Intergovernmental Forum on Chemical Safety
Global Partnerships for Chemical Safety
Contributing to the 2020 Goal
ABSTRACTS
Substitution and Alternatives
ROOM DOCUMENT
List of Contents

Substitution and Alternative Assessment: Framing, Practice and Opportunities
Ken Geiser, USA

How to promote substitution effectively – practical lessons from case studies
Lothar Lissner, Germany

Dependency syndrome as the underlying challenge to substitution of toxic
chemicals in developing countries and economies
Richard Kiaka, iLima, Kenya

Chemical Leasing Business Model:
management of chemicals
Jorge Pérez, Mexico

Workers promoting substitution – case studies, tools, databases
Dolores Romano, ISTAS, Spain

Substitution strategy of a manufacturer of disinfectants
Michael Streek, Schülke & Mayr GmbH, Germany

Lessons learned to phase out DDT from Mexican Malaria Programme
Jorge Méndez, Ministry of Health, Mexico

Establishing tools and criteria for facilitating application of substitutes:
opportunities and challenges
Joel Tickner, University of Massachusetts Lowell, USA
a strategic approach for sustainable
Substitution and Alternative Assessment: Framing, Practice and Opportunities
Ken Geiser, Ph.D.
Director, Lowell Center for Sustainable Production
University of Massachusetts Lowell, Massachusetts, USA
Substitution is a common feature of all industrial and technological development
processes. It can be driven by economic, social, cultural or governmental initiatives.
The dynamics of modernization, industrialization and globalization all involve the
substitution of chemicals, technologies and practices. As such, substitution encourages
invention and promotes innovation and innovation involves the diffusion and adoption of
novel products and techniques.
Substitution can be an important risk reduction strategy where it involves the
replacement of chemicals, practices or technologies with other chemicals, practices or
technologies in order to improve human health and environmental quality. Recent
national and international programs such as pollution prevention, cleaner production,
inherent safety, toxics use reduction, chemicals policy reform and international chemical
restrictions on substances such as ozone depleting substances and persistent organic
pollutants all have promoted substitution
Risk reduction substitution can occur at the chemical, material, product, practice, or
systems level and there are numerous possibilities for changes between the levels. Any
attempt to ban, phase out or otherwise restrict a chemical generates substitution.
However, conventional government programs have too often paid too little attention to
guiding such substitution and the outcomes (as in gasoline additives and refrigerants)
have been regrettable. Substitutions typically involve costs and benefits and there is a
need to consider trade offs and potential equity transfers that may be necessary to ease
conversions.
Substitutions may occur on different scales ranging from small shopping decisions to
global chemical phase outs, however all substitutions generate ripples of consequences.
Substitutions beyond the smallest scale involve systems changes; some that are
intended; some, predictable, and some; unintended and unpredicted. We have begun
to develop methods for predicting and assessing these consequences, although much
work remains. The range of tools and protocols for guiding substitution such as facility
planning, alternatives assessment, technology options assessment, substitution analysis,
life cycle assessment, and comparative chemical profiling are at various stages of
development and implementation. Some governments, corporations and health care
institutions have adopted and regularly use such tools, but many have not.
Risk assessment can play an important role in substitution in screening for priority
setting, however, effective substitution is conventionally based on hazard assessment
and the inherent properties of chemicals and technologies in order to focus on the
fundamental sources of danger and their replacement. By focusing on the inherent
hazards of technologies, substitution creates new design opportunities for green
chemistry, green engineering, extended producer responsibility, chemical leasing, and
new forms of technology management and accountability.
Public policy and government initiatives can encourage or frustrate risk reduction
substitutions. It is useful to consider how best to use government authority to leverage,
guide and enhance socially desirable substitutions such that preferred outcomes are
achieved with minimal costs and limited unintended or regrettable consequences. This
is a broad new area for policy development.
How to promote substitution effectively – practical lessons from case studies
Lothar LISSNER
Germany / Kooperationsstelle Hamburg
The European legal framework for substitution is very supporting. The amount of EU
directives and Member States’ regulations obliging employers to substitute hazardous
chemicals raises the question: why is this process not already complete? Also under the
new REACH-legislation (Registration, Evaluation and Authorisation of Chemicals)
substitution will play a major role. REACH aims to promote the use of less dangerous
substances in future. A given authorisation can even be withdrawn if suitable substitutes
become available.
This is the legal framework; the reality is a little different. The Kooperationsstelle
Hamburg promoted several years the introduction of substitutes for organic solvents in
SME’s, e.g. water based brake cleaning devices instead of highly flammable solvents in
the car repair sector. Based on our practical experience we were charged by national
Ministries and by DG Environment of the EU to study, why companies are sometimes
eager and willing to substitute and often so reluctant to substitute.
These case studies covered substances or substance groups as high solvent coatings,
DEHP as plastic softener, conventional man-made mineral fibres, ceramic fibres,
chromate cement, methylene dichloride as paint stripper, organo-halogen solvents as triand perchloroethylene, organotin compounds, PCP and lindane, brominated flame
retardants, non biodegradable lubricants and NiCd accumulators. These are very
different substance groups; however, some common conclusions about substitution can
be drawn.
The first and most important blockade for substitution is uncertainty and reluctance to
change. For many companies, dealing with current problems, substitution is very
