Chemical Footprint Project Survey: Chemical Inventory. January 24, 2019

Transcription

1 Chemical Footprint Project Survey: Chemical Inventory January 24,

2 Presenters Mark S. Rossi, PhD Executive Director Clean Production Action Sally Edwards, ScD Senior Research Associate Lowell Center for Sustainable Production 2

3 Zoom Webinar: Q&A and Chat 3

4 Chemical Footprint Project (CFP) Chemical Footprinting CFP Survey 4

5 Chemical Footprint Project (CFP) Survey Webinar Series January 17: Management Strategy January 24: Chemical Inventory January 31: Footprint Measurement February 7: Public Disclosure & Verification All webinars: 11:00am 12:30pm EST Note: calls may not go full 90 minutes depending on number of questions Webinars recorded & posted at: Guidance document at s/cfp_guidance_2018_ pdf 5

6 Today s Webinar (1/24) & EDF Webinar (1/30) Today: Chemical Inventory section of Guidance Document I1: RSL / MRSL I2: Implementation of I1 I3: Chemical information from suppliers I4: Full chemical ingredient information I5: Chemical ingredient data management I6: Conformance with inventory requirements Q&A: post your Qs to Zoom Q&A pane EDF webinar on CFP value proposition from investor & retailer perspective on 1/

7 Investors include Bank J Safra Sarasin BNP Paribas Investment Partners Boston Common Asset Management Calvert Research & Management Impax Asset Management Legal & General Investment Management Rhode Island Treasury The Sustainability Group of Loring, Wolcott & Coolidge Trillium Asset Management Retail & Health Care includes CVS Health, Staples, Target, & Walmart Dignity Health, Kaiser Permanente, & Vizient 7

8 Value of CFP Common language Gap analysis Quantitative metric to measure progress Alignment with leading demands from businesses, purchasers, & investors Systemic framework that supports compliance with standards & eco labels 8

9 March 31, 2019: Survey Closes 9

10 CFP Survey: 19 Questions = 100 points 10

11 Chemical Inventory CFP Survey: 20 Questions, 100 pts 11

12 Why focus on Chemical Inventory? 12

13 Key Terms: Chemical of High Concern (CoHC) carcinogen, mutagen, or reproductive toxicant (CMR) persistent, bioaccumulative and toxic substance (PBT) any other chemical for which there is scientific evidence of probable serious effects to human health or the environment that give rise to an equivalent level of concern a chemical whose breakdown products result in a CoHC that meets any of the above criteria Aligns with GHS criteria and GreenScreen Benchmark 1 criteria CFP CoHC 2018 List: updated and consistent with GreenScreen List Translator 1 chemicals tool guidance document 13

14 Key Terms Restricted Substances List (RSL): A list of chemicals restricted by a company in products, parts, or components from its suppliers. Manufacturing Restricted Substances List (MRSL): A list of chemicals banned from intentional use in facilities that process materials, components and/or products. Watch List: A list of chemicals of concern that a company does not currently prohibit, but is considering prohibiting in the future due to scientific evidence that a chemical may cause harm to human health or the environment. 14

15 CFP Survey CHEMICAL INVENTORY INDICATORS (30 points) Restricted Substances I1. What is the scope of chemicals you restrict? I2. How do you ensure requirements are up to date & implemented effectively? Data collection I3. What chemical information do you request from suppliers? I4. For what % of products do you collect full chemical ingredient info? Data Management & Conformance I5. What capabilities do you have for managing data? I6. How does your company ensure conformance with your chemicals requirements? 15

16 Chemical Inventory Absence of chemicals Presence of chemicals Data management/ conformance 16

17 I1: What is the scope of chemicals of concern you restrict in your products and manufacturing processes? (5 points) a. uses our RSL(s) to manage legal compliance within each market where it operates. Our RSL(s) include(s) only chemicals that are legally restricted in each market. b. uses a single RSL that reflects the strictest regulation in all of the countries or markets in which the brand operates and sells products (e.g., regulations that apply to manufacturing, marketing, and sales locations). c. uses a single RSL that reflects the strictest regulation in all locations worldwide. d. a single RSL that includes limits or bans of chemicals beyond what is covered in the most restrictive global regulations, or it includes chemicals that may not be subject to regulation but which the registrant has voluntarily chosen to limit or ban from its products. e. developed an MRSL. f. uses a list of chemicals identified for reduction beyond regulatory requirements. Our company may or may not require suppliers to eliminate these chemicals in products, parts, or components. g. uses none of the above. 17

18 I1: What is the scope of chemicals of concern you restrict in your products and manufacturing processes? (5 points) Restricted Substances List legal compliance only strictest standard across jurisdictions where company operates strictest standard worldwide voluntary limits beyond strictest regulations List of chemicals identified for reduction: may or may not be required Manufacturing RSL covers process chemistry 18

19 Absence of Chemicals: Scope of Restricted Substances List (RSL) Market specific legal restrictions Manufacturing RSL (MRSL) 2 Market 1 3 Most stringent legal restrictions Most stringent restrictions worldwide Voluntary restrictions 19

