The product choice or substituition principle is stated in Miljöbalkens (The Environmental Code) part 2 section 6 §.
This principle means that one should as far as possible avoid the sale of or the use of such chemical products as may be considered to pose a risk to humans of the environment, if they can be replaced by products that are assumed to be less hazardous.
Phase-out – this is what you can do
Below we present a seven-step model that can be used as a basis for systematic work on selecting or replacing substances in such a way as to prevent and avoid risks. For more detailed information or advice on alternatives you can contact your trade organisation.
Think about why the chemical concerned should be replaced.
- Why is it a problem, and for whom?
- What is the function of the chemical that is to be replaced?
Spending extra time on this ground-laying work often pays off in the end. The important thing is to get to the bottom of the problem. The first answer is usually not the best. A good tip is to ask the question "why?" several times repeatedly. In this way one can arrive at new and unexpected solutions for how a chemical can be chosen. Do not forget to take into account the overall environmental effects when choosing or replacing chemicals.
Think about the function of each chemical, and that the choice of one chemical in preference to another can overall place a heavier load on the environment or health seen from an overall viewpoint.
The next step is to consider several different ways to fulfil the function or the need for the chemical that is to be replaced. Substitution not only concerns replacing one chemical by another, but also finding alternative solutions where chemicals are not necessarily involved. Good practice here can be to think "if not". At this stage it is important not to allow yourself to be limited by practical or financial arguments.
- How would you have solved the problem if in the first place you did not have access to that particular chemical?
- Can the product be replaced by another, or can changes in the manufacturing process or in product design mean that the substance is not needed at all?
Now you must assess the alternative that you have decided upon. Think about what can happen if the product concerned could be replaced by one of the alternatives. What for example is financially and practically possible? An alternative is not always obviously better. Take care therefore that you do not choose an alternative that is just as risk-prone as the original.
- Find out what the environmental and health hazard properties of the alternative products are.
- How can the alternative technology or process influence humans and the environment from a life cycle perspective?
- In what way can humans or the environment be exposed to the alternative product or waste products during manufacture, use, disposal as waste or in recycling?
- If there is a risk of harm to humans or the environment, how can these risks be limited?
- How does the alternative method or substance affect quality and function?
You have now assessed the different alternatives according to a number of factors. Compare these assessments with the risks for the product you wish to replace. Note that you should compare the risks, and not the environmental and health hazard properties of the substance. This is not always so easy, since there may often be less information about the alternative substance or method.
You may also have to compare the risks associated with an environmentally hazardous substance against the health risks of a particularly toxic substance. In such cases consider whether the health or environmental risks can be minimised. This may be a suitable point at which to set priorities against the company's internal aims and strategies. Examples of the type of questions that could be posed are:
- How easy is it to limit the risks associated with an alternative product or method, compared to those used now?
- Are there any products that humans or the environment will more probably be exposed to?
- Are there major differences between the different alternatives?
- If humans or the environment are expected to be exposed by an equal amount to the different alternatives – what harm can come to the environment or humans?
- Will any of the alternatives mean greater risks for humans or the environment that others?
Now you have assessed the risks posed by the possible alternatives. You have compared the most suitable with the chemical product or process that you are using or intend to use. At this stage it is time to decide which alternatives are interesting enough to proceed with further.
- Can the product or process be replaced by an alternative?
- What tests need to be performed?
- How long is the test period?
- What will the different methods cost?
If you decide to change your choice of chemicals, such a change usually requires careful planning so that the change takes place as smoothly as possible. You may need to inform customers and users why a substitution is being implemented and how they should deal with the new product. Carefully think through, therefore, what need to be done in connection with the new product or process replacing the previous one.
- Who is responsible for the various stages that need to be carried out, and what is the time schedule?
- When can the alternative process or product come on line and be sent out to the market?
- Do our customers need to be informed?
After you have replaced a substance, an evaluation may be advisable.
- Compare the result with the problem description you wrote in step one and see if the expectations have been met.
- Solve any problems that may remain.
- Compile an experiences document and create a procedure to be used as a basic source of assistance on other occasions when your company needs to phase out a chemical.
It is also important to be aware that a substitution may need to be re-evaluated if new facts come to light in respect of environmental and health risks, new regulations, or new and better alternatives. Continue therefore to work for continuous improvement of products and processes in respect of the risks associated with hazardous environmental and health chemicals or articles.