Intergovernmental Forum on Chemical Safety
Global Partnerships for Chemical Safety
Contributing to the 2020 Goal
02.TS
Agenda item 7
IFCS/FORUM-VI/02.TS
Original: English
26 February 2008
FORUM VI
SIXTH SESSION
OF THE
INTERGOVERNMENTAL FORUM ON CHEMICAL SAFETY
Dakar, Senegal
15 – 19 September 2008
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THOUGHT STARTER
Substitution and alternatives
Prepared by: FSC Working Group, lead sponsor Austria
Secretariat: c/o World Health Organization, 20 Avenue Appia, CH-1211 Geneva 27, Switzerland
Tel: +41 (22) 791 3873/3650; Fax: +41 (22) 791 4875; Email: ifcs@who.int; Website: www.ifcs.ch
Intergovernmental Forum on Chemical Safety
Sixth Session – Forum VI
15 – 19 September 2008
1.
IFCS/Forum-VI/02.TS
26 February 2008
Background
1. Substitution of dangerous chemicals has been one of the major tools for the protection of
the environment and human health. Substitution is a preferred risk reduction strategy since the
beginning of environmental policy, of public health strategies and of workers’ protection
legislation. It is also the preferred mean to avoid risks posed by chemical agents to the health
and safety of workers.1 To replace harmful substances and processes with less harmful ones or
with non-chemical alternatives, can be a very effective strategy of risk reduction. Additionally,
substitution of dangerous with less dangerous chemicals is seen as an ideal way to overcome
the unavoidable deficits of control and regulation.
2. As a strategy of risk reduction substitution means implementing solutions that prevent
human and environmental exposure to certain chemical hazards while still achieving the
intended technical purpose.
3. In other words: substitution is not a goal on its own - but the search for better solutions
aims not only at optimizing product- and cost efficiency but also at minimizing risks for
human health and the environment. Moreover in most cases of chemicals management there
are several paths for achieving a specific goal offering the possibility to choose among
various alternatives according to specific criteria. In a nutshell, substitution is the proverbial
“better being the enemy of the good” – Voltaire’s "Le mieux est l'ennemi du bien" – applied
to chemicals management.
4. The context in which Forum VI will be tackling substitution thus is a broad one involving
comparisons and judgments at the level of single substances, industrial processes and
technologies but also at the level of business models, which could be either product- or
service-oriented. Non-chemical alternatives do not necessarily involve all these comparisons
and judgments at the different levels, as they are often not industrial. Therefore, their
development, implementation and use can in many cases be simplified, rapid and cheap.
1a)
Substitution in the context of international environmental affairs2
5. 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. Chapter 19 of Agenda 21 recommends strengthening
research on safe and safer alternatives to toxic chemicals and reducing risk by using other
chemicals and nonchemical technologies. The Montreal Ozone Protocol requires Parties to
“co-operate . . . in promoting . . . research, development and exchange of information
on . . .possible alternatives to controlled substances, to products containing such substances,
and to products manufactured with them.” The Montreal Protocol, Stockholm Convention,
and Rotterdam Convention on Prior Informed Consent all take special note of the importance
of informing, increasing awareness, and educating the public about alternative substances and
technologies. In the elaboration phase of the Montreal Protocol the notion of “alternative
1
Article 6. Council Directive 98/24/EC on the protection of the health and safety of workers from the
risks related to chemical agents at work.
2
International Agreements concerning substitution and use of alternatives http://www.who.int/ifcs/documents/forums/forum6/meet_docs/en/index.html
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Intergovernmental Forum on Chemical Safety
Sixth Session – Forum VI
15 – 19 September 2008
IFCS/Forum-VI/02.TS
26 February 2008
substances and technologies” was generally used in the discussions and in the minutes and
was generally well understood.
6. What comes closest to a description of substitution on a general level is in Art. 14 of the
Overarching Policy Strategy (OPS) of the Strategic Approach to International Chemicals
Management (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.
7. 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;
1b)
Substitution in business strategy and policy strategy
8. 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.
9. The character of the substitution process depends on the type of problem and the degree of
knowledge already available.
