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Are Raw Material Suppliers and Manufacturers Already Conducting Internal “Green” Chemistry Analysis?

Posted on 2/24/2014 4:13:52 PM By Paul Bertram
  

Are raw material suppliers and manufacturers already conducting internal “green” chemistry analysis?

The chemical makeup of products has traditionally been closely held corporate information and in many cases, beyond Federal and State reporting requirements, only known by a few key team members on a need to know basis.

Understanding the chemical makeup of an end product as related to hazardous material, risk and exposure is as complex as the molecular composition of the individual chemistries and end product. Green chemists already look at the entire life cycle of a chemical product—including raw material acquisition, design and manufacture of the product, consumer use, and finally the sustainable recycling or disposal of the product. Continuous improvement in chemical synthesis analysis includes:

•     Replacing dangerous or environmentally unsuitable chemistries

•     Reducing the number of synthetic steps

•     Analysis of complex molecules and multi-step syntheses

Per their website, the Health Product Declaration Collaborative has introduced their “Health Product Declaration Standard” for manufacturers to report “individual” chemistry makeup of their products. Their objective was to establish a standard format to support consumers’ informed decisions about the products they purchase and their impacts on human health, and to reduce the burden on product manufacturers juggling multiple types of information requests and reporting formats.

SCOPE:
This HPD Standard describes a declaration of product content and direct health hazards associated with exposure to its individual contents.

HAZARD DISCLOSURE
Whether the identity of each ingredient is fully disclosed or not, the HPD Standard requires disclosure of the health hazards associated with each ingredient to be considered complete. The HPD Standard identifies a minimum set of authoritative chemical hazard lists against which ingredients are required to be screened for health and environmental hazards.

The Health Product Declaration Priority Hazard Lists and the warnings that must be included are listed in Appendix D – HPD Priority List Sources & E – HPD Priority List Warnings. For hazard, the HPD Standard only has one threshold of disclosure: Full Disclosure of Known Hazards.

hpd

In a recent conversation with HPD Collaborative’s Technical Director—Eden Brukman—I discussed the concerns about language such as: “manufacturers to report “individual” chemistry makeup of their products”; “product content and direct health hazards associated with exposure to its individual contents.”; and “Full Disclosure of Known Hazards”.

Eden is working on additional clarifications to the reporting requirements because of confusion in understanding exactly what information is acceptable within the limits of a manufacturer’s availability of upstream data.

The Challenges

Concerns that I have consistently heard:

  • Not clearly understanding the objective of supplying “Individual” chemistry makeup of products as related to cross referencing to 30 priority hazardous lists.
  • What consumer would be able to understand HPD reporting; including architects/specifiers?
  • Reporting of “individual” chemistries to be cross referenced to 30 hazardous priority lists for the purposes of product selection or de-selection is an oversimplification of a complex issue.
  • Manufacturers are currently required by law to label any hazardous materials – so why this reporting being requested?
  • Trade secret confidentiality concerns at all levels – end product, raw material suppliers, etc.
  • Legal liability concerns.
  • Many believe this reporting is already provided through OSHA’s regulated Hazard Communication Standard (HCS) that is to conform with the United Nations' (UN) Globally Harmonized System of Classification and Labeling of Chemicals (GHS) Limitations of using data beyond boundaries of supplier NDAs.

Manufacturers have multiple pathways to respond to the HPD movement:

  • One pathway would be to not to provide an HPD with the knowledge that the potential projects, from those firms sending out letters requesting HPD information, would be in jeopardy.
  • A more palatable pathway might be to conduct the HPD as an internal exercise to better understand potential hazards that might be listed in the HPD. That information could then be a basis to have a discussion with the HPD collaboration and the architectural firms requesting the HPD.
    • Note: This was a pathway Kingspan Insulated Panels used and although the HPD has not yet been publically published, the analysis resulted in transitioning to the elimination of a halogenated flame retardant.
    • Internal analysis of the requested information from the HPD could also be the basis of discussions with manufacturer’s upstream suppliers and their raw material suppliers for the purposes of reducing or eliminating materials listed as hazards.
    • The ACC – American Chemistry Council’s Responsible Care® Guiding Principles encourages members who sign on to this program to:
      • Lead in ethical ways that increasingly benefit society, the economy and the environment. 
      • Design and develop products that can be manufactured, transported, used and disposed of or recycled safely.  
      • Work with customers, carriers, suppliers, distributors and contractors to foster the safe and secure use, transport and disposal of chemicals and provide hazard and risk information that can be accessed and applied in their operations and products. 
      • Attach a disclaimer.  This is another concept that might be considered by a manufacturer or supplier that sends out or posts a HPD document. The disclaimer could clarify the limitations of the reporting, making it clear that this is done solely to fulfill certain procedural requirements to comply with an aspirational system (HPD or otherwise).

To achieve the scale of HPD reporting to be effective as a “social benefit” greater industry participation is required. Social considerations are a key part of corporate sustainability reporting.

I use the term “social benefit” because this is the basic premise along with, The Precautionary Principle, of a using the HPD and related Hazard Priority list. The HPD is intended to provide information to consumers to make better informed decisions related to health impacts based on FULL DISCLOSURE of hazards.

Industry can debate the lack of science regarding the HPD reporting initiative, but through what I am going to call “Crowd Sourcing,” the movement has gained support that can’t be ignored.

The HPD Collaboration is aware of this cautionary industry resistance and as a result, created the Manufacturers Advisory Panel as a platform for interactive dialog to advance to goals and objectives of the HPD.

While caution is an appropriate reaction to HPD reporting, once again, I encourage you to work in conjunction with ASC to discuss how to best respond to the issue of material ingredient transparency.



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