Transcript Document

Framing a Future Chemicals Policy
27-29th April 2005
Colonnade hotel, Boston, MA, USA
Workshop presentations
Introduction
Dr. A. Michael Warhurst
Lowell Center for Sustainable
Production
Aim of workshops
• To discuss key aspects of
sustainable chemicals
management
• To focus on solutions, through
identification of options for
possible future discussion and
investigation
0. Introduction
Structure of workshops
• Each workshop had a background paper,
which was presented briefly by the
author
• The background papers are views of the
author, they are not comprehensive reviews of
the issue
• The papers were intended to start the
discussion in the workshops, and pose some
key questions
• The author was normally the rapporteur
• A facilitator ensured that:
• All participants were able to contribute to the
discussion
• The discussion stayed focussed on solutions,
and generated options
0. Introduction
Outcome of workshops
• Workshops were not expected to reach
consensus, but it was hoped that they would
discuss a number of options
• Some options may be mutually exclusive, others
might be best done together
• Not everyone would support every option
• Reporting of the workshops:
• Comments will not be attributed to individuals “Chatham House Rules”
• Facilitator, rapporteur and note takers will
collaborate to ensure the workshop is reported
fairly and accurately
• A short summary of the discussion was presented
by the rapporteur on Friday afternoon (see
following slides)
• A workshop summary will be written up after the
meeting, and published on the LCSP web site
0. Introduction
List of workshops
• Promotion of innovation, green chemistry and
alternative materials
• Defining and obtaining good quality information
for decision making
• Improving Information Flows – in Supply Chains
and Beyond
• Integration of US and Global chemical initiatives.
• Promotion and development of substitution and
alternatives assessment
• Integrating improved chemicals management into
business processes, including product design
• Improving our understanding of substance flows
through the economy
0. Introduction
Note re slides
• The following slides were
produced under great time
pressure during the conference
• They are not a definitive record of
the workshops, nor do they
necessarily fully represent the
views of those in the workshops
0. Introduction
Workshop #1: Promotion of
Innovation, Green Chemistry and
Alternative Materials
Rapporteur - Andrea Larson
1. Innovation
Option Categories
•
•
•
•
Primary research
Education
Transparency
Market campaigns
1. Innovation
Primary Research
in Green Chemistry
• Green Chemistry funding by
federal agencies (NSF, NIH, DOE,
DOD…)
• State level partnerships (like TURI)
1. Innovation
Education
•
•
•
•
•
Educate the educators
Curriculum development
K-12
Higher ed
Industry funding
1. Innovation
Transparency
• Credible 3rd party certification
• Labeling for consumers
• Alternatives assessment
requirements
• Better information for
manufacturers
• Content information for large
buyers
1. Innovation
Market Campaigns
• Retailer focus
• Identify leaders and laggards
1. Innovation
Information needs for decisionmaking that protects health and
spurs innovation
Credible information is critical for
companies, workers, government and the
public to understand and make better
decision and to stimulate innovation in
safer chemicals and processes.
Rapporteur - Mike Wilson
2. Information needs
What kind of information is needed
for decision-making, depending on
user (firm, government, worker,
consumer)
• Toxicity, ecotoxicity, fate, physical
properties, cumulative and interactive
effect, mixtures.
• Use, volume, qualitative exposure
(occupational, env dispersion etc)
• Alternative, green chemistry
• Materials flows, life cycle issues
2. Information needs
Information produced by whom?
• Producer responsible for
generating data, distributing
through commerce and
understanding uses, including
exposure.
• Key questions: Verifying data
produced by manufacturers;
introducing opportunities for
participatory process;
transparency of process; CBI
issues; liability concerns.
2. Information needs
Information needs and format
depends on who the information
is intended for.
• Producers;
• Supply chain: industrial users,
formulators;
• Retailers;
• Government agencies, policymakers;
• Workers and their representatives;
• Non-governmental organizations;
• Individual consumers
2. Information needs
What is the minimum amount of
information needed for decisionmaking?
• Screening tools necessary and
appropriate;
• QRA not prerequisite to action;
• Screening tools needed for
toxicity;
• P, B and toxicity issue.
2. Information needs
Options
• Increase body of information and
make it accessible;
• Develop more tools for rapid
screening; Swedish strategy;
• Policy for assuring duty of care;
• Policy for assuring distribution of
chemical information to wide body
of stakeholders.
2. Information needs
Options
• Combination of regulation,
incentives to achieve chemical
safety and innovation.
• Clearinghouses of public
information on alternatives, tech
assistance.
