Integrating Alternatives Assessment into Your Materials Compliance

Integrating Alternatives
Assessment into Your Materials
Compliance Strategy
Cory Robertson
HP Inc.
RoHS
The Law That Changed Everything
EU 2006
• Lead (Pb)
• Mercury (Hg)
• Cadmium (Cd)
• Hexavalent Chromium (Cr6+)
• Polybrominated Biphenyls
(PBB)
• Polybrominated Diphenyl
Ethers (PBDE)
Logo from companion
regulation
Waste Electrical and
Electronic Equipment (WEEE)
Directive
Are the alternatives better?
2
More Regulations Coming
• Substance restrictions
have become a major
class of regulation for
finished electronic
products
• More substances
• More jurisdictions
• More reporting
Avoid Future Regulation: HP wants to use
materials no one cares about
3
Hazard
Table
U.S. EPA Alternatives Assessment:
Partnership to Evaluate Flame
Retardants in Printed Circuit Boards
•IARC
•Prop 65
•Data
•i.e. LD-50
•Proxy
Chemicals
•QSAR
•Expert
Judgment
•GHS Criteria
•R-phrases
•H-phrases
Training Available
4
Decision
Logic
5
Shift to Hazard
Reduction
12 Principles of Green Chemistry
• Reducing risk through hazard
reduction is more effective and
efficient than exposure reduction
• Better to use inherently safer
chemicals rather than trying to
make a hazardous substance
“safe enough” by limiting
exposure
6
Aligns with
Regulators
Normalizes Stakeholder Inputs
Simple 1-4 score (1=bad, 4=good)
Fate
• Expert knowledge is required
to generate and peer review
the score
• Once generated, the simple
score can be used by others
even if they have no technical
training
Ecotoxicity
GS Benchmark
P
B
AA
CA
Chem #1
2
H
L
L
H
Chem #2
4
L
L
L
H
Chem #3
2
L
L
H
M
Chem #4
1
L
L
H
dg
Chem #5
3
L
M
M
dg
8
9
10
Aquatic Toxicity
Persistent
LD50 = 2150mg/kg
R50/53
Mutagenicity
Bioaccumulation
11
12
13
Avoiding extra substitutions saves money
Any unrestricted
Phthalate 1
$X
DEHP
RoHS 2
Added 2015
Restricted 2019
Phthalate 2
$X
Non-orthophthalate
$X
Transition
Costs
$3X
Incrementally better
Phthalate 1
$X
Non-orthophthalate
$X
$2X
Best
Non-ortho-phthalate
$X
$1X
GreenScreen™ for Assessing
Replacements for Restricted
Substances in Electronics
15
Structural Plastic
Database
Supplier
Supplier Composi Recycled Risk Phase Green Screen HP GSE
Material ID
tion
Content Assessment of Additives Rev. O
for the FRs
HP
Confidential
Notes
ABS, PC, Virgn or Directive
Benchmarks Table 1 Spec for Spec for
PC+ABS, Recyled 67/548/EC
shown have Page 7-9 Plastics Plastics
PC+20GF with XX%
been reviewed
, etc.
post
by HP Green
generic consume
Screen Team
resin r content
composit
ion
Supplier 1 Plastic 111
PC/ABS
Virgin
none
2
Supplier 1 Plastic 222
PC/ABS
Virgin
R53
1
PC
65%
none
Unknown
Supplier 2
Polymer
9099
RoHS BFR/PVC
Meets
Eligible for
FR eligible for EU
2.0
Free
TCO DT EPEAT 4.1.6.2
Ecolabel?
Rev. F
3.0 and optional point?
AiO 1.0
R50/R53,
based on
FR
R40, R45, R40, 45, 46, 50, Numerous Risk
R46, R48, 51, 52, 53, 60, Phrases--Refer to
R50/R53, 61, 62, 63 and Declaration Letter
R60, R61;
their
only for parts > 25
combinations;
g
only for only for parts >
parts > 25
25 g
g
Yes
Yes
Yes
Yes - FR's
meet req.
