Industry groups, nonprofits, governments and big brands, including Target, Walmart, Hewlett Packard, ZDHC and the U.S. Green Building Council, are prioritizing the identification and elimination of chemicals of concern.
When assessing the human and environmental impacts of product ingredients (or more accurately, chemical substances), there are four phases that a designer or manufacturer will engage in:
- Inventory. Knowing what is in the product. This requires engagement with suppliers and sub-suppliers to collect information on chemicals present in the materials that make the product.
- Screening. Once the chemicals in a product are known, they can be screened against established hazard lists lists to identify well-known hazards associated with those chemicals.
- Assessment. Because authoritative lists only include chemicals that have been in use long or extensively enough to have accumulated enough toxicity data to undergo evaluation by the list-setting entities, systematic reviews of the toxicological literature on chemicals are needed to get a complete picture of a chemical’s hazard profile and determine whether non-listed chemicals are truly safe or simply not yet on the radar. These assessments need to be conducted by a chemist or toxicologist.
- Optimization. With all of this good information, a company can start to optimize, reformulate, and even innovate toward the goal of products that pose no risks to humans or the environment.
Inventory and Disclosure of Chemical Ingredients
Why go to all this trouble? There is a push — across industry sectors — for greater transparency and understanding of the ingredients used in products. This approach calls on manufacturers to dig deep into their supply chains, identify all chemicals in their products and disclose them to their customers and, more and more often, to consumers. This transparency helps consumers avoid chemicals of concern while helping them make apples-to-apples comparisons of product options.
There are many barriers to supply chain transparency, including concerns around intellectual property, multiple layers of suppliers, inconsistent reporting and lack of knowledge. In addition, there is little incentive for players deep in the supply chain to share formulation information with their customers, let alone consumers.
Current regulations in the U.S. do not require suppliers to disclose their full formulations. Often the only available information about product ingredients can be found in a Material Safety Data Sheet (MSDS), which is a form required by the U.S. Occupational Safety and Health Administration (OSHA) for the disclosure of certain hazardous chemicals. However, MSDSs do not include all of the chemicals of concern that may be in products. Furthermore, many chemicals are harmful to consumers below the OSHA reporting threshold of 1 percent.
Some companies are setting themselves apart by disclosing everything that is in their products. Being an early adopter of transparency can demonstrate a company’s commitment to change and finding safer ingredients. Even more companies are committed to full material disclosure in their supply chain to understand the risks and opportunities to optimize for human and environmental health.
In the past few years, new tools have emerged to assist manufacturers with the challenge of inventorying and disclosing chemicals in their products. One example is the Health Product Declaration (HPD). The non-profit Health Product Declaration Collaborative (https://www.hpd-collaborative.org/) developed the HPD standard format that systematizes reporting language to enable transparent and standardized self-disclosure of information.
Knowing what's in your product is the first critical step to eliminating chemicals of concern. (We can't change what we don't know.) But just knowing what is in a product does not make it safe. An inventory of ingredients puts the burden on customers to recognize which chemicals they should avoid and understand what hazards and risks are involved.
Screening is an efficient first step in establishing priorities for substitution and elimination or for avoidance during the design phase. There are two types of lists that may be used for screening purposes: chemical hazard lists and restricted substance lists (RSLs).
Chemical Hazard Lists
A variety of state, national and international governmental bodies and nongovernmental organizations (NGOs) maintain chemical hazard lists. These are lists of substances for which an authoritative body of scientists or other qualified entity has undertaken a systematic review of scientific evidence and categorized the substances as having an association with a specific human or environmental health hazard. There are lists for persistent bioaccumulative toxicants (PBTs) and chemicals associated with specific human health endpoints, such as carcinogens, mutagens, and reproductive toxicants.
This category of lists also includes lists specific to aquatic toxicants, ozone depletors, greenhouse gases and chemicals associated with other specific human or environmental health impacts. Sometimes the lists will also categorize the strength of scientific evidence and certainty of the hazard (e.g., differentiating whether a substance is a “known” or “suspected” carcinogen) or the potency of a toxicant indicating the level of hazard.
Restricted Substances Lists
In addition to lists that simply identify and categorize hazards based upon a specific human or environmental health endpoint, there are also restricted substance lists (RSLs) that are policy tools for governments, nonprofits or companies. Some organizations have established restricted substance lists of chemicals that they want to avoid. They ask suppliers to declare that the products they supply don't contain any chemicals included on these lists.
