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Gathering Chemical Information and Advancing Safer Chemistry in Complex Supply Chains Case Studies of Nike, S.C. Johnson, and Hewlett-Packard

M o v i n g

B u s i n e s s

T o w a r d

S a f e r

September 2009

A l t e r n a t i v e s


Acknowledgements The Lowell Center for Sustainable Production would like to acknowledge Monica Becker of Monica Becker & Associates Sustainability Consultants as the primary author of this report and the case studies referenced within. A special thanks is due to the committed companies that were willing to provide their time and insights for the case studies. In particular, we would like to thank John Frazier from Nike; Daniel Lawson from S.C. Johnson and David Long from Environmental Sustainability Solutions; and Barbara Hanley of the Hewlett-Packard Corporation.

2 Green Chemistry and Commerce Council • greenchemistryandcommerce.org


Gathering Chemical Information & Advancing Safer Chemistry in Complex Supply Chains Case Studies of Nike, S.C. Johnson and Hewlett-Packard

Introduction

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onsumer product companies need chemical information from their supply chains for many reasons, including the design of products that are safe for human health and the environment, regulatory compliance, participation in green certification programs, disclosure of chemical ingredients in products to retailers and customers, and preparation of Material Safety Data Sheets (MSDS). Companies with large, complex, global supply chains face many challenges in getting this information. The Green Chemistry in Commerce Council (GC3), a project of the Lowell Center for Sustainable Production, at the University of Massachusetts Lowell, commissioned three case studies of leading firms with complex supply chains to explore and share experiences on how companies gather chemical information from their supply chains and how they use this information to develop safer products. The three companies are Nike, S.C. Johnson (SCJ) and Hewlett-Packard (HP) (See Table 1). The case studies conducted for this project examined a number of questions: 1. Why is the company seeking chemical information from their supply chain? 2. What types of chemical information is the company seeking? 3. How is the company gathering chemical information from its supply chain? What system is it using? 4. What systems are companies using to manage chemicals in products? 5. What systems are companies using to create safer products using chemical information? 6. What challenges have existed and what has worked well to gather chemical information, manage chemicals and design safer products?

All three firms studied are sizable, consumer product companies with large and complex supply chains. They are diverse with regard to the types of products that they manufacture and the types of raw materials that they procure from their supply chain. The reader should keep this in mind when reading the cases and lessons reported in this document. Information gathered for the cases came from interviews with personnel at each firm, internal documents provided by the firms, and publicly available information. The companies were given the opportunity to review and comment on case study drafts. This summary report is designed to synthesize the lessons learned and best practices that were distilled from the case studies.

Table 1. Overview of Supply Chain Case Studies Company Name

Products

Title of Case Study

Nike Corporation

Apparel, footwear, and athletic equipment

“Considered Chemistry at Nike: Creating Safer Products through the Evaluation and Restriction of Hazardous Chemicals”

S.C. Johnson

Home cleaning and storage, air care, and pest control products

“S.C. Johnson is Transforming its Supply Chain to Create Products that are Better for the Environment”

HewlettPackard

Information technology products

“Managing Chemicals of Concern and Designing Safer Products at HewlettPackard”

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Background Why are Consumer Product Companies Seeking Chemical Information from their Supply Chains? growing number of market and regulatory forces are driving manufacturers to eliminate or reduce the use of toxic chemicals in products and design products that are safer for human health and the environment. These forces include green consumerism, green certification programs, consumer demand for greater transparency of chemical ingredients in a product, and regulatory programs such as California’s Proposition 651 and the European Union’s REACH and RoHS2 programs.3 In response to these drivers, many manufacturers are developing a variety of new corporate programs or systems to “green” their products and operations by reducing or eliminating the use of toxic chemicals or disclosing chemical ingredients to their customers. These programs include the evaluation and scoring of environmental, health and safety of chemicals prior to selection for use or to eliminate or substitute toxic components with safer alternatives; promoting the use of safer chemicals; and restricting the use of certain chemicals in products. While diverse in their approaches to promoting safer chemistry, these initiatives share at least one common element: They require chemical information. We use the term chemical information, to cover a range of information, including the following: • the identity of a single chemical or chemical ingredients in a mixture, material or component • the amount or concentration of chemicals, including additives, in a mixture, material or component • the presence of chemical reaction by-products or breakdown products • the hazard and toxicological profiles of chemicals or mixtures • the potential for human or environmental exposure to the chemical from handling, transport and use of chemicals, materials or components

