itself does not environmental impacts and U.S. EPA’s Small Business
chemical related business functions. These dictate a level of environmental develop programs for Division:
systems can significantly improve visibility, performance that must be achieved; continuous improvement of Practical Guide to
control and compliance with good chemical each company's EMS is tailored to the environmental performance. Environmental Management
management practices and regulatory company's own business and goals. ISO 14001:2004 and ISO for Small Businesses
requirements. 14004:2004 focus on and
A Chemical Inventory Management environmental management Documenting Your
Brands and retailers that are not directly System (CIMS) is a centralized system systems. The other standards Environmental Management
manufacturing materials, parts or products, or for ordering chemicals, tracking in the family focus on specific Plan: A workbook for small
are strictly assembling components made by chemical use, managing chemical environmental aspects such as businesses
others, have an obligation to ensure that the wastes and chemical regulatory life cycle analysis,
chemicals being used in their suppliers’ factories requirements, as well as other communication and auditing. Auditing your suppliers
are not harming workers, the public or the chemical related business functions. OHSMS & EMS
environment. You are obligated to determine These systems can significantly Chemical Inventory
that occupational safety & health and improve visibility, control and Management System (CIMS) Firms such as Intertek, SGS,
environmental management systems are in compliance with good chemical Bureau Veritas, and WRAP
place and are being followed. You can work to management practices and regulatory For chemical have developed supplier
ensure that good workplace and environmental requirements. manufacturers/suppliers -‐ auditing services in the area
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protection practices are being used by your The Synthetic Organic Chemical of occupational safety,
suppliers by A Point of Contact (POC) is a person Manufacturer Association's environmental management,
• Determining that suppliers have an active or a department serving as the (SOCMA) ChemStewards® and other related areas.
OHSMS and EMS in place coordinator or focal point of management system is a step-‐
• Auditing suppliers to determine whether they information concerning chemical wise system approach to Chemical Inventory
are following their established OHSMS and information and management systems managing environmental, Management System (CIMS)
EMS systems. Companies can directly audit for the company. Assigning a point of health, safety and security
their suppliers to ensure that these systems are contact is critical where getting (EHS&S) activities, designed Several software firms offer
robust or use a third party auditor. information is time-‐sensitive, accuracy specifically for batch, custom CIM systems. See for
• Requiring that suppliers conform to a standard is important, and when good and specialty chemical example IHS’ Chemical
or certification system (such as a corporate customer relations need to be manufacturing facilities. It Inventory System
social responsibility (CSR) standard) that maintained. defines core principles and
contains requirements for good workplace and provides guidance that helps
environmental practices. ensure compliance with legal
and regulatory
Brands and retailers can reward suppliers that requirements. ChemStewards®
employ good workplace and environmental can also help improve
management systems by giving them preferred-‐ performance by identifying
supplier status. inefficiencies and improving
process
Manufacturers/suppliers of chemicals and controls. http://www.socma.co
chemical formulations need to have OSHMS and m/chemstewards/
EMS systems as well, but also have an obligation
to ensure that their chemicals are being used
safely by their customers. This can be achieved
by providing guidance and training to customers
on the risks posed by these
chemicals/formulations as well as safe handling,
use (including process controls), and disposal of
chemicals/formulations supplied. If a supplier is
aware of a technically feasible, safer chemical
alternative to the one being supplied, the
supplier should inform their customer about
that alternative and provide supporting data.

A common complaint heard is that individuals
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trying to get chemical information from a
supplier are frustrated in their efforts to find the
right person that has or can get the information
that they need. This is often a result of the lack
of a single point of contact or lack of awareness
within the company being contacted about who
their internal point of contact is for these types
of inquiries. Every company in a value chain
should have an individual or team assigned as a
point of contact (POC) to receive inquiries from
their customers regarding chemical
management and health and safety issues.
Suppliers should make their employees aware of
who the point of contact is in order to direct
suppliers and/or customers to the right people.

