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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 .
Key factors for substitution decisions in complex products and production processes
„Substitution and Alternatives Assessment Methodologies Workshop”
Univ. of Massachusetts Lowell
December 2-4, 2004
Lothar Lißner & Dr. Joachim Lohse
Report 1: Substitution of Hazardous Chemicals in Products and ProcessesReport compiled for the EU-Commission, DG Environment Hamburg, March 2003 by: Ökopol and Kooperationsstelle Hamburg
Focus on:Compilation of policies, legislation and public activities in the EU and the EU-Member States Case studies for certain chemicals in products and processes
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”
Substitution is a key concept in the EU Strategy for a Future Chemicals Policy (COM88)
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
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.
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...
Substitution Type 1:
Replace hazardous by a less hazardous substance while maintaining technology / product functionality
Substitution Type 2:Use 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
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
“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 functionalityvia technological or organisational measures”.
Substitution from chemical façade cleaning to the use of mechanical cleaning with water (high pressure cold and hot)
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).
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).
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.
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.