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Chemical information is also needed for other important functions including the preparation of MSDSs and regulatory compliance with programs such as the EU’s REACH4 and RoHS Directives. Historically, the transfer of chemical information from suppliers of individual chemicals and mixtures to consumer product manufacturers has been limited to performance characteristics, safe handling and transport, and basic hazard and toxicological information delivered in product specification sheets and Material Safety Data Sheets (MSDSs). There is a growing consensus, however, that most MSDSs are inadequate for companies trying to evalu-

ate materials and design safer products. MSDSs typically lack sufficient chemical ingredient information and toxicological data to support design for environment efforts. They were primarily designed to provide information on mostly acute occupational health hazards, not those throughout an entire product lifecycle. Barriers and Challenges to the Flow of Information “Down the Supply Chain” from Supplier to Customer A major challenge for many product companies is getting the chemical information that they need to fuel their green product design programs. Over the years, supply chains have become deeper, branched, and global. For example at Nike, all manufacturing is done under contract by almost 640 factories in 52 countries, each supplied by between five to ten vendors. Maintaining visibility and control over the ingredients in the materials or components procured from the supply chain has become a major challenge for many larger companies and comes only at great expense. Original Equipment Manufacturers, or OEMs, typically have direct relationships with their Tier I suppliers, sometimes with Tier II, but rarely with suppliers deeper into a supply chain. Tier I suppliers may be willing to provide the information that they have but often have trouble getting information from their suppliers, and so on down the chain. Barriers and challenges to the flow of chemical information “down” the supply chain, from supplier to customer have been described by Denison and the OECD and include the following:5 • Suppliers may not have the information requested by customers because they source chemicals or materials from their suppliers who are unwilling or unable to provide information. Suppliers may be brokers, distributors, or other intermediaries who lack information. Chemicals are often sold through intermediaries who often do not have the information that their customers are seeking or have little incentive to share the information that they do have. • Suppliers may not have the capability, infrastructure or resources to develop the information. Small suppliers in particular may lack in-house expertise, technology and resources to collect and disseminate chemical information. They may also be unable to pass on the costs of information collection and transmittal to their customers, or may be overwhelmed by information requests from multiple customers.

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• Suppliers may not want to disclose chemical information because they fear losing sales or customers. Some suppliers may be concerned that if they disclose compositional information on their products to their customers, their customers will use that information to find alternate suppliers. • Suppliers may not want to disclose proprietary information (confidential business information (CBI)). Suppliers may be reluctant to divulge chemical information that they deem critical to their competitive advantage. This can be a particular problem with certain chemical categories such as additives to polymers, and fragrances. • Suppliers may not want to disclose information out of fear of potential liability. Suppliers may be afraid of being assigned responsibility for problems that may arise from their products. Companies may also fear being out of compliance with existing laws and may not want to provide information that could reveal compliance problems. • Customers may not clearly articulate their need for information or provide incentives for its delivery. Companies seeking information from their suppliers may not be providing a good explanation for why the information is needed, a clear description of the type of information needed, or the benefits created by having complete and reliable information from their suppliers. In addition, customers may need to provide incentives to suppliers to encourage them to be more forthcoming. • Suppliers may not feel compelled to provide chemical information to their customers if existing laws do not require disclosure of information on chemical uses, hazards or potential exposures.

• Differences in culture, language, values, and legal requirements in global supply chains may act as barriers to the transfer of chemical information between suppliers and customers. Flow of Chemical Information “Up the Supply Chain” From Customer to Supplier The discussion so far has focused on the flow of chemical information “down the supply chain,” from supplier to customer. It is worth noting that there are many important benefits to the flow of chemical information “upstream” from customer to supplier. At the annual Innovator’s Roundtable of the Green Chemistry in Commerce Council, in May of 2009, Janet Mostowy, Vice President, Product Safety and Regulatory Affairs & Management Systems at Bayer Material Sciences noted the importance for chemical manufacturers to obtain information from their customers on how their chemicals are being used. This information can enable chemical producers to provide information to customers on the safe use of its products. She stressed the importance of the identification of chemical uses and applications along all links in the supply chain.6 Fostering this type of communication can be a challenge. As noted by Mostowy, Bayer has access only to its direct customers, who may be chemical distributors, but not always to the companies that incorporate their chemicals into products. Other barriers to information sharing from customer to supplier exist. A supplier may be concerned that they may lose customers if they ask for information on how their chemicals are used. A customer may have a use for the chemical that s/he does not want the supplier to know about, either because s/he wants to protect a novel application or conceal improper handling or use of the chemical.