And remember, especially with formulators,
they truly may not know the information
requested.
Once a company knows some or all of the Alternatives Assessment is a term Alternatives Assessment. Alternatives Assessment
chemicals that are being used in the products it used to describe a process for There are two essential Chemical Alternatives
supplies, buys, makes, or sells to consumers, and identifying alternatives (chemical or elements to AA: (1) the Assessment: Enabling
has information on the relative hazard/safety of non-‐chemical) to a chemical of general framework or process Substitution to Safer
these chemicals, the company can proactively concern, screening out equally or flow; and (2) tools for Chemicals, an article in the
improve its product safety and minimize the more hazardous screening alternatives. Journal Environmental
CM-‐6.0
environmental impacts of the supply chain alternatives, and selecting an Science & Technology about
Safer
through alternative that is technically and A number of frameworks have AA
Alternatives
• Establishing a SoCL economically viable and does not have been developed and are in use
Assessment
• Targeting the prioritized chemicals on the the potential for causing significant today. BizNGO’s Chemical How to substitute high
& Preferred
SoCL for substitution environmental or human health Alternatives Assessment hazard chemicals with safer
Substances
• Conducting Alternatives Assessments (AAs) to impacts. Protocol recommends a alternatives
identify and drive substitution of high hazard hazard-‐first approach in SUBSPORT -‐ Substitution
chemicals with suitable, safer alternatives The Interstate Chemicals evaluating alternatives, i.e., Support Portal provides step-‐
• Developing preferred substances list and Clearinghouse (IC2) AA guidance first screen out hazards of by-‐step guidance on chemical
driving adoption of these preferred chemicals document includes seven assessment equivalent or greater concern substitution; a keyword
within their value chain. modules in its description of AA: then proceed to life cycle searchable case study
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1. Performance of alternatives thinking and exposure database of actual chemical
A main driver for doing AAs is that companies do 2. Chemical hazard assessment assessments if appropriate. substitutions; a keyword-‐
not want to eliminate the use of a high hazard 3. Cost and availability of alternatives Other frameworks for AA are searchable database of
chemical and replace it with an alternative that 4. Exposure assessment available or under restricted and priority
turns out to be hazardous as well. This scenario 5. Materials management development including: substances, and other
is often called a “regrettable substitution.” 6. Social impact assessment • Washington State resources.
7. Life cycle considerations Department of Ecology
(more detail is provided below) Alternatives Assessment P2Rx Topic Hubs provide
Guidance Document information on alternative
Chemical Substitution is a process • U.S. Environmental chemicals and processes in a
that typically includes the following Protection Agency Design for range of technology sectors
steps: Environment (U.S. EPA DfE) that could be of interest to
• Define the problem Program (chemical hazard OIA companies, either for
• Set substitution criteria only) their own operations or to
• Search for alternatives • Toxics Use Reduction provide guidance to suppliers.
• Assess and compare alternatives Institute Five Chemicals See for example:
(AA) Alternatives Assessment Study Textiles
• Experiment through a pilot project • Alternatives Assessment Fiberglass Fabrication
• Implement and improve Framework of the Lowell
Center for Sustainable Preferred substances list
Chemical substitution may be a fast Production A few companies are
and easy process or highly complex, • German Federal beginning to develop
depending on the chemical and Environmental Agency Guide preferred substances list. See
product or process where the on Sustainable Chemicals for example Nike’s Positive
chemical is being used and the • California Proposed Safer List of Chemistries, on page
availability of alternatives. Be careful Consumer Product Regulations 48 of their Nike Restricted
to not adversely compromise product Substances List (RSL) and
quality with a substitute. Most of these documents are Sustainable Chemistry
detailed and complex. Guidance (SCG) document.
And also realize that improvements Streamlined guidance for
can also be made by process businesses, particularly small The U.S. EPA Design for
modifications. With this approach it businesses, is needed. Environment Program,
may be possible to minimize or even Washington State is planning companies making cleaning
eliminate detectable concentrations to develop guidance for products and ingredients for
of chemicals of concern if a suitable businesses. these products, and the non-‐
substitute cannot be identified. profit GreenBlue®
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Tools for the chemical hazard collaborated to create
Driving adoption of preferred assessment component of the CleanGredients®, an online
substances in your value chain AA include tools described in database of safer cleaning
Start with your own operations. Section 4.0. product ingredients that have
Determine where you are using been thoroughly assessed for
restricted substances or prioritized There is some guidance on the their potential environmental
chemicals of concern -‐-‐ either as other dimensions of the AA, and human health and safety
ingredients in products or in e.g., cost and availability of benefits. This database
manufacturing processes such as alternatives, social impact provides an opportunity for
equipment cleaning operations, assessment, in the The ingredient producers to
painting, plating, dyeing and finishing. Interstate Chemicals showcase their ingredients
Look for alternatives using the Clearinghouse (IC2) AA and a formulary for
resources described in the resources guidance document. formulators to select safer
column. Assess whether the Additional, more streamlined ingredients. At present,
alternatives are safer using an AA guidance on these dimensions CleanGredients includes
method described in this guidance (or is needed. listings for surfactants,
engage a consultant to help); solvents, fragrances, and
test/pilot the alternative and Generally, companies are chelating agents. Modules for
implement it. expected to conduct additional ingredient classes
performance and cost are in development.
If there are no suitable alternatives evaluations of alternatives
today, come up with a strategy that using the methods that they
will allow you to learn about new typically use in-‐house to
alternatives as they are developed. evaluate chemicals and
This may include participating in a materials for their products.
community of practice, as described
below. There have been a number of
successful efforts, within
If your company is not directly product supply chains, to
engaged in manufacturing, you will collaboratively evaluate the
need to develop a strategy for how to performance of alternative
engage your suppliers in this effort. chemicals and materials.
Engagement can involve adding an RSL
and/or SoCL to your supplier contract, For example, an apparel
if you do not already have one; having company partnered with
a conversation with your supplier chemical suppliers to develop a
FINAL FOR PILOT
April 22, 2013

about why they are using particular suitable chromium free dye
chemicals that you would like to that was not previously
eliminate and whether they have available.
explored alternatives,
And apparel companies have
partnered with chemical
companies in efforts to replace
nonylphenols, nonylphenol
ethoxylates, long-‐chain
perfluorinated water
repellents, etc.

