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Key factors for substitution decisions in complex products and production processes Presentation at

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 .

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Key factors for substitution decisions in complex products and production processes Presentation at

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  1. 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

  2. MAJOR SOURCES FOR OUR PRESENTATION 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

  3. CASES IN THE EU-STUDY

  4. 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 industriesInterviews with actors from all areas: enterprises, public, scienceNational workshops on issues as “Guiding principles”, “Management systems”

  5. SELECTED CASES IN GERMANY

  6. 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

  7. 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

  8. 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 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.

  9. 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...

  10. MAIN STRATEGIES TO REDUCE RISKS FROM HAZARDOUS CHEMICALS • Hazard reduction approach Substance-oriented • Emission control approach Risk-oriented • Personal protection approach Exposure-oriented

  11. MAIN STRATEGIES TO REDUCE RISKS FROM HAZARDOUS CHEMICALS 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

  12. 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

  13. OUR FINAL DEFINITION OF 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 functionalityvia technological or organisational measures”.

  14. 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).

  15. SUBSTITUTION – CASE STUDY”FAÇADE CLEANING” Substitution from chemical façade cleaning to the use of mechanical cleaning with water (high pressure cold and hot)

  16. SUBSTITUTION – CASE STUDY”FAÇADE CLEANING”

  17. SUBSTITUTION – CASE STUDY”METAL SURFACE CLEANING” ORGANOHALOGENS

  18. SUBSTITUTION – CASE STUDY”METAL SURFACE CLEANING” PETROCHEMICALS

  19. SUBSTITUTION – CASE STUDY”BROM. FLAME RETARDANTS”

  20. SUBSTITUTION – OVERVIEW OF INFLUENCE FACTORS

  21. 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.

  22. 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.

  23. 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).

  24. 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.)

  25. 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).

  26. 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.

  27. 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.

  28. 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.

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