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Summary of Safer Chemistry and Product Design Programs and Chemical Information Needs Described in the Case Studies

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o provide context for the discussion of lessons learned, this section presents a brief overview of the safer chemistry and product design programs described in the case studies and the types of chemical information that the companies are seeking to support these programs. Nike Green Chemistry and Safer Product Design Programs Nike’s Considered Index sustainable product design tool is used to predict the environmental footprint of a product prior to commercialization. This system examines solvent use, waste, materials and innovation for footwear; waste, materials, garment treatments and innovation for apparel. Products are assigned a “Considered” score using a set of metrics. The metrics are based on over a decade of research about materials, solid waste, innovations, textile treatments and solvent use. Nike’s extensive RSL program consists of nine distinct lists of chemicals, including lists specifically for materials that are products of nanotechnology, packaging and toys, and a testing and data management system designed to ensure supplier compliancy. Nike’s RSL includes chemicals or materials that are restricted by legislation and additional “Chemicals of Concern” that Nike has declared undesirable in products. Nike’s Considered Chemistry chemical evaluation system is used to evaluate chemicals in products for possible addition to Nike’s restricted substances list and for conducting focused efforts to develop environmentally preferred materials (EPM) for product platforms (e.g., rubber outsoles, synthetic leather). The system employs a risk-based approach to evaluate the chemical ingredients of materials, considering chemical hazard and potential consumer, worker and environmental exposure to the chemical (risk = hazard x exposure). The system requires chemical formulation information from suppliers. Nike obtains hazard data either from a toxicologist or publicly available databases and conducts hazard and risk analysis. Types of chemical information sought from the supply chain include: • Full chemical ingredient information on materials from suppliers for environmentally preferred materials (EPM) development. • Chemical ingredients in materials that are used at contract facilities to manufacture products. This includes materials such as adhesives and solvents used in manufacturing operations.

• Testing for restricted substances and chemicals of concern in supplied materials, components, and products to verify compliance with Nike’s RSL guidance. The data from these tests are also used to generate Supplier Scorecards for evaluation and comparison of alternative suppliers and to analyze materials, and specific colors of materials, to determine which tend to contain restricted chemicals or chemicals of concern. S.C. Johnson Green Chemistry and Safer Product Design Programs The Greenlist™ process was developed by S.C. Johnson for rating raw materials based on their impact on the environment and human health. Greenlist™ scores are reported alongside performance and cost information in the company’s chemical formulary so chemists choose materials in consideration of their environmental and health properties. Using the scores, materials can be easily compared. Greenlist™ also provides metrics for tracking S.C. Johnson’s corporatewide progress toward greening its portfolio of products. The company has created incentives to encourage the selection of safer materials and discourage less safe materials. Greenlist™ currently has unique rating criteria for 19 material categories. Additionally, the website www.whatsinsidescjohnson.com, is S.C. Johnson’s innovative new ingredient communication program that includes a dedicated website designed to provide chemical ingredient and other helpful information to consumers. Types of chemical information sought from the supply chain, include: • Toxicological and other hazard data for individual chemicals or more complex materials to develop Greenlist™ scores. Generally, suppliers provide what are called Toxicology Summaries with all the information needed to evaluate a chemical using the Greenlist™ system. Some suppliers, fragrance suppliers in particular, regard their products as highly proprietary. In these cases, the supplier determines the Greenlist™ score and provides only the score to S.C. Johnson. The company audits these submittals. • Full chemical ingredient information for www.whats insidescjohnson.com is sought from suppliers.

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Hewlett-Packard Green Chemistry and Safer Product Design Programs Hewlett-Packard’s General Specification for the Environment (GSE) includes a list of restricted materials, requirements for packaging, and requirements for products subject to the European Union’s RoHS Directive. These specifications are for all HP brand products including subassemblies, part, materials, components, batteries and packaging that become part of HP brand products. The GSE is included in supplier contracts as part of the standard terms and conditions. HP’s Design for Environment (DfE) program seeks to reduce the environmental impact of its products. The three major elements of the DfE program are energy efficiency, materials innovation, and design for recycling. Materials innovation is focused on reducing materials use and using materials with less environmental impact and more value at end of life. The company has also participated in the Electronic Product Environmental Assessment Tool (EPEAT) program, designed to help institutional purchasers compare computers, notebooks and monitors based on environmental attributes. EPEAT is a green certification program managed and governed by a not-for-profit organization that provides a clear set of performance criteria to encourage manufacturers to design environmentally sound products. Hewlett-Packard participated in the development of EPEAT and many of Hewlett-Packard’s products have been scored using EPEAT. Types of chemical information sought from the supply chain, include: • Information needed to confirm compliance with RoHS requirements. Suppliers must sign a letter of RoHS compliance and submit it to HP. HP requires its suppliers to provide chemical data, material or component testing upon request. • Information on Substances of Very High Concern (SVHC), under Article 33 of the EU’s REACH Directive. HP must provide information to consumers on the presence of Substances of Very High Concern (SVHC) in

