Hunter S. Thompson once said: “It was the tension between those two poles - a restless idealism on one hand and a sense of impending doom on the other - that kept me going”. You may feel the same way sometimes…
Companies’ environmental health and safety (EH&S) regulatory compliance programmes and strategies have traditionally been aimed at preventing violations, fostering safety, reducing risk and managing waste. As new sustainability and green initiatives emerge as top priorities, the goals of underlying EH&S regulatory compliance programmes have become more ambitious.
New goals include minimising the adverse life cycle impacts of products and operations by designing lower impact products and processes. This approach requires integrating EH&S intelligence and expertise into core business processes, such as R&D, purchasing and operations. At the same time, a more complex regulatory imperative has evolved as global regulations become more complicated and dynamic.
The imperative to develop lower impact products and processes results in an important shift from a focus on violation prevention to embedded compliance. Environmentally smart business has evolved to become less about reactive tactics and more part of a strategic plan which includes green product design and supply chain actions with measurable success factors, rather than vague and incidental attempts to preserve and promote brand image.
How can you help your company integrate EH&S principles and intelligence into core business processes toactually procure, use and create safer, greener products, thus supporting your organisation to competitively operate in an ever changing regulatory and business climate? One possibility is to leverage existing EH&S data and tools to reduce toxic footprints and develop better products.
Understanding the principles
In Green Chemistry, Theory & Practice, Paul Anastas and John Warner define Green Chemistry as a particular type of pollution prevention which “involves the design and redesign of chemical synthesis and chemical products to prevent pollution and thereby solve environmental problems.” Their foundation work establishes an ethical responsibility and a scientific methodology for the development of environmentally innocuous but still economically viable chemical-based goods.
In addition to developing products with considered and benign environmental characteristics, a holistic approach to sustainability must also include application of those same criteria to the supply chain. Procurement of raw materials and non-process chemicals should likewise support the goals of reducing environmental risk and impacts.
Leveraging existing data
While each phase of the supply chain boasts its own unique sustainability requirements, there is a common thread throughout: access to comprehensive and accurate regulatory data is required during each and every phase, as this data is one of the most essential requirements for green and sustainability initiatives.
The importance of this information cannot be overstated: it is absolutely critical for assessing the EH&S sustainability footprint of chemical products. In fact, this data has most likely already been collected for compliance activities, such as hazard communication. Proper analysis reveals how it can also be used to aid in the development and selection of safer and more environmentally friendly products.
The well-known risk evaluation method: Risk = f(hazard*exposure) is useful when determining the relative desirability of products and substances. The hazard variable is exactly the kind of intelligence you are likely to find among toxicity and classification data already collected for compliance activities.
But what exactly should companies look for when evaluating existing data or when researching possible outsourced data alternatives? If the goal is accessing and managing data for green or sustainability initiatives, then users will need access to chemical profiles and substance data to analyse and compare products by toxicity, environmental impact, use type and cost.
Also, consider examining competitive products and developing comparisons of your company’s finished goods to that of similar products in the market place. Think about the results from three perspective: that of a customer, liability and sustainability.
If your competitors’ products gain better ratings based on your analysis how can you improve? If yours are better, let your customers know! Also consider choosing a data source that leverages global CAS level regulatory profiles and chemical classification information
Putting it all together
So, your CEO has issued a mandate (along with a public commitment in a press release) to reduce the company’s environmental impacts, procurement stands at the ready to make better purchasing decisions. Your researchers are smartly attired in organic cotton lab jackets. Now what?
The first step is to decide what winning really means, i.e. a good life lesson best learned early. In the context of achieving your environmental performance goals this means developing an understanding of what matters most to you, your organisation, your stakeholders, and your customers.
There so very many endpoints to consider that it is easy to become overwhelmed. Remember the previously mentioned risk equation. Look at your current data set, your compliance history and your waste stream, then examine what are your greatest current impacts and risks.
Evaluate measures such as severity and potency. What particular hazards can you most feasibly reduce and/or eliminate? These answers are most likely contained in your current body of data, as mentioned above. A detailed analysis of this data will provide a wealth of information regarding environmental effects, disposal considerations, risks to human health and exposure data.
Next, understand the current and pending regulatory landscape. Some components and products may have restrictions in the EU, which might be a significant source of your company’s revenue. Again, this type of information should already be something your company is maintaining in the EH&S and Regulatory Affairs departments.
Then, work with a highly qualified and strongly trusted data provider to understand what regulatory concerns may be pending. For example, is the US EPA working towards a ban on a particular Chemical Action Plan under the TSCA that will affect one or more of your options? Has one or more of your substances been listed as a SVHC under REACH?
Choosing the right green tool
Once you understand what criteria matter most and the related profiles of substances and products you are working with plus the associated global regulatory restrictions and limitations you can create normalised ratings in order to compare substances and products across use types. There exist in the marketplace robust tools for developing such ratings. The following are some key tips.
Look for a flexible system that allows users to use pre-determined criteria to calculate ratings and group products into categories, and even includes material costs to create direct and meaningful comparisons.
While green procurement and product evaluation are important to companies, without a universally-accepted standard for sustainability it can be difficult to develop and implement a successful green programme. The right tool can provide a baseline scoring methodology that can be completely customised to suit the requirements of a specific company or industry.
While the tool should be flexible it should also provide guidance to those who might still be defining their parameters. It should also integrate seamlessly with enterprise chemical and regulatory data in a way that enables decision makers to assess the sustainability footprint of raw materials or finished goods quickly, compare products to evaluate more environmentally friendly alternatives for greener purchasing decisions and create a simple baseline methodology to measure improvement.
The tool should leverage best-in-class content, both product level MSDS data and substance level regulatory data, from a highly qualified and trusted provider, in order to optimise the data management, criteria and scoring.
The tool should easily integrate into the enterprise’s MSDS inventory management system, and not be tied to a particular transactional or procurement model. And from a productivity standpoint, it should very quickly assess the chemical impact, with results shown in seconds, not hours or days.
In addition to all this, you should base purchasing decisions and product formulations on acceptable hazard ratings for components which are appropriate to the required use scheme.
Making safer, greener choices
The right EH&S data and tools can support green chemistry initiatives throughout the enterprise, product life cycle, and supply chain. By better tracking and managing chemical inventories and ensuring that the materials being used conform to corporate and regulatory throughout the product lifecycle, companies can reduce their toxic footprint and facilitate the development of greener products.
The sort of activity you will undertake to evolve product development and procurement within your organisation to support green ambitions is one of the smartest investments you can make in the competitive position of your organisation. And by leveraging much of the data already gathered and developed in-house for the purposes of compliance the resulting innovations need not require great capital investments.