Gestaltungsoptionen für handlungsfähige Innovationssysteme
zur erfolgreichen Substitution gefährlicher Stoffe


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Andreas Ahrens

The SubChem Projekt


1. Description


Background and Main Issues:
Comprehensive toxicological and ecotoxicological testing of chemicals before placing on the market for the first time has become a legislative requirement and a widely accepted principle in dealing with chemicals today. In the EU Whitepaper on the "Strategy for a Future Chemicals Policy" (February 2001) the European Commission has proposed to adopt precaution and
substitution1
as further principles in managing chemicals. The Environmental Council has accepted this proposal in June 2001. Moreover, it was stated that innovation needs to be stimulated for the development of new chemicals and alternative technologies.

In Germany the substitution-principle for hazardous substances in the working environment is laid down in the national legislation as "duty of the employer to investigate" alternatives and "order to substitute" if necessary (§ 16 GefStoffV). In addition, the absence of hazardous substances has become a relevant market demand with regard to consumer products, and "Health and Environment" has become an important policy issue in general. However, only in a few cases so far enterprises have succeeded in making precaution and substitution an integrated principle in the development of products and the design of technical processes. The following factors contribute to this situation:
  • More than 90% of the market still consists of chemicals, which have been used since decades ("Existing substances"), which have not been adequately tested before being placed on the market and which have found a large number ( wide areas) of technical applications. The properties of these "existing substances" related to health and environment are not fully assessed. Given a certain technical need this makes a sustainable entrepreneurial choice for the "right substance" very difficult.

  • The European chemicals legislation requires significantly higher efforts for documentation and assessment before placing a "new chemical" on the market compared to the requirements regarding "existing chemicals". As a binding deadline at which all existing substances have to meet the same standard is lacking so far, the chemicals legislation sets economic signals, which at least impede substitution measures for existing substances by new substances.

  • The entrepreneurial choice among two or more alternatives as substitutes of a hazardous chemical should be taken from the viewpoint of sustainability, taking into account ecological, social and economic aspects. However, practical instruments for the evaluation of chemicals (or techniques) with regard to the "direction of the innovation" are hardly available so far.

  • It is obvious that the ‚absolutely safe substance' does not exist. However, there are always ‚safer' alternatives. Therefore, the substitution of hazardous substances requires a dynamic, self-sustaining innovation process in the sense of a continuous improvement of products and processes. The integration of this task into the internal organisation of enterprises with regard to purchase management, safety, health and environment, process technology and product development has only been achieved in very few enterprises so far.

    Since chemical substances have specific functions in processes and products, their hazardous properties are very often closely related to their respective technical functions. The substitution therefore often requires technical and/or organisational adaptations by various actors in the supply-chain. Hence substitution depends on a system of actors who are capable of supporting innovation.

Within the scope of the R+D Program „Integrated environmental protection - Framework conditions for innovation promoting sustainable economy (RIW)“ of the German Ministry for Education and Research (BMBF), the project „Options for facilitating innovation systems for successful substitution of hazardous substances aims at the identification of strategies and measures which would eliminate the obstacles to innovation as described above.

Three main questions shall be answered:
  1. Direction of innnovation
    Which assessment approaches and instruments provide the economic actors with more "confidence in direction" when replacing hazardous substances?
  2. Risk management
    Which conditions and which measures could support the integration of the substitution-task into the internal organisation of enterprises in the supply-chain ?
  3. Capacity for innovation
    Which framework conditions promote the formation of systems of actors which are capable to innovate? How can industry, trade, state authorities and other stakeholders interact in a successful way ?

Implementation
The project will be carried out in a co-operation of three research institutions in Hamburg, the University of Applied Sciences - Faculty of Engineering and Production, Oekopol - Institute for Environmental Strategies and Kooperationsstelle Hamburg. The work includes Co-operation with the German Chemicals Association (VCI) and some of its sector- associations (e.g. TEGEWA) as well as with associations of industrial users of chemicals (e.g. association of textile finishers [TVI] or association of metal industries [NORDMETALL]) and selected enterprises. The project duration is 2,5 years - spring 2001 till end of 2003.

Methods and Focus of Work
Based on the analysis of substition cases2 (success, failure or under discussion) a typology of successful innovation systems shall first be developed. From this, recommendations for the formation of management systems, procurement systems, participation of stakeholder groups and systems of actors, as well as policy styles and regulation patterns, shall be derived. The collection of information will be done by literature evaluations and interviews with the persons involved. In order to gain confidence in the direction of an innovation process, it is necessary as a second stage to evaluate both the original substances and their substitutes from the perspective of sustainability. Existing methods will be further developed within the scope of the research project.