specific products. HP’s suppliers are required to provide information on the weight in grams of substances listed on the current Annex XIV candidate list of chemicals under REACH. Suppliers are given the option to indicate where the substances are used in the product. These data are consolidated by Hewlett-Packard and used to prepare reports required under Article 33 of REACH.7 • Tracking of additional chemicals of concern in products. In addition to the Annex XIV chemicals, HP requests information from its suppliers on approximately 240 additional chemicals. This voluntary reporting list was narrowed from the 67/548/EEC (as amended) Annex 1, as well as other chemical regulatory lists that contain substances meeting the SVHC criteria, such as the Stockholm Convention (POP list) and the Rotterdam Convention (PIC list) list. It includes carcinogens; mutagens; reproductive toxins (CMRs); persistent, bioaccumulative and toxic chemicals (PBTs); and endocrine disruptors that HP determined as possibly used in electronics products. These data provide HP with information on where and how these chemicals are used in their supply chain, should they become restricted in the future. • Information on chemicals of emerging concern is gathered from suppliers under a provision of HP’s GSE. This provision was written to allow Hewlett-Packard to collect information on a chemical’s health or environmental hazards, requirements for safe use, and packaging or labeling issues. As these highlights illustrate, each company has developed a unique mix of programs and techniques for designing safer products and gathering the chemical data required for these efforts. The types of programs and chemical information needed are further summarized and categorized in Table 2.

Gathering Chemical Information & Advancing Safer Chemistry in Complex Supply Chain 7


Table 2. Summary of Programs for Designing Safer Products and Chemical Information Required Type of Chemical Information Requested from Suppliers

Program Type

Company

Program

I. Evaluation and scoring of environmental, health and safety of chemicals prior to selection for use

S.C. Johnson

Greenlist™

Toxicological & other hazard data for chemicals and materials to generate a Greenlist™ score

II. Evaluation and scoring of chemicals in existing products to eliminate or substitute toxic components

Nike

Considered Chemistry Program—for development of EPM

Full chemical ingredient information

III. Promoting the use of specific chemicals that are highly rated for environmental safety and health

S.C. Johnson

Greenlist™

Toxicological & other hazard data for chemicals and materials to generate a Greenlist™ score

IV. Restricting the use of certain chemicals in products (either banning the chemical or limiting its concentration)

HP

General Specification for the Environment (GSE)

Signed letter of RoHS compliance. Chemical data, material or component testing upon request

Nike

Restricted Substances List (RSL)

Analytical test results for supplied materials, components and products to verify compliance

S.C. Johnson

Restricted Use Materials (RUM) under Greenlist™

Toxicological & other hazard data to generate a Greenlist™ score

V. Reporting of SVHC chemicals under Article 33 of the EU’s REACH Directive

HP

REACH compliance

Weight in grams and location in product (optional) of Annex XIV chemicals

VI. Tracking of chemicals of concern in products to prepare for future regulatory requirements

HP

Extension of REACH compliance activities

Weight in grams and location in product (optional) of 240 chemicals of concern

VII. Programs to voluntarily disclose chemical ingredients in products to customers

S.C. Johnson

www.whatsinsidesc johnson.com

Full chemical ingredient information

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Lessons Learned: Gathering Chemical Information

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n this section, we present a description of the challenges and enabling factors reported by the case study companies for obtaining chemical information from their supply chains.

are unwilling to test for these chemicals. The chemicals may have been introduced by Tier II or other suppliers back further in the supply chain and Tier I suppliers are unaware of their presence.

Challenges All three companies reported that getting chemical information from supply chains can be difficult or impossible in some cases, time consuming, and costly. A number of specific challenges were cited by case study firms.

• Chemical ingredient information provided may be incorrect. Validating information provided by suppliers is difficult and costly and may require chemical testing of materials or products.

• Suppliers are sometimes unwilling to provide chemical ingredient information. Although the companies studied are quite large, they may still represent a relatively small share of a supplier’s sales and therefore may have little leverage. Nike, for example, described an instance when the company tried to get chemical information from a supplier that supplied dyes to a facility that dyed textiles for Nike products. The supplier, a formulator of dyes, was unwilling to provide information on dye ingredients. Nike sales accounted for approximately 5% of the supplier’s total sales.

• In some cases, data requirements under regulatory programs or green certification programs are unclear or confusing making it difficult for customers to provide clear instructions to their suppliers for information gathering and reporting.

Case study firms cited concerns over confidential business information as the reason for some supplier’s unwillingness to provide chemical information.

• Clear communication with suppliers. This has taken several forms, as described in the points below.

