Substitution

Substitution may be voluntary, though not a common practice. Usually it happens when a company wants to get eco-label or implement the environmental management system ISO14001. Sometimes substitution is demanded by customers abroad with more stringent requirements in the field for hazardous substances. Substitution can also be mandatory, as required by EU legislation on chemicals (such as REACH with restrictions on certain uses or a complete ban on a number of substances). It is required when the manufacture, use or disposal poses an unacceptable risk to human health and environment.

Substitution can be done in different ways, depending on the use of hazardous substance. For example, one substance may be replaced with less dangerous, which has the same technical characteristics, but can also completely transform the product or its development process. One of the main challenges in this process is the substitution without increasing power consumption.

Why the hazardous substances should be substituted?

  • smaller hazardous waste management costs
  • simpler chemical inventory
  • simplified work safety requirements
  • on the market product can be positioned as consumer health and environmentally friendly
  • compliance with requirements of the law, which will come into force in the near future
  • substitution may enable new innovations and resource efficiency.

Which hazardous substances should be substituted?

Substitution is necessary for the hazardous substances in products and processes that create unacceptable risk to human health and environment, e.g. they are:

  • carcinogenic, mutagenic and toxic for reproduction;
  • environmentally persistent, bioaccumulative and toxic substances;
  • other substances which cause a similar effect, that is, a substance that possesses a serious threat to the environment or to humans if they are not treated properly, such as endocrine disruptors.

How to find out if there are  hazardous substances which should be substituted in the company?

Check if the chemicals that you import, produce or chemicals from which mixtures are created are not marked with any of the following danger symbols:

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Make sure that the employees in your company, that operate with certain chemicals, do not complain about health problems, such as frequent headaches, skin rashes, dizziness, nausea, eye irritation.

Make sure that the chemicals you use in the enterprise found in the safety data sheets Chapter 2, don’t have any of the following hazard statements:

Substitution is very important

Substitution should be considered

H300, 310, 311, 314, 330, 340, 350, 360, 361, 362, 370, 372, 400, 410, EUH032

H301, 302, 304, 312, 314, 315, 317, 318, 319, 331, 332, 334, 341, 351, 371, 373, 411, EUH029, EUH031

Information about the characteristics of the hazardous substances can be found in the following databases:

Information on chemicals: ECHA website Information about the chemical substances, which are produced or imported to European Union. Information about the hazardous charachteristics, classification and labeling and safe usage is available here.

Classification & Labelling Inventory: ECHA website

The classification and labeling information on manufacturers and importers notified and registered substances.
OECD eChemPortal Possible to search for announcements and data by entering the name and/or number of the substance.

How to prioritize substances which are to be substituted?

Criteria how to evaluate the substances which would be the most important to substitute:

  • (future) laws (the substance will be banned or restricted)
Substances already banned or restricted

Substances restricted under REACH;

Subsport list of restricted substances

Substances which will be restricted in the nearest future, the amount of evidence about their hazardness increases

Candidate List of Substances of Very High Concern (SVHC) for Authorisation

Substances requiring Authorization under REACH

ChemSec Sin List
  • occupational health and safety issues (staff reviews, the working environment risk assessment results);
  • considerable cost in reducing emissions into the environment, the emission thresholds;
  • customer pressure;
  • product and process changes that may take place simultaneously with the chemical susbtitution;
  • the company's policy for the eradication of dangerous substances.

What are the main steps in substitution process?

Substitution can be done in different ways, depending on the use of hazardous chemicals. However, in order to assess all possible aspects of substitution, it is recommended to apply the following steps:

  1. identify hazards and assess the risks - to ascertain whether the current substance use or process is dangerous. Or substances storage, use or destruction poses a major risk?
  2. explore alternatives;
  3. analyze the consequences that would result from the use of these alternatives;
  4. the comparison of different alternatives;
  5. assess the benefits of the substitution, to evaluate the effectiveness of the solution;
  6. make a decision about the substitution;
  7. carry out the substitution.

Only by fulfilling all these steps, you can assess the real effectiveness of substitution.