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L. Lißner & J. Lohse
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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
Kooperationsstelle
Hamburg
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L. Lißner & J. Lohse
MAJOR SOURCES FOR OUR PRESENTATION
Report 1: Substitution of Hazardous Chemicals
in Products and Processes
Report 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
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CASES IN THE EU-STUDY
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MAJOR SOURCES FOR OUR PRESENTATION
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 industries
Interviews with actors from all areas: enterprises, public, science
National workshops on issues as
“Guiding principles”, “Management systems”
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SELECTED CASES IN GERMANY
FIELD OF APPLICATION
CONVENTIONAL CHEMICALS AND POSSIBLE
SUBSTITUTES
Industrial cleaning of metal surfaces
Water-based cleaners vs. organo-halogen solvents
Softeners in plastics
DEHP vs. alternatives as DINP or DIDP
Mould releases (concrete separating
agents)
Petrochemical products vs. esters based on renewable
vegetable oils
Fibres in automotive silencers
Conventional man-made mineral fibres vs.. biosoluble
fibres
Mineral fibres in automotive catalytic
converters
Ceramic fibres vs. biodegradable fibres
Cutting fluids
Petrochemical oils and biocidal additives versus
minimum quantity cooling lubrication
Automotive series coatings
High solvent coatings vs. low solvent coatings
Cement
Chromate cement vs. cement with additives to reduce
skin diseases
Stripping agents
Methylene dichlorid vs. MDC-free stripping agents
Printing inks in packaging printing
Solvents vs. UV-drying
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SUBSTITUTION STANDS FOR A VARIETY OF CONCEPTS
 Policy level: Substitution as a general policy guideline
without specific instrumentation.
Substitution is obligatory, wherever it is possible
 Policy level: Substitution as a causal argument for a
market restriction aiming at relative risk reduction;
Substitution as policy instrument with high priority
 Enterprise level: Substitution as an integrated part of a
management system on the enterprise level;
Substitution as a permanent part of the risk analysis
 Enterprise level: Substitution as a continuous duty for
producers to evaluate the used substances and
alternatives and assess / compare the evaluated risk;
Substitution as a permanent highly important part of the risk
analysis and a measure with a high priority
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SUBSTITUTION AS KEY ELEMENT IN POLICY AND LEGISLATION
Substitution is a key concept in the EU Strategy for a Future
Chemicals Policy (COM[2001]88)
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
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SUBSTITUTION AS KEY ELEMENT IN POLICY AND LEGISLATION
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 work
Article 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.
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SUBSTITUTION AS KEY ELEMENT IN POLICY AND LEGISLATION
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...
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MAIN STRATEGIES TO REDUCE RISKS FROM
HAZARDOUS CHEMICALS
• Hazard reduction approach
Substance-oriented
• Emission control approach
Risk-oriented
• Personal protection approach
Exposure-oriented
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MAIN STRATEGIES TO REDUCE RISKS FROM
HAZARDOUS CHEMICALS
Substitution Type
1:
Substitution Type
2:
Substitution Type
3:
Replace hazardous
by a less
hazardous
substance while
maintaining
technology /
product
functionality
Use a less
hazardous or nonchemical solution
by changing the
technology /
product
functionality
Use a less
hazardous or nonchemical solution
by changing the
work organisation
/ product use
pattern
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APPROACHES OF SUBSTUTION
EXAMPLE 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
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OUR FINAL DEFINITION OF SUBSTITUTION:
“Substitution means the replacement or
reduction of hazardous substances in products
and processes by less hazardous or nonhazardous substances, or by achieving an
equivalent functionality via technological or
organisational measures”.
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Hamburg
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SUBSTITUTION – DEFICITS IN PRACTICE
•
•
•
•
Most enterprises do not follow the most simple rules:
Cited from BAUA – Federal Institute for Occupational Safety and
Health in Germany: „All in all it can be assumed that around 70% of
commercial users of hazardous substances do not (or cannot) observe
the statutory requirements of employee protection.“
HSE: „In approximately 1.3 million British companies chemicals are
handled. When questioned, only 16% of these companies were able to
state the applicable law for handling chemicals or the limit values for
these substances at the workplace.“
The European Agency for Safety and Health at Work states in a
laconic way: “There is a need for monitoring compliance with
legislation” .
By way of reaction to the evident deficit in implementing the
differentiated chemicals/hazardous substance legislation in Europe,
the authorities responsible in all EU Member States set up the CLEEN
network (Chemical Legislation Enforcement Network).