• Revise TSCA to introduce health
and environment into design of
chemicals.
2. Information needs
Workshop 3. Improving
Information Flows – In Supply
Chains
and Beyond
Report-back on workshop
outcomes
Rapporteur: Richard Denison
Facilitator: Liz Harriman
3. Information flow
Summary of Discussion
• Broad agreement that richer and freer
flow of information is needed
• Power of info is in its use
• Less agreement on what info and for what
purpose; whose responsibility
• Value chain barriers are real and impede
all actors/stakeholders
• CBI, liability, competition/secrecy
• MSDS insufficient
• Inconsistent, poor quality, little/no constituent
information
• Needed but also other needs: articles,
lifecycle, reflect transformations
3. Information flow
Key issues discussed
• Need to dissect current scope of CBI
claims
• How much info should be provided by
whom?
• Responsibility needs to flow down supply
chain
• Hazards only vs. composition
• Public ability to understand not excuse to
withhold
• Interpretation or appropriate decision
framework should not be left to provider only
• More than hazard (i.e., risk) info needed for
workplace
3. Information flow
Options for CBI
• Distinguish between CBI,
proprietary info in US law
• Criteria for when chemical identity can
be CBI
• Provide data ownership protection
while allowing disclosure
• Ensure data compensation/sharing
• Patents, exclusivity rights
• Purchasers reward disclosure in
marketplace
• Address liability?
3. Information flow
Options: How much info should
be provided?
• Crux of debate: All info available,
then distilled for specific vs.
Provide info tailored to need/user
• Options:
• Mfr: Process to identify info needs by
sector/product type/user;
• could use vol or reg to decide what gets
provided
• NGO: Require release of full info;
range of users decide how to use
3. Information flow
Options: How much info should
be provided?
• Downstream user:
• Require GHS data for all substances; govt
database
• Materials declaration model – other
sectors
• Labor: Require employer to assess
chemical risk to workers
3. Information flow
Workshop 4. Integration of US
& Global Chemical Initiatives
Report-back on workshop
outcomes
Rapporteur: Mark Rossi
4. Integration
Key options discussed
• Implement GHS (in the U.S.)
• Data Sharing
• Confidential Business Information
(CBI)
• POPs Ratification
• High Production Volume (HPV)
Chemical Data
• Stakeholder Working Group on
Information Sharing
4. Integration
Implement GHS (in the U.S.)
• Harmonize across sectors & agencies
• De-link from legislation
• Make the business case:
• Business to business dialogue
• Business – government dialogue
• Joint campaign in support of
implementation
• GHS data are very important to
downstream users
4. Integration
Data Sharing
• Clearinghouse
• Where to locate it? Trade associations?
• Government role? Facilitate? Require?
• Compensation?
• E-bay for chemical data – “chem bay”
• Share data for (free) w/downsteam users
in exchange for upstream sharing of
findings
• Inter-government data exchange –
mechanism is being created (EU & US
data portal) – create global data
• SAICM?
• Government incentives/sanctions for
providing data
4. Integration
Confidential Business
Information (CBI)
• Agree on what information should
be CBI, what information should
never be CBI, & when CBI should
be invoked
• Need to separate CBI from
proprietary data
• Need proposal from businesses on
how to handle CBI
4. Integration
POPs Ratification (in the U.S.)
• NGO-Business collaboration on
ratifying POPs
• Need to address implementation
question? How new chemicals are
added to the treaty (disagreement
• Ratify treaty at state level?
4. Integration
High Production Volume (HPV)
Data
• Mesh HPV data with other data
being collected
• Need long-term testing data on HPV
chemicals
• Options / priorities for lower volume
chemicals
• See Canada / Europe as model on how to
do this
4. Integration
Stakeholder Working Group
• Information Sharing, including
POPs, HPV, GHS
• NAFTA, North American Commission
for Environmental Cooperation to host
dialogue
4. Integration
Alternatives Assessment and
Substitution
Report-back on workshop outcomes
Beverley Thorpe (Rapp)
Sally Edwards, Pam Civie, Cathy
Crumbley
5. Substitution
Key Themes discussed
• Theme 1
• Substitution Planning
• Theme 2
• Education
• Theme 3
• Government Role
• Theme 4
• Institutional Customers and Role of
Procurement
5. Substitution
Theme 1: Substitution Planning
• Elements:
• 1 Mandatory/Voluntary
• 2 Who? Involve workers, community
• 3 Methodology: LCA? Indicators? RA?
Inherent hazard as basis?