The involved associations (transfer partners) and enterprises (practical partners) will participate in all stages of the project via workshops and information events.


german version

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2.Workshop Report 3


2.1 Outcome

We had specifically invited scientists and practical experts from the areas of evaluation of chemicals, innovative research, risk communication, chemical regulation and policy, worker protection, environmental protection and consumer protection, production and application of chemicals, and we had received almost only acceptances. The subject matter, evaluation of chemicals and substitution of hazardous chemicals, is currently the subject of increased interest, not least of all also due to the fact that publication of the EU White Paper on Chemicals Policy has revived the debate. The initial findings of the workshop are described here in brief.

2.1.1 Change of paradigm in chemicals policy

A purely scientific, (eco)toxicological approach to the analysis and evaluation of substance-related risks, a risk management based primarily on these results and also the concomitant risk communication must be considered to have failed to date. There are many reasons for this. They range from the questionable necessity, responsibility and also scientific/technical and/or financial feasibility of animal experiment programmes to the fact that risks are also 'created communicatively' and are perceived and evaluated individually depending on individual situations
4. Scientific findings are only one part of this, among many. Further development or creation of instruments to encourage independent and market-driven substitution processes is one of our vital research objectives. The approach used to date to enact national regulations governing individual substances is not efficient enough seeing that there are approximately 30,000 existing substances on the market. Also the procedure practised in Germany to implement the "order to substitute" contained in § 16 of the Ordinance on Hazardous Substances (GefStoffV) by making official recommendations for substitutions into Technical Regulations for Hazardous Substances (TRGS) is extremely slow. In a period of 10 years less than 20 substances and/or substance applications have been processed.

A change of paradigm in chemicals policy is due. In the EU White Paper "Strategy for a Future Chemicals Policy" (February 2001), the EU Commission proposed that precaution and substitution should be the fundamental principles for dealing with chemicals in future. The Environmental Council confirmed this proposal in June 2001 and also stated that the efforts for innovations by all parties to develop new chemicals and alternative technologies must be accelerated and stepped up. At the same time the Commission and the Council are endeavouring to introduce extensive market restrictions for particularly dangerous substances. The research project thus takes place against the background of unexpectedly topical dynamics.

2.1.2 Support for users of chemicals

An important approach to promote the substitution of hazardous substances is to provide support for users in three respects: firstly, they must become aware of their own 'market power' and use this - most effectively in co-operating with the trading industry - to 'educate' manufacturers. Secondly, they must insist on having as complete information as possible
5 and better communicate their requirements (not only those that are scientifically founded) for materials as well as for material and functional qualities. Thirdly, they must be put into a position to choose between as large a range of substance and 'functional' alternatives as possible for their intended purpose. The question remains as to who should actually ensure the required range of alternatives: national research policy, chemical manufacturers, those deciding on the formulations or the industry?

2.1.3 Application of the principle of precaution and 'inherently safer substances' model

Evaluation methods and decision-making instruments, which facilitate a sure direction in developing and selecting alternatives, are important factors for those involved. This applies both to the (eco)toxicological evaluation of substances and to the assessment of other effects in relation to sustainability, such as the use of resources and the emission of gases having an effect on the climate. In the past substitutions have frequently been carried out, which have also proven to be problematic after a relatively brief period, such as e.g. the substitution of toxic and combustible cooling agents and propellants by CFCs, the substitution of asbestos by artificial mineral fibres or the substitution of organic tin compounds by other biocides, which are scarcely less dangerous. Absolutely safe substances do not exist and knowledge of possible effects of substances will also never be complete. Therefore, it is important to clarify: what do we have to know and what can we know? And how can we responsibly utilise any remaining gaps in our knowledge? Lack of knowledge is frequently stated as a strategic factor against innovations, both against existing and new chemicals and also against possible substitutes. Innovations are always linked to risks, and it is the level of risk that is important. Uncertainty or lack of will by the actors involved can result in future-oriented innovation possibilities not being explored. It can also mean that required and technically feasible substitutions are not implemented with the justification that not enough is known as yet about the risks involved in the alternatives. This means that excessive claims regarding knowledge about the "safety" of alternatives can also lead to undesired effects, i.e. the continuation of practices that are known to be hazardous.

A decisive factor to make operational the precaution principle that is now clearly demanded is, therefore, how we use this lack of knowledge. It is thus important not just to note that there is a lack of knowledge, but to develop methods to assess the extent of this lack of knowledge and also to take action to keep the level and the problematic consequences of this lack of knowledge as small as possible. This, in turn, can be done in two ways: on the one hand, by more research and knowledge and, on the other hand, by taking more care when intervening in complex and dynamic systems. The latter option has been pursued much too little to date. An interesting approach here is 'short-range chemistry' (Scheringer) as an attempt to make operational the model of "inherent safeness of substances" .