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Hamburg
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SUBSTITUTION – CASE STUDY”FAÇADE CLEANING”
Substitution from
chemical
façade
cleaning
to the to
usethe
of mechanical
cleaning with water
Substitution
from
chemical
façade
cleaning
use of mechanical
(high pressure
and(high
hot) pressure cold and hot)
cleaning
withcold
water
PRO SUBSTITUTION
Environmental hazards
Less chemical health
hazards
CONTRA SUBSTITUTION
MAIN ACTORS
Speed of the working process
Cleaning enterprises, workers
Reduced cleaning effectiveness
Cleaning enterprises
against strong staining, fats and oils
Environmental authorities
Workers, Trade Unions
Experience of workers with
conventional methods
More advanced and expensive application technologies and equipment
Accident risks for workers: contact
with high pressure water and / or
with hot water
Larger amounts of waste water
Workers, Foremen
Cleaning enterprises
Workers, Trade Unions, Costs of
absence, Health and Safety Authorities
Cleaning enterprises (Costs),
Environmental authorities
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Hamburg
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SUBSTITUTION – CASE STUDY”FAÇADE CLEANING”
PRO SUBSTITUTION
CONTRA SUBSTITUTION
Costs of illness
Selling of more (other, higher
priced) cleaning equipment
Costs of water based cleaners
Costs of energy for hot water cleaning
Threat of freezing
Premature decay
Oxidation of masonry
Regulations for restoration: physical
treatment and strong wetting of the
surface not accepted, but strong chemicals
Regulations for restoration of
historic buildings: no strong
chemicals accepted
Costs for removal of
contaminated waste
Less risks of spilling and water
contamination
MAIN ACTORS
Workers, Trade Unions
Equipment suppliers
Cleaning enterprises
Cleaning enterprises
Enterprises, Owners
Owners
Owners
Local and regional cultural
heritage protection authorities
Local and regional cultural
heritage protection authorities
Local and regional authorities
Local and regional authorities
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SUBSTITUTION – CASE STUDY”METAL SURFACE CLEANING”
O
R
G
A
N
O
H
A
L
O
G
E
N
S
MAJOR ROUTE OF USE AND SUBSTITUTION
Carbontetrachloride (CCL4)
(1850 to 1940)
1,1,1,Trichlorethan
and similarchlor. solv.
)
(1920 to a very limited use today
Perchloroethylen (C2CL4)
(1930 to today)
Trichloroethylen
e(1920 to
loosing market
today, share towards
PER
MINOR USE AND ROUTE OF SUBSTITUTION
Chlorofluoro
carbons (CFC’ s)
)
(1940 to 1980
Hydrochlorofluoro
carbons (HCFC’s)
(1975 to today)
)
Hydrofluoroether HFE’sand
Perfluorocarbons(PFC’s)
(1975 to today)
MAJOR ROUTE OF USE AND SUBSTITUTION
Carbontetrachloride (CCL4)
1,1,1,Trichlorethan
and similar chlor. solv.
Carbontetrachloride (CCL4)
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SUBSTITUTION – CASE STUDY”METAL SURFACE CLEANING”
P
E
T
R
O
C
H
E
M
I
C
A
L
S
MAJOR ROUTE OF USE AND SUBSTITUTION
CRUDE SOLVENT
Mixtures of all types
mainly alkanes
containing aromates
SOLVENT MIXTURES
with less impurities and
without benzene
(from 1960)
SOLVENT MIXTURES
without aromates
(from 1980)
SOLVENT MIXTURES
without aromates
(from 1980)
MINOR USE AND ROUTE OF SUBSTITUTION
Alcohols , Ketones , Esters,
Ethers, Acids,
all other hydrocarbon based alternatives
SEMI-AEQUEOUS CLEANERS
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SUBSTITUTION – CASE STUDY”BROM. FLAME RETARDANTS”
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SUBSTITUTION – OVERVIEW OF INFLUENCE FACTORS
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RESULTS: ENTERPRISES
Enterprises with superior interest in innovation to replace dangerous
chemicals – to substitute - are few. Cases with purely market driven
substitution are rare.
Main arguments encountered are:
- “too time-consuming task”
- "no one takes the lead“
- "unclear interests, roles and responsibilities of potential
co-operation partners”
- “problems occur immediately, success is only expected”
“Co-Evolution“ with other actors of the supply chain is necessary but
does often simply not happen due to insufficient communication.
Public forces become influential where chemicals are under public
concern or discussion.
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Hamburg
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RESULTS: ENTERPRISES
In order to avoid problems regarding process integration and product
quality, companies normally prefer to
• take small steps towards less hazardous chemicals instead of big steps
(e.g. metal parts cleaning HC development).
• apply emission control or protective measures rather than undergoing
changes in process or product performance itself
Large companies assembling a product from a large number of supplied
components – like electronic or car industry – have developed their own
substitution rules (strict control, internal black and green lists etc.).
In some branches green and ethic considerations have an increasing
strategic impact.
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Hamburg
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RESULTS: PRODUCERS OF CHEMICALS
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).
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Hamburg
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RESULTS: IMPORTANT OTHER INDUSTRIAL ACTORS
The suppliers (traders) between producers and users play an important
but underestimated role.
They can function as
- strong propagators (big retail chains in the textile industry)
- or as a real barrier (Metal parts, Mould releases).
Equipment producers potentially play an innovative role, because a
change of chemicals often includes the opportunity to sell new or additional
equipment (emission control and substitution.)
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Hamburg
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RESULTS: AUTHORITIES
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).
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CONCLUSIONS AND RECOMMENDATIONS
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.
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Hamburg
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CONCLUSIONS AND RECOMMENDATIONS
FULL PICTURE OF THE ECONOMY OF THE SUBSTITUTE
When comparing the current situation with a possible alternative situation,
economic considerations should include factors as:
• Price / performance ratio
• Man hours connected with the use of the substance or preparation
• Investment costs for technical equipment
• Energy consumption
• Price of freshwater and waste water treatment
• Environmental protection costs (air, soil and water)
• Health and safety protection costs
• Waste management and disposal costs and
• Accident and fire protection incl. insurance costs.
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CONCLUSIONS AND RECOMMENDATIONS
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.
Kooperationsstelle
Hamburg