Does your product contain EDCs?

Aim: To identify EDCs in products and add discovered EDCs to RSL list.

A good base for EDC identification is to start with the 32 EDCs compiled in a scientifically based study by ChemSec, also available as a comprehensive list.

If there is need to increase the identification scope, the current status of identified EDCs, as well as EDCs being evaluated within the EU, can be found here.

Use the following sources to find out whether your product or supply chain contain EDCs:

1. Full material disclosure (FMD)
   • Request FMD from suppliers
2. Compositional analysis data (chemical analysis)
   • Request compositional analysis data from suppliers
3. Obtain supplier declaration or product chemical content information from suppliers

As a last resort, you can perform chemical analysis. Since chemical tests are expensive, you might want to do some prework in investigating what kind of EDCs you can expect to find in a specific product or material. Knowing the use and function of the EDCs can help you here. This is also described in the next step.

Is the EDC necessary?

Aim: Determine the function of the EDC and if it’s essential for the product.

1. Scope: Understand the function of the EDC in the relevant product and process.
2. Criteria: Decide which physical and functional properties the replacement must have in order to match all functions within the scope.

Use the following questions to determine function:

• What properties and function does the substance provide?
• In what materials do we need these properties?
• In what products do we have such materials?
• Who supplies them?
• Is the function necessary for the product or process?
• Is it a contaminant or by-product?

Is there an alternative that can replace the EDCs?

Aim: Find an alternative that can replace the EDC.

1. Assessment: Investigate which replacements have viable properties according to the criteria. Include external variables such as availability, price, or quality to decide which would be the most suitable replacement.
2. Look for an alternative technical solution or drop-in chemical. Can another material, where this chemical is not necessary, be used?

Use the following sources to find alternative chemical/material/process:

• ChemSec Marketplace (If you can’t find an alternative, you can post a request)
• TCO Certified Accepted Substance List
• ChemFORWARD
• GreenScreen Certified
• US EPA Safer Chemical Ingredients List
• Ask your network and suppliers

Is the alternative safer?

Aim: Find an alternative that can replace the EDC.

The initial step is to decide upon criteria for hazard properties to determine if the alternative is safer than the chemical you want to substitute.

There is no universal approach to determine safer. Different companies and organisations handle this in different ways in order to avoid regrettable substitution. The most common approaches to determine if an alternative is safer are:

• Hazard lists
• Available assessments and methods
• Own or existing hazard criteria
• A combination of approaches

Criteria for substances of very high concern:

• Chemicals with CMR properties
• Chemicals with EDC properties
• Chemicals with PBT/vPvB properties
• Chemicals with PMT properties
• Chemicals on the SIN List
• Respiratory sensitizers

Resource to determine safety:

• OECD Substitution and Alternatives Assessment Tool Selector
• OECD QSAR toolbox
• SIN List
• Scivera
• SINimilarity
• Pharos
• GreenScreen Certified
• ToxServices’ Full Material Disclosure (ToxFMD) Screened Chemistry
• ChemFORWARD

After having assured that the alternative is safer, to be viable, you also need to consider:

• Performance of the alternative
• Price of the alternative
• Availability of the alternative
• Environmental aspects such as emissions, energy, water use, and waste

Develop safer alternative

Aim: Find an alternative that can replace the EDC.

If no suitable alternative can be identified, there are some other strategies that can be pursued:

• Change process/techniques
• Change product design
• Change material
• Change chemical

However, if no safer alternative exists and no other approach is viable, the remaining option is to develop a safer alternative. The process is different in different organisations, but the main steps can be:

• Set up innovation team or find innovation partner (EIC Accelerator)
• Work with suppliers to introduce safer materials and solutions
• Use R&D department to develop safer alternatives
• Test hazard properties of potential alternative according to criteria
• Remember to minimize the exposure to occupational hazards for the workforce by implementing the hierarchy of controls

Initate phase out

Aim: To remove and replace hazardous EDCs.

At this stage, you know:

1. What chemical to replace/remove
2. The function of the chemical
3. There is a safer alternative

To remove the EDCs, consider the following aspects:

1. Assure product quality and performance through pilot testing
2. Set timeline for phase out
3. Perform phase-out

EDCs phased out

Great job!

You have now completed the flow chart and started your journey towards safer products.