Yes
Yes
Yes
Yes
No
No
Yes
Yes
Yes
Yes
Yes
Yes - FR's meet
req.
Yes
Yes
16
Electronics Cleaners
Repair and rework spot cleaners
used in the manufacturing
process
•Spot cleaners have little
exposure control
•Field repair
•Rework stations
•New material type =
manufacturing
chemical (not product
material)
•Worked with formulators
to develop effective
cleaners that meet
hazard criteria
•Challenges
•Dealing with mixtures
•Synergistic effects
•Efficacy may require small
amounts of GreenScreen™
Benchmark 1 chemicals
PVC-Free Power Cord
GreenScreen™ Pilot
• PVC being phased out
voluntarily
• Screening mandatory, in
addition to all standard and
regulatory requirements
• Full disclosure under CDA
• Supplier Training
• Over 30 materials screened
• Several approved
18
Integrated Alternatives
Assessment
California Safer Consumer
Products
BizNGO Project
California Safer Consumer
Products Regulation
• Became effective October 1, 2013
1) Is this chemical necessary?
2) Is there a safer alternative?
• Manufacturers of Priority Products required to
produce alternatives assessments on Candidate
Chemicals
• Brand reputation is a key driver
21
Alternatives Assessment
Pilot Project
Purpose: Gain useful experience to inform
public comments on Safer Consumer Product
regulations and guidance documents by
completing an Alternatives Analysis that meets
requirements of Article 5 of the SCP Regulation
Summer 2012 to Winter 2013
22
BizNGO
bizngo.org
• Collaboration of representatives from leading
companies and non-governmental organizations
(NGOs)
• Launched in 2006 by Clean Production Action
• Mission: To promote the creation and adoption of
safer chemicals and sustainable materials, thereby
creating market transitions to a healthy economy,
healthy environment, and healthy people.
23
Decabromodiphenyl Ether
(DecaBDE)
• Successfully substituted already
• Data rich
• Allowed for focus on the process
24
BizNGO Chemical Alternative
Assessment Protocol
• BizNGO
Framework
• Phased/ordered
steps
• Hazard first
• LCA and
exposure
25
Stage 1 Process Observations – Many
Alternatives
• Over 100 Alternatives
• Group alternatives and analyze a
representative from the group
• Allow any reason for de-selection in
stage 1
• Advanced multiple alternatives into
stage 2
• Objective is to find better alternatives
not necessarily the “greenest”
MDH - Magnesium di-hydroxide
RDP Resorcinol bis (diphenyl
phosphate)
DfE Hazard Table, Known Alternative
TPP - triphenyl phosphate
DfE Hazard Table, Known Alternative
Zinc Borate
DfE Hazard Table, Known Alternative
Aluminum housing material
Material Change
Added sheet metal fire enclosure
Material Change
High PC content PC/ABS
Tris-(2-ethylhexyl) phosphate
Material Change
Representative--Alkyl Phosphate
Group
silicon dioxide
Representative--Filler Group
ZnHS - Zinc Hydroxystannate
BFR Synergist
Antinomy trioxide
APP Ammonium Polyphosphate
(coated)
BFR Synergist
DfE Hazard Table, Known Alternative
Duplicate
APP Ammonium Polyphosphate (with
synergists)
Duplicate
Boehmite (Aluminium oxide
hydroxide)
Group--Aluminum tri-hydroxide
DEEP - Diethylethane phosphonate
Group--Alkyl Phosphate
Expandable graphite
Group--Filler
26
GreenScreen® Hazard Assessment Tool
Benchmark 1
prohibited
-
Benchmark 2 or higher is
required
Converted the
Benchmark 1 criteria into
endpoints
Hazard endpoint
Group I Human
Carcinogenicity
Mutagenicity/Genotoxicity
Reproductive Toxicity
Developmental Toxicity
Endocrine Activity
Group II Human
Acute toxicity
Systemic Toxicity/Organ Effects and
Neurotoxicity; single exposure
Systemic Toxicity/Organ Effects and
Neurotoxicity; repeated exposure*
Skin Sensitization*
Respiratory Sensitization*
Skin Irritation
Eye Irritation
Ecotoxicity
Acute Aquatic Toxicity
Chronic Aquatic Toxicity
Fate
Persistence (P)
