Lead sponsors:
Th. Jakl, B. Perthen-Palmisano, M. Wittmann
Chemical Policy Directorate, Ministry for the Environment, Austria
IFCS/FSC/07.12
„Substitution and Alternatives”
Prepared by IFCS Forum VI drafting group
Proposal (25 May 2007 )
I.
Background
Substitution has been one of the tools for the protection of the environment virtually since the
beginning of environmental policy. To replace harmful substances and processes with less harmful
ones or with non-chemical alternatives, can be an effective strategy to reduce risks to human health
and the environment. Substitution is thus a strategy of risk reduction through implementing solutions
to prevent human and environmental exposure to certain chemical hazards while still achieving the
intended goal. In other words: substitution is not a goal on its own - however better solutions are
natural enemies of the good ones also with regard to human health and the environment. Moreover in
most cases of chemicals management there are several paths for achieving a specific goal or service1
offering the possibility to choose among various alternatives according to specific criteria.
On the one hand substitution has been called one of the principles of environmentalism. However,
there is no explicit mention of a “Substitution Principle” on the level of international environmental
instruments or declarations, as opposed to the many principles of environmentalism one can find
enshrined in the Rio Declaration and elsewhere. Substitution is, however, one of the strategies
implemented by the Stockholm Convention or the OSPAR agreement, as the process mechanism of
these instruments.
What comes closest to a wording of a Substitution Principle for chemicals on a general level is in Art.
14 of the Overarching Policy Strategy (OPS) of the SAICM:
The objectives of the Strategic Approach with regard to risk reduction are:
(j) To promote and support the development and implementation of, and further
innovation in, environmentally sound and safer alternatives, including cleaner production,
informed substitution of chemicals of particular concern and non-chemical alternatives.
Substitution should also be understood in the context of Art. 14(d) of the OPS:
To ensure, by 2020:
(i) That chemicals or chemical uses that pose an unreasonable and otherwise unmanageable
risk to human health and the environment based on a science-based risk assessment and taking
into account the costs and benefits as well as the availability of safer substitutes and their
efficacy, are no longer produced or used for such uses;
(ii) That risks from unintended releases of chemicals that pose an unreasonable and otherwise
unmanageable risk to human health and the environment based on a science-based risk
assessment and taking into account the costs and benefits, are minimized;
Substitution is a common and inherent process of technological development, industrial business and
innovation. The ability to substitute one chemical product should be approached on a life-cycle basis
with a consideration of the risks, costs and benefits of substitution. It is important to assure that
recommendations on substitution include a focus on performance of alternatives, and possible use of
incentives as options to encourage a transition, particularly to encourage an understanding of what
societal tradeoffs are to be expected. Beside the economic drivers, such as increase in resourceFor example “clean surfaces” can not only be achieved via a cleaning process but also by avoiding surface
contamination
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Lead sponsors:
Th. Jakl, B. Perthen-Palmisano, M. Wittmann
Chemical Policy Directorate, Ministry for the Environment, Austria
IFCS/FSC/07.12
efficiency, improvement of the environmental and toxicological profile of industrial activities should
be a reason to substitute a chemical substance or its application with more favorable
substances/technologies. These alternative solutions shall not be seen as being restricted to chemicalbased options.
Thus substitution shows a twofold nature being an instrument of environmental and health policy on
the one side and an inherent component of business management on the other. Both approaches are
based on analyses facilitating prioritization and subsequent decision making.
Therefore, it is important that one topic for discussion at IFCS Forum VI be on substitution and
alternatives. To engage in effective discussion, the following is proposed:
II.
Goals/objectives of a plenary session on the topic
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III.
To raise awareness and discuss substitution (both chemical and non-chemical alternatives2) as
a proven and effective instrument to lower risks, in a multi-perspective, multi-stakeholder
way.
To identify and analyse potential triggers and drivers of substitution processes including
analytical tools supporting prioritization and subsequent decision making.
To establish consensus on definitions of substitution and alternatives
To determine ways and approaches to implement substitution and consider presenting these in
the form of recommendations in what might be called the Dakar Recommendations on
Substitution.