Efforts depend on the type
of the substitution problem
1. Open innovative and
demanding technological questions
Regulatory Option
Intended result
R&D
Support, incentives, research
2. Adaptation of existing
technologies necessary
DEVELOPMENT
Mixtures of incentives and
command-and-control
INFORMATION AND
OBLIGATION
Substitution has to be applied
– exceptions only for certain
applications
Development of a new
preparation or of a
completely redesigned
process
Adaptation of processes
Medium-Term
implementation
Introduction of an already
practically tested solution
3. Implementation of
already widely spread
reference processes
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Intergovernmental Forum on Chemical Safety
Sixth Session – Forum VI
15 – 19 September 2008
IFCS/Forum-VI/02.TS
26 February 2008
10. 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. These judgments should also take such aspects into consideration that might vary
from region to region, be it for climatic, economic, cultural or other reasons. Therefore,
substitution is also a social process, which involves different actors and stakeholders
(enterprises, different departments in enterprises, workers, business customers, private
consumers, science, politics, authorities, environmental and consumer NGOs, financers,
public and trade media, etc.)
11. Beside the economic drivers, such as increase in resource-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 or
processes, as these alternative solutions shall not be seen as being restricted to chemical-based
options.
12. 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.
13. There is a regulatory option for each type of substitution problem. It is obvious that
proper legislation can be an important driver for substitution. However, legislation is not the
only essential element for substitution strategies, as many success stories in substitution were
brought about by non-governmental stakeholders alone and were made feasible by voluntary
activities and high motivation of the stakeholders. Therefore, the plenary session on
substitution and alternatives at IFCS Forum VI will not mainly focus on legal aspects but
highlight more factors of the whole set of relevant influence factors of substitution.
1c)
Working definition of substitution
14. To avoid time-consuming discussions on definitions and terminology, a working
understanding of the term “substitution” for the purpose of this session is established in this
paper (adopted from a European study on 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.” 3
More elaborated definition:
15. “Substitution” means:
a) replacing a specific chemical by an alternative chemical substance to do the same task,
and/or
b) replacing the technology, using a chemical, by a different technology using other
means to do the same task.
3
Lohse J., Lissner L. et al (2003): Substitution of hazardous chemicals in products and
processes, Revision 1,
http://ec.europa.eu/environment/chemicals/pdf/substitution_chemicals.pdf
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Intergovernmental Forum on Chemical Safety
Sixth Session – Forum VI
15 – 19 September 2008
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26 February 2008
16. “Alternative” means:
a) alternative substance, doing the same task as the original chemical, and/or
b) alternative technology, rendering the same service to the end user as the technology,
using the original chemical.
17. Types of substitution:
a) full replacement of the chemical,
b) partial replacement of the chemical, depending on the reasons of substitution,
c) replacement by one single alternative, or
d) replacement by a variety of alternatives, according to the services, the original
chemical substance is fulfilling.
18. Reasons for substitution:
a) the specific chemical used is hazardous,
b) the use of a specific chemical is hazardous, if the application of precautionary
measures can not be guaranteed,
c) the specific chemical used is suspicious to be hazardous,
d) the specific chemical is expensive,
e) the technology, using a specific chemical, is expensive,
f) the safety measures, using a special chemical, are expensive,
g) there is a less hazardous alternative easy available and applicable,
h) internal management systems, external insurance providers, large customers or
governmental regulations demand the use of the least or a less hazardous technology,
i) the specific chemical is technically not fully satisfying, or
j) others.
19. To engage in effective discussion, the following is proposed:
II. Goals/objectives of a plenary session on the topic
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To raise awareness and discuss substitution by alternative substances and
technologies 4 as a proven and effective instrument to lower risks, in a multiperspective, multi-stakeholder way.
To identify and analyze potential triggers and drivers of substitution processes.
To explore the need to establish a clear picture of existing definitions and approaches
towards substitution and alternatives and consider presenting these in the form of
recommendations in what might be called the Dakar Recommendations on
Substitution and Alternatives.
4
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. In addition, they
present low dependency to fossil fuels, reducing the impact on the climate. 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. Perhaps it is useful to introduce some practical examples
of such non-chemical alternatives. Typical areas are: floor coverings of wood or textiles instead of
PVC, cleaning with high pressurised air or water instead of solvents, industrial cleaning with
ultrasound or vibration instead of solvents, pressing of pipes instead of welding (for water supply
in households).