• Advantages:
• 1Mandatory: Level Playing field
• 2 Prioritise common indicators/criteria used
• Problems:
• 1Lack of uniform consistent method
• 2 different value judgments/who pays
5. Substitution
Theme 2: Education
• Elements:
• 1Labeling
• 2 Broader consumer awareness
• 3 Training within industry/academia
• Advantages:
• 1stimulates market (NGO advocate)
• 2 Rewards responsible companies
• Problems:
• 1False Advertising/self promotion/Liability
• 2 not individual consumer responsibility
5. Substitution
Theme 3: Government role
• Elements:
• 1 Chemical Plant Security
• 2 substitution planning/chemical
info/Bans/phase outs
• 3 R&D, tax incentives/subsidy elimination
• Advantages:
• 1 Level playing field for companies
• 2 Fills current data gaps
• Problems:
• 1 No clear transition planning
• 2 lack of government commitment
5. Substitution
Theme 4: Institutional
customers/Procurement
• Elements:
• 1 Review specifications
• 2 Can be ‘biggest’ driver
• 3 Where is government responsibility?
• Advantages:
• 1 Quickly move market
• 2 takes onus off individual consumer
• Problems:
• 1Specs can hinder (eg carpets)
• 2 Company Staffing? Time?
5. Substitution
Recommendations for follow up
• Duplicate this type of conference in
Europe and Asia …
• Common ground statement from
conference (landmark conference!)
• Workshops needed for:
• Practical Tools - eg, Alternative Assessment
• Retailers
• Best Practices for: Specific Industry sectors
(eg toys)
• Advocacy groups, labor, gov’t …
5. Substitution
Workshop 6.
Integrating Chemicals
Management into Business
Decisions
Report-back on workshop
outcomes
Rapporteur: Tom Swarr
6. Chemicals Management
Who is Responsible?
Consumer
Education
OEM
Regulator
Government
Supplier
Formulator
Chemical
workers
community
6. Chemicals Management
Summary of Discussion
•
•
•
•
•
Information / Education
Regulations / Incentives
Accountability
Lessons from the 90’s P2 Efforts
Roles & Responsibilities across
supply chain
6. Chemicals Management
Key options discussed
• Goals from OEMs
• Set the direction w/ measurable
targets
• Better chemical information
• Dual track MSDSs
• Incentives / Regulation
• Information, rewards, & regulated
minimum
6. Chemicals Management
Option 1: OEM Goals
• Elements:
• Identify requirements
• Assess impacts
• Measurable targets tracked
• Advantages:
• Prioritization
• Market focus
• Problems:
• Complex supply chain
• Public participation
6. Chemicals Management
Option 2: Chemical Information
• Elements:
• Technical data for design/ develop
• Food pyramid for general audience
• Targeted & harmonized information
• Advantages:
• Better information = better informed
decision- makers
• Problems:
• Cost, flow through supply chain
• Access
6. Chemicals Management
Option 3: Incentives
• Elements:
• 3rd party certified information (labels,
required use information, etc.)
• Green procurement / funding
• Regulated floor
• Advantages / Problems:
• Finding the balance
• Public participation
• UL label doesn’t guarantee no fire
6. Chemicals Management
Workshop 7. Substance Flow
Analysis
• Report-back on workshop
outcomes
Rapporteur: Cheri Peele
7. Substance flows
Summary of Discussion
• Value of analysis depends on many
variables
• Which materials?
• Who would use information? For what
purpose(s)?
• Scope of information?
• At what cost? To whom?
• Need for systematic methodology
7. Substance flows
Variable 1: Materials
• PBTs
• High-value recyclable materials
• High-exposure chemicals (body
burden)
• High-volume and hazardous
• Substances of regional concern
7. Substance flows
Variable 2: Users of Analysis
•
•
•
•
•
•
Regulators
OEMs/Downstream users
Recyclers
Affected communities
Researchers focusing on exposure
Product/ process developers
7. Substance flows
Variable 3: Scope of Information
Collected
• Exposure information vs. mass
flow
• Black box economy vs. material
flow through economy
• Include environmental fate &
transformation?
• Consider:
• Transformation of chemicals
• What data is available
7. Substance flows
Variable 4: Data Collection
• How much is already available?
• EPA
• USGS
• USDA
• Need to find most cost-effective
point to ask questions
• How much do manufacturers know?
• CBI
7. Substance flows
Next steps
• Each workshop will be written up,
and these write ups will be
incorporated in the conference
report.
• The conference report will be
available on the Lowell Center for
Sustainable Production’s
Chemicals Policy web site:
• www.chemicalspolicy.org