To discuss process mechanisms for substitution, particularly for resource poor countries
Issues that would be considered by the Forum
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Terminology
Experiences and best practices regarding substitution as political instrument within national,
regional and international frameworks
Experiences and best practices regarding substitution processes within industrial applications
of chemical substances
Specific cases where substitution was not effective in achieving its overall aim of lowering
risk or resulted in detrimental product/process performance from a multi-stakeholder
perspective.3
Ways and approaches to implement substitution, i.e. replacing harmful substances by less
harmful ones or by non chemical alternatives and risky applications and processes by less
risky ones. 4
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Political background: These may also lead to low tech solutions easily handled by their potential
beneficiaries, with low impacts, if none, on the health and the environment. IFCS should actively tackle the
issue of non-chemical alternatives with a view to sending a signal in order to open SAICM to this very
valuable opportunity.
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We can also learn from the experiences of when an effort to substitute was not effective from an overall
risk perspective. Together, the “best” cases from above and “worst” cases would help to demonstrate which
tools best promote and support further innovation in and implementation of substitution in industrial
processes and products.
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These first topics should also highlight important drivers for substitution; types of substitution functional, chemical, etc., challenges of substitution (technical – performance, cost - R&D of alternatives
and implementation), lifecycle issues;
2
Lead sponsors:
Th. Jakl, B. Perthen-Palmisano, M. Wittmann
Chemical Policy Directorate, Ministry for the Environment, Austria
IFCS/FSC/07.12
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IV.
Approaches to substituting absolutely, as soon as possible, substances that in the long run do
irreversible harm to human health or the environment, such as CMR substances, persistent and
bioaccumulative substances or known endocrine disrupters
Mechanisms existing or needed for informing importing countries (other countries in general?)
of substitutes available for chemicals being exported and/or currently used in other countries,
e.g. alternatives data base readily accessible for all countries.
Guidance on assessing chemical risks and potential harm based not merely on hazard data, but
also on the use context.5
Process/mechanism for ensuring the substitution/alternative identified is truly less harmful in
the short and long term.
Possible Forum actions
The Forum might recommend
 proven and effective ways and approaches to implement substitution within chemical strategies
on the international, national and company level.
 potential process mechanisms for substitution and the use of alternatives in differing country
contexts (i.e. developed, developing or economy in transition).
V. Plenary session structure (format, presentation(s), time (e.g. 90, 180 mins)
180 minutes
Eight presentations of 15 minutes each, with 60 minutes for plenary discussion
Possible presentation topics include:
 Setting the stage – substitution/alternatives: terminology, what this means in practice; scope
(industrial chemicals, product development, agriculture),
 Non-chemical alternatives (processes, technologies, business models, case examples and
preconditions for success )
 Life Cycle Analysis as a means to identify possible substitution opportunities, including a
discussion of data needs as well as for prioritisation and subsequent decision making,
including qualitative and quantitative guidance on risk issues and its role in promoting safety
 Substitution as a strategy of product development (from stakeholder point of view)
 Substitution issues and foreseeable implementation problems/challenges particularly for
developing countries and economies in transition
 Substitution as a driver for innovation
 Case studies on substitution, both successes and challenges (e.g. brominated flame retardants,
dry cleaning of textiles, asbestos, CFCs, hexavalent chromium-containing conversion
coatings, leaded solders, pesticides etc.; including case studies from developing countries &/or
economies in transition)
 Legal background – international overview of examples of the use of substitution approaches
in existing legislation
 Proposal for possible action to be taken by the Forum
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Explanation: Some chemicals may not be “risky” when used in a controlled environment with all the
required protective mechanisms which are not always available in developing country use contexts. Thus
alternatives/substitution may be necessary for a chemical used in one country, but may not necessarily be
the case for another.
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Lead sponsors:
Th. Jakl, B. Perthen-Palmisano, M. Wittmann
Chemical Policy Directorate, Ministry for the Environment, Austria
IFCS/FSC/07.12
VI.
Process for preparing – how the plenary session documents (decision, information and/or
thought starter) will be prepared.
The session including meeting documents will be prepared by a multistakeholder working group
chaired by the lead sponsor.
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