With a continued push to find replacements for a host of hazardous substances, Dave Howell reports on the current state of the substitution market.
The chemicals industry continues to expand. By 2010 global chemicals output stood at $4.12 trillion (£2.6 trillion). China saw the largest growth of a single country with the Organisation for Economic Co-operation and Development (OECD) region accounting for the bulk of the growth seen, with the latest forecasts predicting a 3% per year expansion of the market to 2050.
Hazardous substances have been a focus for regulators for decades. REACH and COSHH offer a framework for the management of hazardous substances. Over recent years with a developing focus on human health and improving environmental protection, the substitution of hazardous substances by less harmful substances or inert compounds has been gaining pace.
In 2001 the EU issued a “Strategy for a future Chemicals Policy” White Paper, which stated: “Another important objective is to encourage the substitution of dangerous by less dangerous substances where suitable alternatives are available. The increased accountability of downstream users and better public information will create a strong demand for substitute chemicals that have been sufficiently tested and that are safe for the envisaged use.”
One of the key issues has been to define what substitution means. In a report compiled for the Directorate General Environment, Nuclear Safety and Civil Protection of the Commission of the European Communities, this issue was raised with the report concluding:
“Substitution of hazardous substances by less hazardous alternatives appears to be a straightforward approach when enterprises consider management and reduction of chemical-related risks. Substitution is also debated in the context of the future chemicals policy in the EU. At the same time, various stakeholders' perceptions differ widely about the definition of substitution and concerning the question whether substitution should be a ‘fundamental principle’, a ‘duty to both producers and users of chemicals’, a ‘preferred risk reduction strategy’ or whether it is ‘just another tool for managing risk’.”
Can one risk be deemed better than another? When a substance is to be substituted, a myriad of concerns emerge. There is, though, a clear drive to move to what are at least perceived as safer substances.
In Greenpeace’s report “Hidden Consequences”, it concluded: “Preventing pollution and substituting hazardous chemicals with safer alternatives can bring multiple benefits. For instance, it reduces waste — especially hazardous waste — and the cost of its disposal; it makes the workplace safer; and it delivers substantial economic benefits with regard to manufacturing costs. These financial benefits are the result of an increased understanding of inefficiencies, and a focus on innovation in products and the production process.”
Finding an equivalent can be a time-consuming and costly process. Regulation may be pushing users of hazardous substances to find less harmful alternatives, but there is no clear roadmap that is independent or funded.
Kevin Stairs, the Greenpeace EU Unit Chemicals Policy Director commented: “The timetables need to be realistic. They cannot be 1–2 years in most cases, but commensurate with the task. Likewise they cannot be longer than 10 years for any given substance. Inside confiding chemical industry experts have revealed that 10 years is sufficient for the vast majority of hazardous substances. In addition, a self-financing mechanism can be adopted to drive substitution. The hazardous substances identified would be subjected to a fee (low at first) increasing over time to ensure the affected industries invest the R&D&I (investment) to succeed. The revenue would be directed directly back into the R&D&I of the substitutes.”
Chemical awareness is important in many industries, but perhaps none more so than in the food packaging sector. The recent debacle surrounding the use of Bisphenol A (BPA) in packaging illustrates where a lack of clarity and understanding — mostly because of poor testing and analysis of a compound’s potential affects — adds weight to the debate regarding the substitution of substances across a range of industry sectors.
In addition, the reaction to the study “Case report: High Prenatal Bisphenol A Exposure and Infant Neonatal Neurobehavior” has been strong, with many in the scientific community condemning its findings as inaccurate and suggesting that that the report ‘fans the flames’ of media speculation regarding the perceived health risks of BPA.
The BPA debate is symptomatic of the chemicals industry that has to balance its efficient processes with the desire to enhance environmental and human health protection. Says Alex Hills, a consultant with integrated health, safety and risk management specialists Santia: “As an example many would say that Atrazine-based weed-killers have greater longer-term effectiveness than Glyphosate ones; however Atrazine is restricted due to its environmental effects.
“The substitution for alternatives may introduce other health, safety and environmental concerns so an often difficult 'balance of risks' needs to be determined, eg relative risks of substances which have different levels of toxicity, flammability or environmental damage potential. There may also be undesirable side-effects such as a degreaser may leave an oily residue and last, but by no means not least the safer alternative may be more expensive and this could pose financial problems for companies.”
“The substitution for alternatives may introduce other health, safety and environmental concerns so an often difficult 'balance of risks' needs to be determined eg relative risks of substances which have different levels of toxicity, flammability or environmental damage potential. There may also be undesirable side-effects such as a degreaser may leave an oily residue, and last but by no means not least, the safer alternative may be more expensive and this could pose financial problems for companies.”
Dr Mel Cooke at Alchemy Compliance also said: “It is getting the data on which to base substitution decisions. Also, sometimes it is difficult to compare one substance with another. If you have a substance that is a respiratory sensitiser (asthmatogen), is this more serious than a substance that causes damage to the eyes? With all regulatory decision-making, there is a pay-off between having simple criteria (eg CMRs should be substituted) versus the time, expertise, and complexity in more informed decision-making (eg CMRs whose uses may lead to adverse effects in humans or wildlife because of they persist in the environment and whose release cannot be adequately controlled should be substituted). NGOs tend to go with the former; industry tend to push for the latter.”
The future then looks to include much more testing, but who picks up the bill is less clear, especially in developing countries, as the Greenpeace “Hidden Consequences” report states:
“In East Asia, Southeast Asia and other parts of the world where industrialisation is booming, there is a danger that expenditure on even basic environmental measures — let alone the avoidance of hazardous substances through substitution — could be seen as an unnecessary impediment to economic growth. The case studies from the Global North show that attempts to ‘save money’ by opting for the cheapest ways to use and dispose of hazardous chemicals in the short term can ultimately translate into extremely high costs and losses in the future. These costs then have to be borne by someone, and this is either the companies concerned or the taxpayer — often both.”
The Directorate General Environment, Nuclear Safety and Civil Protection of the Commission of the European Communities concluded:
“Substitution should be based on comparative assessment of alternatives which requires reliable information on the hazard of substitutes and the associated risk of using them instead of the conventional substance. The current situation is often described as unsatisfactory in this respect. If in the future public policy will ensure that, as a pre-requisite for informed choices, comparable risk-related information on conventional substances and their substitutes is available, this will bear significant potential to accelerate substitution of hazardous substances in products and processes. Industry-specific innovation networks can contribute substantially to these informed choices.”
Will substitution become the norm? Regulation is certainly compelling chemical users to look at their processes in more detail. But as Santia’s Alex Hills concludes, the cost to effectiveness considerations will at the moment at least favour the cost side of the equation: “If people don’t think it is effective or it costs too much they won't buy it. For a user of a product, the most important consideration is generally 'does it do what it says on the tin?' They are unlikely to be convinced by a safer but less effective alternative. Suppliers of chemicals will be aware of the need to be competitive and it is doubtful that their customers will pay much of a premium for a 'safer' product.”
What is clear is that the replacement of a hazardous substances is not a straightforward exercise when the functionality and potential health and environment hazard of the proposed alternative is concerned. A more complex and in-depth understanding of how an alternative substance may perform in any given scenario is not known for an array of substances. And without it, universal testing is likely to continue to be a major issue for any process.
Last reviewed 17 September 2012