2.1.4 Capacity for innovation

Successful substitution essentially depends on whether the various actors involved combine well in an innovation system, whether e.g. printers, printing ink manufacturers, printing machine manufacturers, cleaning agent suppliers and the authorities can successfully communicate with each other and are able to work synchronously on sustainability-oriented innovations in order to reach a joint objective. Important factors for successful, innovative systems are thus the type and degree of networking, the 'climate for innovation', the ability to communicate, the transparency of decision-making processes, sensitivity and openness for external impulses as well as flexibility and the ability to organise oneself. Innovations for the substitution of hazardous chemicals also appear to progress especially successfully, if individual highly motivated actors take on a leading role and state authorities support the distribution of lower-risk products or technologies by means of economic or regulatory instruments.

Innovations are thus encouraged by various impulses. Important impetuses for innovations for the substitution of hazardous substances can be new developments in the areas of substances and technologies (science and technology push), such as e.g. biodegradable plastics. A new demand situation on the markets (demand pull), which is frequently initiated by a public debate concerning health risks, such as e.g. formaldehyde in construction materials, may also serve as a decisive impetus. Lastly, government regulations may also initiate innovations, such as e.g. the regulations governing the recycling of chlorinated solvents, used vehicles and electronic equipment. 2.1.5 Safer products and processes as a competitive factor

Intensification of competition, saturated, highly fragmented and dynamic buyers' markets, shorter innovation cycles, but also dependence of a company's value (not just at the stock exchange) on the company's public image have greatly increased companies' sensitivities (and also vulnerability) towards external impulses. If several companies are able to offer the same quality for the same price on the globalised markets, the importance of so-called 'soft' quality factors increases (e.g. sustainability factors of intra-generational and intergenerational integrity, industrial safety and environmental protection). Target conflicts between hard and soft factors are thus not excluded, but today we can assume that such target conflicts also determine everyday practices within companies and that they are no longer borne out solely between companies and their 'environment'. It is possible that companies, under such circumstances, develop a more acute "inherent interest" in the substitution of hazardous substances.

However, more knowledge about the environmental and health-related properties of the manufactured substances also means a considerable rise in costs for substance evaluation. However, as transparency and transfer of the manufacturer's knowledge to the market are required at the same time, appropriate mechanisms need to be found to distribute the costs equitably.

And lastly, both companies and also society in general have a justified interest that neither government regulations nor making the precaution principle operational impede the capacity for innovation (and therefore also capabilities for substitution of hazardous substances) of companies and societies excessively.

2.1.6 Network

In the final analysis the kick-off event contributed to the further development and focussing of our research hypotheses. The workshop was also especially important for the formation of networks to accompany research. Within the scope of the event a project advisory body was established, in which all relevant groups of actors are represented. It is the role of the project advisory body to monitor quality and practicability, to provide impulses for the project and to ensure transfer of the research results to the relevant areas of activity of its members (cf. annexe).





2.2 What does the future hold?

We shall examine and continue to develop the outlined hypotheses in a first stage on the basis of 10 cases 6. We hope that by the end of 2002 we will be able to gain an insight into the framework conditions of successful innovation with regard to the manufacture and usage of non-dangerous chemicals from each case using a systematic description. The case analyses, which will mainly be based on interviews, scientific literature and general market data, are particularly aimed at the following aspects of the evaluation:


  • indicators for successful innovation under environmental and health aspects as well as under economic and social aspects;

  • characterisation of the market situation, such as competitive intensity, role of imports and exports, quantity and company size of manufacturers and users, market saturation as well as manufacturer-dominated or demand-dominated markets;

  • availability of substance information and evaluation instruments suitable for practical use;

  • type of innovation impulse and significance of environmental and health-related arguments and/or requirements;

  • progress of discussions in companies and in the industry, the role of certain actors;

  • communication of the individual cases to customers, suppliers, in the industry.


On the basis of the findings from the case samples, in the second stage we shall examine in depth the effects of certain systems of actors and their options to exert influence. These include for example:


  • organisation of industry initiatives with binding and operational agreements between the different actors;

  • regulatory approaches, which especially bring about creativity, competence and the acceptance of responsibility of the market participants;

  • easily manageable instruments for substance evaluation offering 'directional safety';

  • successful organisation of substitution search and evaluation on a company level.


By autumn 2003 we expect to be able to gain vital impulses and information concerning the stated matters from workshops accompanying the above described processes, which will be carried out together with our co-operation partners.





SubChem case studies - product and process innovation



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