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Intergovernmental Forum on Chemical Safety
Sixth Session – Forum VI
15 – 19 September 2008
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To discuss or share experiences on approaches or process mechanisms for
substitution, particularly for resource poor countries, including methodological tools
supporting prioritization and subsequent decision making.
To recommend measures in order to implement substitution as risk reduction
strategies on the international, regional, national and company level.
To develop risk management strategies involving all stakeholders of the productionand use-chain of a chemical, mainly producers and users of a chemical and the users
of the final product containing the chemical. The users of a final product are often the
most important partners, because they know best, which alternatives render an
adequate service and what advantages and disadvantages they have.
Issues that would be considered by the Forum
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Experiences and best practices regarding substitution as political instrument within
national, regional and international frameworks,
Experiences and best practices regarding substitution processes within industrial and
agricultural 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 multistakeholder perspective,5
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, 6
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 carcinogenic,
mutagenic, or reproductively-toxic (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,7
Process/mechanism for ensuring the substitution/alternative identified is truly less
harmful in the short and long term,
Criteria and methodologies to select and compare alternatives for different uses and
processes,
5
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.
6
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.
7
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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Intergovernmental Forum on Chemical Safety
Sixth Session – Forum VI
15 – 19 September 2008
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Resources for substitution (information and training in form of databases,
clearinghouses, technical support, seminars etc.),
Benefits of substitution for companies (economic, technical, organizational,
marketing, regulatory, etc.), for workers, for society, etc.,
Identify needs of different stakeholders of the substitution process,
Identify measures to implement substitution within chemical strategies on the
international, regional, national and company level,
Support of substitution by national or international financial incentives (R&D, green
taxes, financing of pilot processes or reference processes),
Good examples of benefits of substitution for companies (economic, technical,
organizational, marketing, regulatory, etc), for workers, for society, etc.,
Incentives for the substitution of harmful or possibly harmful (risk assessment
controversial) chemicals: legal, administrative, economic, political, financial, userbased, etc.,
Barriers to the substitution of harmful or possibly harmful (risk assessment
controversial) chemicals: legal, administrative, economic, political, financial, userbased, etc.
Possible Forum actions
20. The Forum might recommend:
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proven and effective ways, measures and approaches to implement substitution within
chemical strategies on the international, regional, national and company level, e.g.:
o lists of substances of high concern that must be substituted,
o company, country and regional chemical substances inventories,
o hazardous substances substitution plans with clear objectives and timelines,
and/or
o accessibility to information on alternatives substances and process.
potential mechanisms for substitution and the use of alternatives in differing country
contexts (i.e. developed, developing or economy in transition).
innovation support and research and development programs for alternative substances,
technologies and processes or overarching approaches (as e.g. Clean Production or Green
Chemistry).
development and application of methods to evaluate progress or success (before and after).
a database, which would gather such (already existing) information and it would be
available to all interested stakeholders. Members of IFCS should provide relevant
information, or provide links to already existing databases and information. (Chemicals
users don't have enough information on possible less dangerous alternatives.)
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Intergovernmental Forum on Chemical Safety
Sixth Session – Forum VI
15 – 19 September 2008
IV.
IFCS/Forum-VI/02.TS
26 February 2008
Plenary session structure
180 minutes
Eight presentations of 15 minutes each, with 60 minutes for plenary discussion
Possible presentation topics:
1. Setting the stage – substitution/alternatives: descriptions and approaches; what this
means in practice; scope (industrial chemicals, product development, agriculture,
producers’ views, users’ views, etc.), types.
2. 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 and/or economies in transition).
3. Non-chemical alternatives (processes, technologies, business models - in particular
“Chemical Leasing” and related service-oriented business-models, case examples and
preconditions for success).
4. Workers promoting substitution, accessible resources on alternatives (databases,
clearinghouses, technical support, economic support, training, etc).
5. Substitution as a strategy of product development – as well as a driver for innovation
(from stakeholder point of view).
6. Substitution issues and foreseeable implementation problems/challenges particularly
for developing countries and economies in transition.
7. Case on substitution: DDT and its alternatives.
8. Criteria and tools for selecting and comparing alternatives, as a means to identify
possible substitution opportunities German Column Model, Life Cycle Analysis
among others, 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.
9. Proposal for possible action to be taken by the Forum.
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