20 Example of I1c: AAFA 2018 RSL 20

21 Example of I1e: ZDHC MRSL 21

22 I2: What actions does your company take to ensure that its requirements (as selected in I1) are current and implemented effectively? (5 points) a. delineates compliance requirements in contracts with suppliers. b. trains suppliers about how to comply with our requirements. c. updates our RSL/MRSL/other requirements at minimum on an annual basis. d. engages external stakeholders such as non governmental organizations (NGOs), business customers, and consumers in the development of our RSL/MRSL/other requirements. e. publicly discloses our RSL/MRSL/other requirements. Provide web link. f. uses none of the above. 22

23 Example of I2a: HP Active Verification 23

24 Example of I2b: AFIRM Group Training Materials 24

25 Examples of I2e: publicly available RSLs 25

26 I3: What chemical information does your company, either directly or through a respected third party, collect from suppliers? (5 points) a. confirm RSL compliance b. confirm RSL compliance + info on Watch List (1 50 chemicals) c. confirm RSL compliance + info on Watch List (> 50 chemicals) d. request full chemical ingredient information. e. require full chemical ingredient information 26

27 I3: What chemical information does your company, either directly or through a respected third party, collect from suppliers? RSL (confirm absence of chemicals of concern) Watch List (partial ingredient information) Full chemical ingredient information: request or require 27

28 I4: For what percentage of products sold by your company do you collect full chemical ingredient information? (5 points) Intent This question seeks to understand the scope of your company s data collection on full chemical ingredient information. It is available only if, in question I3, you have checked response options d or e. I3.d. request full chemical ingredient information. I3.e. require full chemical ingredient information 28

29 I4: For what percentage of products sold by your company do you collect full chemical ingredient information? Answer all that apply. 14a. Formulated Products: For what percentage of formulated products sold by your company is full chemical ingredient information collected? percent 14b. Articles: For what percentage of articles sold by your company is full chemical ingredient information collected? percent 29

30 I4: For what percentage of products sold by your company do you collect full chemical ingredient information? Key definition: Full Chemical Ingredient Information with different requirements for formulated products and articles Formulated products: o 100% of the intentionally added substances by mass and o any likely impurities that are both a CoHC and present at 100 parts per million (ppm) or higher in the formulation. Articles at the level of homogeneous material (definition of article based on REACH): o 95% of the intentionally added substances by mass and o any likely impurities that are both a CoHC and present at 1000 ppm or higher. For definitions of formulated products and article see Appendix C: Glossary of Terms 30

31 I4: For what percentage of products sold by your company do you collect full chemical ingredient information? Key reporting & documentation requirements: Report using either: o mass percent of full chemical ingredient information collected by mass of products sold; or o sales percent of full chemical ingredient information collected by number of units or dollars of products sold. Other metrics can be used, such as product categories, but these units of analysis are less preferred as they require more details to understand how they are defined. Documentation: must clearly demonstrate how percent of products sold was calculated and how full chemical ingredient information is collected, including impurities 31

32 I4: For what percentage of products sold by your company do you collect full chemical ingredient information? Source: Source: File&recordOId= &fileOId=

33 I5: What capabilities does your company have for managing data on chemical ingredients in its products? (5 points) Check all that apply. Our company has: a. an internal named point(s) of contact or outside contractor who communicates with suppliers concerning our chemical information requirements. b. a data system (either internal or third party) to manage an inventory of chemicals in products. c. a data system (either internal or third party) that links our inventory of chemicals in products to chemical hazard information. d. a data system for generating reports on chemical/material ingredient declarations to customers. e. none of the above. 33

34 I5: What capabilities does your company have for managing data on chemical ingredients in its products? b. a data system to manage an inventory of chemicals in products d. a data system for generating reports on chemical/material ingredient declarations to customers Source: 34

35 I5: What capabilities does your company have for managing data on chemical ingredients in its products? c. a data system (either internal or third party) that links our inventory of chemicals in products to chemical hazard information. Third party examples include 35

36 I6:How does your company ensure conformance with your chemicals requirements? (5 points) Check all that apply. Our company: Formulated Products a. has an audit program to verify supplier submitted data. b. requires suppliers to test parts in third party approved labs and provide results. c. trains suppliers on how to comply with reporting requirements. d. routinely tests parts, components, or products to ensure conformance with reporting requirements. e. has none of the above. 36

37 I6 b. requires suppliers to test parts for compliance to REACH, RoHS, halogen free, etc. c. trains suppliers on how to comply with reporting requirements a. has an audit program 37

38 I6:How does your company ensure conformance with your chemicals requirements? c. trains suppliers on how to comply with reporting requirements d. routinely tests parts, components, or products to ensure conformance with reporting requirements. Source for quotes: 38

39 Timeline January 1, 2019 CFP Survey opened January February 2019 CFP webinar series March 31, 2019 Survey closes Q2/Q CFP Survey scores released to responders Q2/Q CFP 2019 Annual Report released 39

40 Questions? For follow up questions or clarifications contact: Cheri Peele, Senior Research Associate Clean Production Action For resources go to: 40