laborious and causes additional problems. The second reason is uncertainty in risk
assessment. The third reason is that substitutes are less tested in practice. Sometimes
the integration of a new product with suppliers and customers is difficult. Finally,
substitution causes often new technical problems or is less economic.
There are two main factors that strongly support substitution. Some of the main actors
are convinced that it is already a realistic target to create a world free of toxic chemicals.
Such people promote their guiding ideas by supporting product and process features as
water-based, biodegradable, simply ‘green’, zero waste or zero hazard. A second
perhaps even stronger factor are market forces. The market and the public force many
companies to avoid the use of any scandal substances that might harm their image.
What does this mean for regulation and policies? In the majority of cases, substitution is
the implementation of already wide-spread reference processes. In these cases
substitution requires nothing more than information about these reference processes.
Here substitution should be obliged and exceptions should only be made for certain
applications. In most cases substitution requires adaptation of the existing equipment or
processes. In such cases it is a regulatory option is to give time-limited authorisations. In
the most complex cases substitution needs innovative solutions, with all the problems
connected with that. This requires research, development and public or private financial
means.
Dependency syndrome as an underlying challenge to substitution of toxic
chemicals in developing countries and economies
Richard Kiaka, iLima, Kenya
Environmentally sound practices including chemical management can become real in
the presence of suitable attitude, technical and administrative conditions. The flow
should be such that proper scientific research on characteristics of various chemicals,
should guide formulation of effective policies which should lead to well informed public
and influence the implantation of the policies.
Research into toxic chemicals is least developed in the developing counties and
economies. Most research writings on toxic chemicals are largely done by researchers
from the developed countries and economies. Consequently the education tools for
public awareness and empowerment in circulation are mostly Eurocentric making the
whole concept of safer chemical management including substitution and alternatives be
viewed as western thinking rather than a human health and environmental concern. The
education and public awareness materials borrowed from the developed countries and
economies are even more complicated to interpret for use in the informal/artisan sector
making a substantial percentage of chemical users.
Where policy formulation is possible, insufficient data and relevant information lead to
hasty or inadequate policies which relevant to local toxic chemical issues. Furthermore,
the policy makers very often get influenced by foreign corporate companies whose main
focus is on the profit rather than the mitigation of the potential hazards of the toxic
chemicals. Where a policy or an implementation plan is formulated, lack of political will
emanating from poor governance and influence of multinational companies through
Foreign Direct Investments (FDIs), hinders the enforcement.
There is relatively low investment by the governments of developing countries and
economies into toxic chemicals research in order to develop best available technologies
(BAT) and best environmental practice (BEP). However, where funding is made
available through government, its flow from the treasury to the lowest level possible and
through the bureaucracies reduces its value. Moreover, the governments are more
interested in the macro-level economy sector where there is higher literacy levels on the
toxic chemicals than the small medium and micro-enterprises (SMMEs) where there
lower literacy levels on the chemicals.
Chemical Leasing Business Model: a strategic approach for sustainable
management of chemicals
Jorge Pérez, Mexico
In the following paper, we present the results of the implementation of the strategy for
sustainable chemicals management "Chemical Leasing", promoted by the Austrian
Government in collaboration with the United Nations Industrial Development
Organization. The Chemical Leasing Business Model is implemented in several
countries, including Mexico through the Mexican Cleaner Production Centre, which is
part of the UNIDO Cleaner Production programme and network. This brought significant
environmental and economic benefits: 1) reduction in chemicals consumption, 2)
substitution of chemicals for less hazardous substances to the environment and finally 3)
lower environmental affectation, with a responsible management of emissions and waste
due to the collaboration between the user and the supplier of chemicals.
Workers promoting substitution - case studies, tools, databases"
Dolores Romano, ISTAS, Spain
The International Labour Organization (ILO) estimates that 340,000 workers die each
year due to exposure to hazardous substances at their workplaces. Only asbestos is
responsible for more that 100,000 fatalities. Millions of workers are exposed to toxic
substances on a daily basis. Only in the EU-15 32 million workers are exposed to
carcinogens.
As a main group affected by the use of hazardous substances, workers may play an
important role promoting their substitution. Activities carried out by workers and unions
to promote the use of safer alternatives
include awareness building, training,
development of materials and tools to help identify, assess and compare hazardous
substances and alternatives, promoting toxic substitution in companies through bargain
with management, participation in Health and Safety Committees, and in EMAS,
promotion of substitution through collective bargain agreements, promotion of the
adoption and enforcement of policies, programs and regulations on substitution,
promotion of scientific and technical fora on substitution and safer alternatives.
Substitution case studies, tools and database developed by workers and unions from
different countries will be presented during the IFCS Forum VI Substitution and
Alternatives Plenary Session.
Substitution strategy of a manufacturer of disinfectants
Michael Streek, Schülke & Mayr GmbH, 22840 Norderstedt, Germany
The substitution strategy is based on the following facts:

