Following the inception of the Green Deal and the Chemicals Strategy, Europe has experienced a surge in technical terms that are supposed to act as guiding principles for the EU’s path towards a green, sustainable and overall rosy rainbowed future.
At a quick glance, these technical terms may sound like the epitome of political dryness, but scratch the surface a bit and you will see that the final definition of what such terms should actually mean could have huge implications.
For this reason, there is currently a lot of hustle and bustle behind the scenes, as stakeholders fight it out with different arguments to explain why their particular definition of these terms should be the one that everyone else follows.
A couple of weeks ago ChemSec discussed one such term – Essential Use. Now it’s time for another: Safe and Sustainable by Design. Or SSbD, as it is called by people in the know.
The SSbD concept aims to support a transition into an economy where chemicals, materials and their use in products are safe and sustainable throughout their life cycle, in other words production, use, and end-of-life. It may come as a surprise to some people, but this is not the case today.
“Safe and Sustainable by Design. Or SSbD, as it is called by people in the know”
And just like the case of Essential Use, the definition of what should be considered safe and sustainable could have huge implications for the chemical industry. So it’s not really surprising that Europe’s big and powerful chemical industry organization – CEFIC – is very active in this debate (and that its representatives literally say “SSbD” on average 67 times in every meeting they attend).
At the beginning of October, CEFIC presented its position on how the Safe and Sustainable by Design concept should be developed. In this paper the trade body highlights many important environmental parameters that need to be better addressed in the production of chemicals.
Following close scrutiny, however, there’s not really anything in there that explains how CEFIC and its members plan to shift the production of harmful chemicals to inherently safe chemicals (as in non-carcinogenic, non-hormone-disrupting and so forth), as this is a main goal of the Chemicals Strategy.
The Chemicals Strategy clearly states that “new chemicals and materials must be inherently safe and sustainable”. In other words:
1. Chemicals needs to be inherently safe – meaning that substances of concern can never be labelled “safe”
2. Chemicals should be produced in a sustainable way
CEFIC insists that chemicals should always be assessed in relation to their application or use. Here we strongly disagree, simply because it is impossible to predict the exact application and use of a product throughout its life cycle. This is even more true in a circular economy, where products and materials will be used, reused, and recycled.
In short, the only way to do proper risk management in a circular economy, both from a public health and economic perspective, is to exclude substances of concern altogether.
“The only way to do proper risk management in a circular economy is to exclude substances of concern altogether”
The CEFIC position paper has a strong focus on the production process. And while we appreciate the intention of making production of chemicals more sustainable – as the chemical industry is the production sector using the most energy in the world. Yes, you read that correctly: in the world – it is also necessary to give attention to the actual chemicals that are being produced and their inherent properties.
A sustainable production phase is obviously good and necessary, but it would not be enough to label a chemical safe and sustainable by design. That would simply be false marketing.
To avoid diluting the ambition embedded in the Safe and Sustainable by Design concept the criteria that are set need to be ambitious. We do not expect all of EU industry to be able to comply with these today, but we do expect that, in time, they will push EU industry to become more sustainable and produce inherently safe chemicals, and in doing so create invaluable business opportunities.
This is where we agree with CEFIC though. We both believe that Safe and Sustainable by Design is an opportunity for the European chemical industry to position itself as a world leader, creating business opportunities and growth. ChemSec is looking forward to continuing the dialogue with industry and with the Commission in order to find an ambitious definition of the concept that fulfills the vision of the Chemicals Strategy for Sustainability.