Another such effort evaluated
alternatives to lead-‐containing
solder for printed wiring
boards in electronic products
and involved an academic
research group that did some
of the performance testing. In
these collaborations, funding
and expertise can be pooled,
making the performance and
cost assessment results more
robust and cheaper on a per
company basis. This model
could be used to assess
alternatives for broadly-‐ used
chemicals/materials within the
outdoor industry, where
individual companies have
been challenged to find safer
substitutes with required
performance characteristics.
CM-‐7.0 Transparency/public disclosure of chemicals. A Community of Practice (CoP) is a Scoring sustainable chemistry Transparency/public
Sustainable Over the past few years, many consumers, group of professionals, with a disclosure of chemicals
Chemistry governments and advocacy groups have become common interest in a particular field, Nike’s Material Sustainability
FINAL FOR PILOT
April 22, 2013

Innovation & increasingly concerned about the health and that come together with the goal of Index (MSI) is a scoring system Examples of companies that
Continuous environmental risks posed by certain chemicals furthering their work and the work of for materials selection, which are publicly disclosing of
Improvement in consumer products. Concerns around others in the group through sharing of includes a chemistry score that chemical/material content of
bisphenol A (BPA) in baby and sports bottles, knowledge, expertise, best practices is calculated using an algorithm products
brominated flame retardants in mattress and and mutual support. A CoP can exist and data addressing Interface, a manufacturer of
furniture foam, lead on toys and in other in person or on-‐line. “significant chemical carpet tiles, publishes the
children’s products are just a few examples that substances” across the cradle-‐ material content in its
have alarmed consumers and other Final product refers to the product to-‐gate life cycle of a material. environmental product
organizations and have lead them to seek out that is used by the consumer (e.g., a The chemistry score combines declarations (EPDs), including
information on the chemical content of set of skis that are purchased and human health hazard information on general
products. used by a customer). evaluations for carcinogenicity, material types in the product
acute toxicity, chronic toxicity, (see example).
A number of brands have responded by making Intermediate product refers to a and combined reproductive
their product ingredients public. Most of these product made by a supplier and sold toxicity and endocrine Construction Specialties
companies are formulators, making cleaning and to a business customer, for use in a disruption with assumptions publishes its Cradle to Cradle
other household products, rather than articles final product. An intermediate about potential exposures Certified reports, which list
(e.g., clothing, bicycles, electronic equipment). product is not used by a consumer. during the life cycle. Eco-‐ generic names for the
Examples of public chemical disclosure are given An example of an intermediate toxicity is not considered. chemicals and materials in its
in the Examples and Templates section to the product is dyed fabric made by a dye products and the chemical
right. house and sold to a cut and sew SC Johnson’s Greenlist™ and material risk score that
factory to be made into a garment for Scoring System S.C. Johnson’s MBDC assigns to that
Scoring sustainable chemistry a consumer. chemical classification process substance (see example)
Many have heard the adage, “what gets called Greenlist™ rates raw
measured gets managed.” This applies to materials based on their Method discloses all the
Product chemistry refers to the
chemicals management as well. Companies that impact on the environment chemical ingredients in its
chemicals in a final product, their
have goals to move toward safer chemistry and and human health. Greenlist™ products with the exception
hazard characteristics, the potential
metrics for measuring their progress are more scores are reported alongside of fragrances, for which it
for exposure to these chemicals and
likely to make meaningful strides in this area. performance and cost provides a generic
possible harm.
information in the company’s description—fragrances are
Measuring progress toward safer chemistry chemical “free of
Process chemistry refers to the
adoption within your value chain can be done in formulary so chemists can phthalates and other dirty
chemicals used in a manufacturing
a number of ways, including: choose materials in ingredients, not irritating to
process, their hazard characteristics,
• Instituting robust programs that track supplier consideration of their skin or toxic in use; partial
the potential for exposure to these
compliance with RSLs environmental and health natural essential oil content,
chemicals and possible harm.
• Instituting systems that assess and score properties. Using the scores, partially synthetic
chemicals and products materials can be easily ingredients” (see the “what’s
FINAL FOR PILOT
April 22, 2013

compared. S.C. Johnson in it” tab in this example).
Several scoring systems are described in the chemists around the globe
examples and templates section. have instant access to data on
the score of ingredients for
product formulation and
reformulation. Greenlist™ also
provides metrics for tracking
S.C. Johnson’s corporate-‐wide
progress toward greening its
portfolio of products. Each
year, the company calculates a
weighted average Greenlist™
score for all raw materials
used. The overall score is
calculated by multiplying the
weight of each chemical
purchased by its Greenlist™
score, summing these numbers
and then dividing by the sum of
all raw materials used by
weight. A rising score indicates
increasing use of
environmentally preferable
materials. This metric is
tracked yearly and yearly goals
are set to reach a five year
goal. The company also tracks
the year-‐on-‐year percentage
change in the use of materials
in each group. S.C. Johnson’s
goal is to increase the
percentage of raw materials
that are rated “Better” or
“Best.” See the GC3 case study
on Greenlist™ for more
information.
FINAL FOR PILOT
April 22, 2013



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