• Some suppliers lack sophistication and do not have adequate data collection and management systems to collect and provide chemical data to their customers. • Tier I companies are not always able to get chemical ingredient information from their suppliers. This is particularly true when the Tier I supplier represents a small fraction of sales for the Tier II or higher suppliers. • Different languages and cultures can make it difficult for customers to successfully convey details on the type of information needed and to get a commitment from suppliers to provide the information. • Getting information on dyes, fragrances, preservatives, contaminants and unintended by-products presents a particular challenge. SC Johnson reported that in the case of dyes and fragrances, their suppliers often view these chemicals as proprietary and some are unwilling to disclose them. In some cases, suppliers do not want to disclose the presence of preservatives, contaminants and by-products in the materials that they sell or they

Enabling Factors All three companies also reported that certain programs and practices that they have implemented have facilitated their efforts in collecting chemical information. Specific enabling factors include the following:

– Provision of detailed written guidance on information sought. In particular, HP and Nike have developed detailed guidance documents for their RSL programs. These documents can be accessed on-line.8 – Training of suppliers on chemi-cal data reporting requirements. In addition to training its Tier I suppliers, HP has reached out directly to Tier II suppliers to clarify data requirements. SCJ provides training to suppliers on their Greenlist™ system for rating raw materials according to environmental and human health impact and on toxicological data needed by SCJ to evaluate suppliers’ materials. In addition, both Nike and HP provide detailed guidance documents to suppliers on their RSL requirements. • Providing an easy-to-use system for suppliers to submit chemical data. HP’s web-based portal for chemical data entry has facilitated data collection. This system was developed internally by HP and uses the companies SAP/Environmental Health and Safety modules to process the data.

Gathering Chemical Information & Advancing Safer Chemistry in Complex Supply Chain 9


• Finding innovative ways to overcome barriers associated with confidential business information (CBI). SCJ’s Greenlist™ system overcomes CBI barriers by requiring suppliers to provide toxicological information on chemicals, chemical mixtures or materials rather than actual chemical ingredient information. Under this system, the identity of the chemical ingredients remains confidential. • Developing verification systems to ensure accuracy of data and compliance with RSL and other requirements. Nike considers its material, component and product testing program critical to ensuring that suppliers are

complying with its RSL requirements. Hewlett-Packard uses what they call an “active verification” process to ensure that suppliers and HP products are in compliance with the requirements of their GSE. This program consists of a signed letter indicating compliance, corrective action plans, and analytical testing in certain cases. All three firms expressed a hope or an expectation that the EU REACH Directive will over time lead to greater disclosure of chemical information and that consumer product companies worldwide will benefit.

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Lessons Learned: Advancing Safer Chemistry and Designing Safer Products

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ach case study provides a number of important lessons and best practices for safer product design, as described in the points below.

• Case study firms are expanding their focus from exclusively working to ensure that specific hazardous chemicals are absent from their products to identifying the chemicals that are in their products and determining whether they are safe. S.C. Johnson’s Greenlist™ System is used to evaluate and score the human and environmental health and safety of all of the ingredients in its products. (Though as noted by the company, in some cases it is difficult to get information from sup-pliers on certain classes of chemicals such as preservatives, and unintended contaminants and by-products from ingredient reactions.) While Nike and HP rely heavily on RSLs to ensure compliance with regulatory chemical restrictions, and to restrict other chemicals that they have deemed undesirable, they have begun to look more broadly at other chemicals that are in their products. HP is collecting data from its suppliers on 240 chemicals of “emerging concern,” not yet restricted, and building a database that points to where these chemicals occur in its supply chain. This will facilitate future efforts by HP to restrict those chemicals, either because of new regulations or a corporate decision, and to work with suppliers to find safer substitutes. Nike’s work in evaluating material platforms and its new protocol for evaluating chemicals in products represent efforts to evaluate all chemicals in products. These initiatives aim to identify chemicals that pose risk to consumers (i.e., they are high hazard chemicals with high potential exposure) and replace them with safer substitutes. • Working in partnership with suppliers helps to advance green chemistry. Partnering with suppliers on R&D has advanced green chemistry at S.C. Johnson. Suppliers routinely provide samples of new, greener chemicals to S.C. Johnson chemists for performance evaluations so that the chemists can quickly determine whether the greener alternatives are effective. The company is currently working closely with fragrance suppliers to develop phthalate-free fragrances for its home cleaning and air products.