RSLs frequently take into account multiple endpoints and may be based on regulation, assessments of the hazard and risk of specific chemicals, or other factors influencing chemical policy An example of a nonprofit RSL is the Cradle to Cradle Certified Products Program draft Version 4 RSL, which is a list of chemicals that are not eligible for use in certified products if present above the allowable threshold.
One type of RSL is an MRSL or Manufacturing Restricted Substances List. An MRSL addresses hazardous substances potentially used and discharged into the environment during manufacturing and related processes, not just those substances that could be present in finished products. One example of an MRSL is the Zero Discharge of Hazardous Chemicals (ZDHC) (http://www.roadmaptozero.com/fileadmin/layout/media/downloads/en/MRSL.pdf) list for the apparel and footwear industry.
While RSLs are a starting point to eliminate known hazards, this approach often leads to a perpetual revision process as regrettable substitutions are made with chemicals that are not on the list but have the same or worse human and environmental health impacts. For consumers, an RSLt only tells them what they are not getting. This approach may eliminate "known bads" to reduce immediate business and regulatory risk, but it does not help to prepare for the future and does not mean that a product is safe.
Given the number of chemical hazard lists and RSLs, it can be a daunting and time-intensive task for designers and manufacturers to sort through them all to establish which of their own ingredients may be listed on one list or another. To help speed this process, the MaterialWise screening tool automates this process using an online catalog of more than 50,000 chemicals. It identifies known human health and environmental hazards using more than 75 authoritative scientific lists. Users will also be able to reference restricted substance lists to check for compliance with certification and RSLs.
Screening allows manufacturers to quickly identify chemicals of high concern that are included or being considered for inclusion in their products. However, these lists may not include chemicals that are newer, less commonly used, or have not yet risen to the attention of the entities compiling the screening lists. On its own, this “free-of” approach is thus insufficient to ensure safe chemistry.
Because authoritative lists only include chemicals that have been in use long or extensively enough to have accumulated enough toxicity data to undergo evaluation by the list-setting entities, systematic reviews of the toxicological literature on chemicals are needed to get a complete picture of a chemical’s hazard profile and determine whether non-listed chemicals are truly safe or simply not yet on the radar. These assessments need to be conducted by a chemist or toxicologist
Chemical hazard assessments conducted by trained toxicologists and chemists to evaluate a comprehensive set of endpoints are the best way to determine the potential human and environmental health impacts of product ingredients. Manufacturers can use this information to make informed decisions in product design and development.
Conducting these assessments consistently and with integrity requires expertise and standardization. GreenScreen for Safer Chemicals and the Cradle to Cradle (C2C) Certified Product Standard offer credible methodologies to conduct hazard assessments.
Chemical hazard assessments are increasingly being recognized as a foundational tool for applications that include risk assessment, alternatives assessment and product design and development. In both GreenScreen and the Cradle to Cradle Material Health Assessment Methodology, chemical hazard assessments can inform substitution by identifying safer alternatives to chemicals of concern. They support product design and development by providing a scientifically robust and transparent way to evaluate and compare chemicals across a suite of hazard endpoints. They provide transparency about chemical hazards and data gaps, helping users to "know what they know, and to know what they don't know" about a chemical so they can reduce uncertainty and make informed decisions.
The goal of the assessment is to understand all human and environmental health hazards, with the goal of ultimately using only materials and chemicals that are safe; many products are actually optimized as they are going through the process.
The Cradle to Cradle Certified Material Health Assessment Methodology uses human health, environmental health and chemical class endpoints as the basis of a chemical’s evaluation. The rating scheme used for this methodology follows a “traffic-light” hierarchy in which the chemical’s hazard is communicated by a green, yellow, red or grey rating for each endpoint.
To assign these ratings, the assessor conducts research and performs data collection on all 19 human and environmental health endpoints. They examine all relevant sources of data, including measured data from standardized tests and scientific literature, authoritative lists and information derived from models and chemical analogs.
With all of this data, expert judgment classifies each hazard endpoint. In some cases, a data gap is assigned after an exhaustive search has been completed and no hazard classification can be made.