Disinfectants make an active contribution to the fight against infections and
therefore protecting the health and the life of humans

As a result of the biocidal nature disinfectants are often hazardous substances
and can have an adverse effect on the environment

The use of disinfectants is strictly controlled in Europe by a large variety of
regulations, e.g. for drugs, medical devices and biocides
The presented solution of Schülke is based on the “Chemical Leasing” concept for
consumables. Schülke understands its role not only as a manufacturer and seller of
disinfectants but as an expert for implementing and maintaining high hygiene conditions.
This abstraction of the way we see ourselves draws the attention to the service we
provide to minimize the demand of disinfectants by providing consultation, training and
reorganization of processes while ensuring safe working conditions.
At the same time the revenues of the company will be ensured for the future
development and the impact on the environment minimized. Examples of the realization
of this concept will be presented.
Lessons learned to phase out DDT from Mexican Malaria Programme
Jorge F. Méndez-Galván, Ministry of Health, Mexico
Mexico has reduced the total new Malaria cases in such a way that now registers the
lowest historical records. Malaria control is now accepted as a shared responsibility
among government and local communities. Empowerment of these communities include
basic sanitation practices such as elimination of breeding mosquitoes’ sites,
improvement of houses, keeping houses clean and personal hygiene.
Community’s empowerment also provides them with capacity for early case detection
and treatment surveillance, increasing success in Malaria control.
In the light of Mexico´s experiences, it is clear that the old focus on Malaria eradication
and control, based on mosquitoes’ elimination with pesticides as a most important
measure, probable is no longer practical, desirable or sustainable due to the costs of the
programs, the dificulties of personnel and social and political problems, and not only
because pesticides use also has developed mosquito’s resistance and then a more
complex task to control them. Also, in most cases parasite resistance to chemotherapy
is a big issue.
Malaria control with community participation in Mexico has shown to be highly
successful since the phase out of DDT in 2000, when community participation started.
Through an integrated strategy that hit both Malaria parasite and vector (in both larval
and adult stages), local communities have tolls to reduce the encounter with vector and
transmission of the parasite. Chemical treatment is still needed in order to get a full
malaria control. An integral strategy and coordinated work between government and
local communities is the most effective and sustainable way to reduce and even
eliminate Malaria in local communities. To provide knowledge and some easy tools to
people can make a big difference.
Establishing tools and criteria for facilitating application of substitutes:
Challenges and Opportunities
Joel A. Tickner, ScD
Lowell Center for Sustainable Production
University of Massachusetts Lowell
An increased attention to substitution of chemicals of high concern with safer substitutes
creates significant challenges and opportunities for firms, governments and other
stakeholders. Some of the important challenges include:
What are the materials of highest concern that should be substituted?
What products are the materials of concern in? Are some uses of greater concern than
others and how should that be determined?
How does one define a safer substitute? What data are available and should be used in
such determinations? Will the substitutes have possible health safety and environment
trade offs?
Will the substitutes provide equal performance and cost characteristics?
Will technical support be needed for the implementation of substitutes?
Will safer chemicals and products have some preferential treatment in the marketplace?
This presentation explores some of the challenges to chemical substitution as well as
tools that have been developed by governments, industry and others to facilitate
effective, sustainable substitution decisions. These include the German Column Model,
the Swedish PRIO protocol, the UK Health and Safety Executive’s COSHH Essentials
the SC Johnson GreenList, and the Clean Production Action GreenScreen. We present
a framework for alternatives assessment that provides a concrete structure to guide
alternatives assessment processes and criteria that can help guide substitution
decisions in the future. We then explore emerging opportunities, tools, models and
policies that can help support firms and nations in advancing safer chemicals and
products.
In the end, successful substitution programs will require not just mandates for
substitution but also tools and support to governments and industry to overcome the
challenges to implementation as well as policies that incentivize safer products.