Nike recognizes that they will not achieve their goals simply by dictating terms to their suppliers. When possible, Nike works closely with its suppliers to find a solution to a problem. The company recognizes partnerships with suppliers result in a more reliable supplier base over time. • Providing specific criteria for safer chemicals is effective in stimulating green chemistry innovation. S.C. Johnson’s Greenlist™ chemical scoring system clearly articulates the company’s criteria for greener materials, and in response, suppliers develop new chemicals to qualify for Greenlist™’s top score. Greenlist™ is helping to accelerate green chemistry innovation within S.C. Johnson’s supply chain. • Clear and constant communication with suppliers on desired green material attributes yields results. S.C. Johnson is extremely proactive in communicating its desire for green materials through, for example, supplier training, and has been rewarded for these efforts. S.C. Johnson’s supply base is well aware that by proactively introducing green materials to the company they can either gain new business or, they can protect their existing business relationship by offering greener materials. • If product greening is a core product design objective, integrated into the product development process and easily gauged by product developers, it is more likely to happen. Greenlist™ is a yardstick that product development chemists can use to easily gauge the relative “greenness” of their proposed formulations, just as they gauge performance and cost with well established metrics. The Greenlist™ score is embedded into the company’s global formulary, the chemical information system used by product developers. Nike’s environmentally preferable materials (EPM) program and HP’s DfE program are other examples of programs that integrate environmental objectives into design. • Collaborating and exchanging best practices with government agencies, non-profits and peers is highly beneficial when developing and implementing safer chemistry and product design programs. S.C. Johnson’s Greenlist™ program was developed with input from organizations such as the U.S. EPA, Forum for the Future, chemical suppliers and university scientists. The company has had a long-standing cooperative and collaborative relationship with regulatory agencies and in particular

Gathering Chemical Information & Advancing Safer Chemistry in Complex Supply Chain 11


the U.S. EPA, participating actively in the U.S. EPA’s Design for Environment Program’s Formulator Program9, an initiative that encourages individual companies and industry sectors to compare and improve the performance, human health profile and environmental responsibility of products, processes and practices. The company has had direct access to the expertise of EPA chemists, environmental scientists and risk reduction staff that has been beneficial in investigating materials to improve the health and environmental profiles of its products. HP was actively engaged in the development of EPEAT and many of HP’s products are listed in the EPEAT database. HP also participates in other green product certification programs. Nike’s RSL programs have benefitted from its participation in the Apparel Footwear International RSL Management Group, or the AFIRM Group. AFIRM is a working group that shares best practices on RSL management programs in this sector.

Nike, HP and SC Johnson have been active participants in the Green Chemistry and Commerce Council (GC3), an organization of more than 120 representatives in various industries, which serves as a forum for the exchange of best practices to encourage the adoption of Green Chemistry and Design for Environment. Nike has identified an opportunity to collaborate with other companies to overcome a barrier to safer chemistry and product design. Specifically, Nike would like to work with other companies to develop an information system and database to enable rapid retrieval of publicly available hazard data for individual chemicals. In Nike’s view, it is inefficient for individual companies to search for the same data, on their own. As a final note, case study firms are seeking global harmonization of similar chemical regulations to reduce the costs associated with regulatory activities. The patchwork of global chemical regulatory systems is seen as highly inefficient. Managing the proliferating regulatory programs takes considerable effort, even when the same set of substances is restricted in a similar manner (e.g., the variations on RoHS that have sprung up worldwide). These firms hope that harmonization will free up resources for more proactive green chemistry and design for environment activities.

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Conclusions

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he case studies reveal im-portant lessons, barriers and enablers for gathering chemical information in complex supply chains and using the information to advance safer chemistry and products. By sharing this information, these three companies and the GC3 hope to provide useful insights that other companies can benefit from as they design their own information, green chemistry and design for environment systems. A number of chemical information systems have been

developed for specific industry sectors, retailers, consumers, and government agencies. The report, Toxic Substances in Articles: The Need for Information10, conducted for the Nordic Council of Ministers, describes many of these systems. These systems provide additional models that may be useful to individual companies. The report also provides several short case studies describing why information on toxic substances is critically important to a variety of stakeholders, at various points in the life-cycle of a product.

Endnotes 1 California’s Safe Drinking Water and Toxic Enforcement Act of 1986, commonly referred to as Proposition 65, contains a provision that aims to warn workers and consumers about products containing substances that are known to cause cancer, mutagenic effects or reproductive health hazards. Companies selling products in the State of California that contain a listed chemical above a threshold concentration must label their products with a warning. The list includes approximately 775 chemicals. See California Office of Environmental Health Hazard Assessment, Proposition 65 in Plan Language, at http://oehha. ca.gov/Prop65/background/p65plain. html 2 REACH, or Registration, Evaluation, Authorization and Restriction of Chemicals, is a new European Union law addressing the production and use of chemical substances and their potential impacts on both human health and the environment. REACH replaces numerous EU laws related to chemicals. RoHS, or the EU Restriction on Hazardous Substances Directive, went into effect in July of 2006. The directive restricts the use of six toxic substances in electrical and electronic products: lead, mercury cadmium, hexavalent chromium, polybrominated biphenyls and polybrominated

