Avoiding substances of concern is the very first step when implementing a safe and sustainable by design process, and chemical safety is a key criterion for sustainable products, according to the European Environment Agency (EEA). This is most welcome validation of facts that we at ChemSec have known and talked about for a long time.
The EEA recently published a briefing describing the need for a new approach to chemicals, in order to design safe and sustainable products. The briefing has been produced to further emphasize the need for a wider and safer approach to the use of chemicals, which is also highlighted in the Chemicals Strategy for Sustainability.
Four key criteria contributing to the sustainability of products are identified in the briefing: chemical safety, resource use and circularity, greenhouse gas emissions, and impact on ecosystems. There is a clear focus on chemical safety to achieve sustainability, and several important findings are described.
Safety from known harm is not safe enough
The concept of “safety” might require some elaboration, since it is sometimes used in an alternative context, with different implications. Dr. Xenia Trier at EEA explains the meaning of the concept in the briefing:
“If you ask a citizen, most would understand ‘safe’ as being safe from diseases caused by chemicals, regardless of whether the chemicals are known or suspected to cause harm. It is this intuitive definition of safe that we mean.”
Non-toxic from the start – and through recycling loops
The briefing states that the very first action, when implementing a safe and sustainable by design process, is to avoid chemicals of concern. In other words: Ditch the hazardous stuff! As we at ChemSec have described in our report, The Missing Piece, using non-hazardous chemicals is the only way to achieve safe and sustainable products in the long run. This is increasingly true in a circular economy.
The importance of considering resource use and circularity is emphasized in the briefing. The end-of-life and continue-to-live options for products suitable for the circular economy must be considered. Recyclability is a central feature of any circular product design.
Dr. Trier explains:
“Circular is part of the ‘resource’ parameters, and hence part of the sustainable element. There will be design considerations, one of which could be to reduce complexity of the materials, and diversity of chemicals used – and the separability of the final product – which will help to repair, reuse and recycle the product.“
This further stresses the need for careful considerations regarding chemicals, since products intended to be circulated cannot contain problematic content, for example chemicals known or suspected to be hazardous. In fact, chemicals tend to accumulate when materials are recycled, leading to higher concentration of chemicals, with detrimental effects on human health.
The four criteria serve as a scorecard
The remaining key criteria, greenhouse gases emissions and impact on ecosystems, together with chemical safety and resource use and circularity, form the yardstick used to score the performance of safety and sustainability. According to the briefing, the minimum requirements for each of the criteria must be met, in order for a product to be considered safe and sustainable.
Dr. Trier elaborates:
“All four criteria need to have a minimum score. In addition, a maximum score is proposed to avoid skewing the final score. It is similar to the taxonomy approach, where one goal cannot cause substantial harm to another goal and still be considered sustainable.”
So, what’s next? At this moment, the Commission is developing the framework in order for the EU to have safe and sustainable by design criteria by 2022. This is being outlined by the Chemicals Strategy for Sustainability. The tentative first steps are being taken through a series of workshops, where relevant stakeholders will be heard, exploring different possible outcomes.
In the light of this process, the EEA briefing is a welcome supplement to the discussion, and the Commission would be wise to pay good attention to what the EEA has to say.