Bioaccumulation (B)
Reactivity
Flammability
Criteria Cutoff
High
GHS Category 1A (Known) or 1B (Presumed)
GHS Category 1A (Known) or 1B (Presumed)
GHS Category 1A (Known) or 1B (Presumed)
GHS Category 1A (Known) or 1B (Presumed)
Evidence of endocrine activity
Very High
High
GHS Category 1 or 2
GHS Category 3
GHS Category 1
GHS Category 2
GHS Category 1
GHS Category 1
(Corrosive)
GHS Category 1
(Irreversible)
GHS Category 1A
GSH Category 1A
GHS Category 2 (Irritant)
GHS Category 2A
(Irritating)
GHS Category 1
GHS Category 2
NOEC < 1.0 mg/L
NOEC < 1.0 mg/L
Very High
High
Days:
Days
Soil: t1/2>180
Soil: 60 < t1/2 < 180
Water: t1/2>60
Water: 40 < t1/2 < 60
Air: t1/2>50
Air: 2 < t1/2 < 5
BAF/BCF > 5000;
1000 < BAF/BCF < 5000
Log Kow > 5.0
4.5 < Log Kow < 5.0
Equally or less reactive than chemical of concern
Equally or less flammable than chemical of concern
27
27
Stage 2 Product Function and
Performance
• Performed finite
element analysis
• All of the alternatives
performed adequately
• Ultimately, prototypes
will determine
suitability
• Important to have
many alternatives
28
Stage 2 Economic Impacts
• Used 2006 study by Washington
State Department of Ecology
• Predicted an $80 benefit per
person
Deeply Problematic
No Data Sources
No Methods
• Based on hazard assessment all of
the alternatives are expected to
have lower economic impact
• Would be very different if we had
proposed continued use of the
chemical of concern
29
29
Summary Matrix
A Adverse Environmental Impacts
B Adverse Public Health Impacts
C…
30
30
Project Conclusions
• Provided feedback and lessons learned to CA
DTSC
• DTSC provided a completeness review
• Sufficiency is still an open issue—how do you
know when you are done
• Brand reputation is an important driver
• Guidance and standards are needed
http://www.bizngo.org/alternatives-assessment/model-assessments
31
31
A Framework to Guide
Selection of Chemical
Alternatives
National Academy of Sciences
Why Hazard Assessment
First?
• Hazard assessments are faster, easier to
complete than complete LCA or Risk
– Narrower, endpoints are relatively well defined
– Science-based, facilitates relatively quick
chemical assessments
– Can screen out hazardous options before
investing time and money
• Regulatory bodies are increasingly using hazard
as a screen for substances of concern, so useful
an indicator of future restriction
– Aligns business process with regulatory
process
3
5
Lessons Learned
What has changed?
If we articulate
environmental
requirements to our
suppliers we get
better materials
37
“Maybe we should pre-screen
our materials before we send
you our formulations.”
--Polymer formulator
“Our customers are asking us
about HP’s requirements.”
–Flame retardant supplier
Surprises?
•Many suppliers have similar frameworks
that they use internally.
•Suppliers have additional toxicology data
that isn’t publically available.
•Just asking our suppliers to do the
GreenScreen™ assessments motivated
suppliers to remove chemicals from
some formulations.
39
Ecolabels
•Non halogenated flame retardants used in
plastic parts that weigh more than 25 grams
shall be on the publically available Accepted
Substance List for TCO Certified. This means
that the substance has been assessed by a
licensed profiler according to GreenScreen™
and been assigned a benchmark score ≥ 2
40
•Non halogenated flame retardants used in plastic parts
that weigh more than 25 grams shall be on the publically
available Accepted Substance List for TCO Certified. This
means that the substance has been assessed by a licensed
profiler according to GreenScreen™ and been assigned a
benchmark score ≥ 2
41
Ecolabels
42
Thank You!
Backup
http://www.theic2.org/hazard-assessment
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