diphenyl ethers (PBDEs). China passed a similar law (China RoHS), applying only to electronic devices and requiring a labeling provision. 3 For a description of chemical information needs of various stakeholders and existing information systems, see Massey, R., Hutchins, J., Becker, M., Tickner, J., Toxic Substances in Articles: The Need for Information, Nordic Council of Ministers, TemaNord 2008:596, 2008. Available on-lie at: http://www.turi.org/home/home_ page/new_at_turi/toxic_substances_in_ articles_the_need_for_information 4 REACH is designed to improve chemical information flow and enhance chemicals management in multiple dimensions. It mandates information sharing about both chemical hazards and chemical uses. The information requirements under REACH require firms to obtain and disclose to their supply chains (and to some degree the public) significantly more information about chemicals in products than is currently available. As a result, it is expected that REACH will lead to greater information flow up and down the supply chain. 5 See for example, Denison, R.A., Improving Information Flows – in Supply Chains and Beyond, Workshop Background Paper, ”Framing a Future Chemicals Policy,” Boston, April 28-29, 2005; and Organisation for Economic Co-operation and Development

(OECD), Environment Directorate, Joint Meeting of the Chemicals Committee and the Working Party on Chemicals, Pesticides and Biotechnology, Series on Risk Management No. 18, Workshop on Exchanging Information Across a Chemical Product Chain, Stockholm, Sweden, 15-16, June 2004, ENV/JM/ Mono(2004)29. 6 Mostowy, J., Bayer MaterialScience, Product Stewardship, Workshop Presentation, “Green Chemistry and Commerce Council Innovators Roundtable: Opportunities and Challenges in a New Era,” Broomfield, Colorado, May 4-6, 2009 http://greenchemistryandcommerce.org/ downloads/Mostowy.pdf 7 See for example http://www.hp.com/ hpinfo/globalcitizenship/environment/ productdata/reachdesktop-pc. html?jumpid=reg_R1002_USEN 8 HP’s General Specification for the Environment can be found at http://www. hp.com/hpinfo/globalcitizenship/environment/pdf/gse.pdf. Nike’s RSL document can be found at http://www.nikebiz.com/ responsibility/considered_design/documents/CorpRSL_Jan_2009.pdf. 9 http://www.epa.gov/dfe/pubs/projects/ formulat/index.htm 10 See note 3.

Chemicals, alone or in combination, are the platform upon which key elements of the global economy have been built, and have been incorporated into millions of products used every day. Many chemicals may have inherently harmful characteristics that can impact ecological and human systems as they are used throughout supply chains. A growing number of companies are discovering that the approaches of green chemistry and Design for Environment (DfE) allow for a transition to safer alternatives. The Green Chemistry and Commerce Council provides open conversation about the challenges to and opportunities for this successful transition. The GC3 is a project of the Lowell Center for Sustainable Production at the University of Massachusetts Lowell.

Green Chemistry and Commerce Council • 978-934-2997 • greenchemistryandcommerce.org

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M o v i n g

B u s i n e s s

T o w a r d

S a f e r

A l t e r n a t i v e s

Considered Chemistry at Nike: Creating Safer Products through the Evaluation and Restriction of Hazardous Chemicals Case Study for the Green Chemistry and Commerce Council (GC3)

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hen you hear the word Nike, immediately what comes to mind are sneakers, the “Swoosh” logo, or Michael Jordan gracefully depositing a basketball in a waiting rim. Typically one does not think about the vast array of materials that go into Nike products, the chemicals that make up those materials, and how both are chosen or, for that matter, rejected. Nike’s products must perform and materials are the building blocks of product performance. Up until the mid 1990’s, the company chose materials to meet performance and cost targets. Then, inspired by Paul Hawken and driven to respond to outside critics, Nike began to shoot for a third goal: Sustainability. The company began to view its products in an entirely new light. Looking at the entire life cycle of its products—manufacturing, use, and endof- life—Nike began to develop strategies for integrating sustainability objectives into the design and manufacturing of its products. Materials selection became a key focus of the company’s sustainability efforts, with particular emphasis placed on evaluating the toxicity of the chemicals that go into Nike products and the materials that aid manufacturing. Since that time, Nike’s work in sustainability, like its products, has evolved. The company has been on a nonstop voyage to find better ways to evaluate materials and produce products that are safer for consumers and the environment. Size and Supply Chain Headquartered near Beaverton, Oregon, Nike reported record revenues of $18.6 billion for its fiscal year 2008. Nike does not own or operate any of the contract factories that make Nike products.1 All manufacturing is done under contract by almost 640 factories in 52 countries, each supplied by between five to ten vendors.

