What is a Restricted Substances List?
The terms most often used for list-based screening are restricted substance lists (RSLs) and more recently manufacturing restricted substance lists (MRSLs). For the sake of brevity, the term “M/RSL” will be used as the generic reference. Despite the important progress that has been made using M/RSLs, manufacturers are realizing that list-based screening is not enough to ensure they can achieve their sustainable chemistry goals.
In our last blog, Why List-based Chemical Screening is not enough, we explained the meaning of RSLs, how they’re used, the ways in which they can be useful, and the limitations of relying solely on RSLs for chemicals management. Here we go further, to outline six recommended strategies for chemical management that ensure a more robust approach, benefitting suppliers, brands, and resulting in better outcomes for human health and the environment.
- Better data and measurement of chemical impacts
- Chemical footprinting to understand assets and liabilities
- Transparency throughout the value chain
- Provide suppliers with preferred or positive chemical lists
- Provide suppliers with the context of use of chemicals in products
- Incorporate principles from the circular economy
Manufacturers Need Better Data to Manage Chemicals Effectively
Many downstream manufacturers are realizing the need for more sophisticated methods of identifying and managing the chemicals used to make their products. M/RSLs are used as a first screen to identify known chemicals of concern so limited resources can be spent on assessing unlisted chemicals of concern.
Companies request their suppliers to fully disclose all chemicals, including known impurities or contaminants. Third party intermediaries (e.g., toxicology firms or software platforms) are used to gather the necessary information and to conduct chemical safety assessments for each chemical listed in a product formulation while protecting suppliers’ confidential information. A US-based chemicals management software company called Scivera provides its innovative platform, SciveraLENS, to many of the world’s most recognized retailers, brands, manufacturers, and upstream suppliers who use their software to assess the hazards of chemicals in products and process inputs.
In 2014, Scivera presented a paper to the Society of Toxicology which showed that of a sample size of 440 chemicals, 113 were considered “high hazard”, with only 46% being represented on any RSL. M/RSLs are not intended to be a comprehensive accounting of all chemicals of concern. This is why many companies incorporate Confidential Full Formulation Disclosure (CFFD) and Chemical Hazard Assessments (CHA) in addition to M/RSL screening into corporate chemical management strategies and business practices. Only chemical management systems that are based on full formulation disclosure, with mechanisms to protect confidential information driving comprehensive chemical safety assessments, can provide a practicable level of transparency.
M/RSLs provide only a partial view of a product’s thumbprint much less a company’s chemical footprint, which encompasses the entire product portfolio and value chain. The most effective way for a company to de-risk its business from chemical liabilities is to design and build a chemicals management system to provide a view of its chemical footprint at any given point in time. By converting bills of materials (BoMs) into bills of substances (BoSs) whose underlying hazard attributes are fully characterized, manufacturers can classify all of the chemicals in their material inventories, to account for their material “assets” and “liabilities”.
Chemicals and their related emissions can have potential impacts along their entire life cycle from creation, use in intermediate and finished products, and after each service life. There is little understanding, much less quantification, of the cumulative impacts of hazardous chemicals on humans or our environment at each stage. Downstream chemical users (i.e., retailers, brands, component suppliers) need greater transparency of the chemicals in their products to identify those that are known to be of concern (e.g., probable carcinogens, mutagens, reproductive toxicants, and endocrine disruptors as well as chemicals that are persistent, bioaccumulative and toxic).
Transparency drives better science and better system design. A transparent chemical information sharing system should be based purely on the inherent chemical hazard characteristics. This enables regulatory and manufacturing communities to accurately assess potential exposures and the probability of harm at each stage of their life cycle as used in manufacturing processes or as part of the composition of materials and products.
Exposure and risk assessments are predicated on having a full understanding of a chemical’s potential impact across all human and environmental fate endpoints. There are many chemicals that lack complete hazard data for all endpoints, and this hampers our ability to accurately estimate all potential routes of exposure as well as the risk of harm. Better transparency also allows manufacturers to protect the health of workers and surrounding communities who are most vulnerable to toxic emissions in their air, water and soil.
Provide Suppliers with Preferred or Positive Chemical Lists
If a company is able to identify a list of safer chemicals, to share with their suppliers, it is a cost effective and time efficient means to optimize manufacturing inputs. Levi Strauss & Co. provides their suppliers with a Preferred Chemical Product List with over 1,000 textile chemical products that have been certified to meet Screened Chemistry criteria. When chemical characterizations also include the function of chemicals it is much easier for manufacturers to search and replace chemicals of concern with safer substitutes. Characterizing hazard and function together greatly reduces the likelihood that manufacturers will replace a chemical of concern with one that is equally problematic (aka “regrettable substitution”).
Chemicals in products – Context of Use
The regulatory community lacks visibility into all of the possible product applications of potentially toxic chemicals. It is difficult to perform comprehensive exposure and risk assessments without an understanding of the context use. Often, it is only once a chemical or class of chemicals is causing harm that authorities are able to trace their use across multiple product applications. In an article on sustainable chemistry and the UN Sustainable Development Goals, Paul Anastas, one of the founding proponents of green chemistry describes what he views as the ultimate objective of any regulatory framework: “… the societal goal to advance sustainability is not to regulate a chemical, it is to address the unintended consequences of the chemical. Therefore, rather than simply identify a list of individual chemicals, it will be most important to identify those attributes that bring about the unintended consequences in the first place.”
Better chemical information allows manufacturers to communicate their priorities and leverage their purchasing power to send a clear demand signal to their suppliers. It also allows them to gauge potential exposures to workers, the impacts from emissions, as well any chemical liabilities passing to their downstream customers, consumers, and the recycling community.
Chemical Management in the Circular Economy
The circular economy is rooted in life cycle thinking and the interdependence of humans and ecosystems. In the context of chemical management, it is predicated on transparency and sharing of chemical information capable of informing scientific understanding, best practices and the creation of effective government policies. It also should be based on a shared consensus that the private sector has primary responsibility and accountability to use the safest chemicals possible for the manufacturer of products and their associated emissions. Building a chemicals management framework that seeks to prevent the introduction of toxic chemicals more than mitigating the risks associated with their use is reliant on access to accurate chemical data and much more transparency for how chemicals are being used in the manufacture of products and services.
There is increasing demand from consumers, retailers and brands for manufacturers to verify that they have systems in place to design and manufacture safer products. The business landscape is shifting, and regulatory compliance is no longer sufficient. While it is a good first step to use M/RSLs to achieve greater chemical transparency in their supply chains, companies will need to employ more comprehensive chemical management strategies and tools to realize the benefits of sustainable chemistry as a path to product and business innovation.
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