Whether using the Cradle to Cradle or GreenScreen methodology, this in-depth assessment process helps manufacturers identify hazards throughout the supply chain and manage priorities for reducing risk, replacing chemicals of concern and improving eco-effectiveness.
For manufacturers, the benefits of using assessment data include helping mitigate risk from known hazards, staying ahead of regulations and allowing for third-party verification of safer chemistry claims.
Material and Product Assessments
In the Cradle to Cradle Certified program, the chemical hazard assessments are taken one step further and rolled up into an evaluation at the material level. This includes a contextual evaluation that considers the relevant chemical hazards and exposure scenarios during the manufacturing, use and end-of-use phases. For example, titanium dioxide is carcinogenic via inhalation, but when it is encapsulated in a polymer it cannot be inhaled and this hazard is not relevant.
Assessments at the material level can help those who are designing more complex products to understand the relevance of the chemical hazards within a product. Furthermore, having a material level rating can help simplify the design process so that the manufacturer does not need advanced understanding of chemical-level hazards in each material.
The Cradle to Cradle Certified mark provides a quick reference for users to understand how much of the product has been inventoried, assessed and optimized. Any materials or products that have achieved the Gold level in the Material Health category are verified to pose no risk to human or environmental health, and this can be an easy identifier for preferred, safe chemistry.
Beyond evaluating the material health of a product, the Cradle to Cradle Certified program requires an assessment of the product's design for material reutilization, as well as against criteria for renewable energy use and carbon management, water stewardship, and social fairness. This can help a manufacturer understand the potential environmental impacts of a material choice that go beyond toxicity.
Information is power. Tools for material health, inventory, screening and assessments cannot only be used to support communication around the chemical safety of a product, but also guide manufacturers on how to make better ingredient decisions that can improve products and make a measurable impact on sustainability and human health. The benefits of this work include better decision-making and knowledge for product design and development, chemical and material procurement, risk management, workplace safety, and more.
The goal of the material health journey is optimized or “positive” materials that are safe for humans and the environment from manufacture to use to next use. The results are products that are manufactured with safe ingredients that can be perpetually cycled and are manufactured in ways that respect humans and the environment.
With good information from inventory, screening and assessment, a company can start to optimize, reformulate and even innovate to get to the goal of offering a product that poses no risks to humans or the environment.
Some strategies for optimization include:
- Elimination of the chemicals of concern
- Identifying alternatives
- Reformulating or redesigning a product
- Innovation through research and development
- Applying design thinking to eliminate the need for a problematic chemicals
Bringing Material Health to Scale
The transformation to safer products requires new processes, behavior changes and tools to empower manufacturers and suppliers. Data is the foundation of this transformation and will enable long-term scalable growth of green chemistry and positive product design.
Toward this end, MaterialWise intends to provide a suite of tools and processes that will empower manufacturers to improve the safety of the chemicals used in their products by providing cost-effective access to verified, actionable data about the materials and the chemicals they use. These tools will include:
- Free Chemical & Material Screening. MaterialWise will allow users to screen the ingredients in their products against an online catalog of more than 50,000 chemicals, including polymers, metals and other substances. It identifies known human and environmental health hazards using more than 75 authoritative scientific lists. Users will also be able to reference RSLs to check for compliance with certification program RSL’s such as Cradle to Cradle Certified and industry initiative MRSLs such as the Zero Discharge of Hazardous Chemicals (ZDHC) MRSL. This screening tool is powered by the Healthy Building Network’s Pharos.
- Education. A unique collaboration between the Ellen MacArthur Foundation and the Cradle to Cradle Products Innovation Institute will provide specific guidance on smart material choices for a circular economy in the form of four new material health learning modules to guide designers, innovators and manufacturers through the process of making smart material choices. These learning modules will be connected with MaterialWise and will leverage the free screening tool. Look for these new resources in July 2018.
- Industry Exchange. Piloting in 2018, this unique cooperative model will convene members with similar needs to work together to identify priorities for shared hazard profiles, pool resources, procure high-quality third-party verified hazard profiles, and share those profiles in a secure platform. This unique cooperative approach will create an efficient marketplace for the lease and exchange of information. The verification process will set a quality standard not seen before in this emerging practice and create trust for users, assessors and consumers alike.
Providing manufacturers with access to insights on the chemistry they are using throughout the design, development and production cycle will further accelerate the generation of positively designed products and inputs for the circular economy.