Considered Design: Nike’s Sustainable Design Program Today, Nike’s sustainable design activities are housed within the company’s Considered Design Program. Launched in 2005, Nike assembled a team of chemists, biologists, material specialists and designers and charged them with the task of fundamentally integrating environmental sustainability with other Nike product design objectives. With the help of outside advisors from the Natural Step and other organizations, the company developed and adopted sustainable design guidelines, trained footwear designers and reviewed the application of those principles in quarterly meetings. Today, the goals of Considered Design are to reduce waste throughout the design and development process, use environmentally preferred materials, and eliminate toxics. Nike’s long-term vision for their Considered Program is to create products that use the least possible material, are designed to be easily disassembled for recycling or safely returned to nature at the end of life. In this case study, we describe two major elements of Nike’s Considered Design Program. • The Considered Index—a sustainable product design tool used to evaluate the expected environmental footprint of a product prior to commercialization. • Considered Chemistry—a set of activities designed to achieve Nike’s long-term corporate environmental goals to eliminate substances known or suspected to be harmful to human health or the environment. 1. Nike’s Considered Index Nike utilizes a sustainable product design tool called the Considered Index to predict the environmental footprint of a product prior to commercialization. The system examines solvent use, waste, materials and innovation for footwear. Apparel products are evaluated on waste, materials, garment

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treatments and innovation. Products are assigned a Considered score using a set of metrics contained in the index framework. The metrics are based on over a decade of research about materials, solid waste, innovations, textile treatments and solvent use. Specifically, the Nike Considered Index evaluates the following attributes: • Solvents—the intensity of use of solvent based cleaners, primers and solvents in footwear assembly as well as in decorative applications • Waste—in footwear, the waste footprint created in the manufacturing processes for material cutting, midsoles, sockliners, decorative applications, tooling use; in apparel, the waste footprint created in fabric cutting at the garment factory • Material—a life cycle analysis approach to material evaluation which considers growing and extraction practices, chemistry, energy intensity, energy source, water intensity, waste, recycled content and end-of-life for both footwear and apparel • Garment Treatments—the use of post assembly garment treatments in apparel • Innovation—significant new solutions to product-related environmental impact issues that are not currently captured in the Index criteria for both footwear and apparel

A. Nike’s Restricted Substances List Program (RSL Program) Nike has made a significant investment in the development of Restricted Substances List (RSL) and an extensive management system designed to ensure compliance on the part of suppliers. Restricted substances are chemicals or materials that must either be completely absent from a product, package or manufacturing process or present below a specified concentration. The list is a communication tool both for suppliers and internally for Nike. Nike’s RSL is derived from lists of chemicals or materials that are restricted by legislation or have been determined by Nike to be undesirable. Nike systematically reviews global legislation to identify chemical restrictions that are relevant for its products. Where more than one country or region restricts a chemical or material in the same application, Nike bases its corporate restriction on the strictest standard. Nike engaged the services of a consultant to develop and update a regulatory tracking system to stay current on relevant chemical and material restrictions. Once developed, Nike recognized that this system had broad application to other companies in the apparel and footwear industry. Nike permitted the consultant to make the system public and it is now available on the internet at http://www. regconnect.com/wsp/.

Products bearing the label Considered are those whose score significantly exceeds the corporate average. There are different levels of Considered: Gold, silver and bronze. The company is aiming for all footwear, apparel and equipment to be bronze or better by 2011, 2015, and 2020, respectively. Achievement of these goals would mean waste in Nike’s supply chain will be reduced by 17 percent and the use of environmentally-preferred materials will be increased by about 20 percent.

Nike’s RSL has nine sections: 1. Nike Finished Product Restricted Substances List (RSL) 2. Nike Corporate Odor Management Material Guidelines & Scented Material Guidelines 3. Nike Corporate Nanotechnology Material Guidelines 4. Nike Corporate Animal Skins Policy 5. Electrical and Electronic Components (this section applies to Regulated Substances in Electrical and Electronic Equipment (EEE)). 6. Packaging Restricted Substances List (PRSL) 7. Nike Footwear Manufacturing Restricted Substance List (MRSL) 8. Toys 9. Additional Chemicals of Concern

2. Considered Chemistry One of Nike’s long-term corporate environmental goals is to eliminate substances known or suspected to be harmful to human health or the environment. In 2004, the company stated that it would proactively target, remove, or replace chemicals that, while not illegal to use, fit the scientific definition of toxic. Nike developed several programs to help realize this goal: a. A Restricted Substances List Program (RSL Program); b. An initiative to reduce the use of toxic chemicals in manufacturing operations; c. An on-going initiative to evaluate material platforms to develop environmentally preferred materials; and d. A chemical review process to evaluate individual chemicals. Each of these programs is described in the sections that follow.

These nine sections are described in an appendix to this case study. Management of the RSL Process

Nike’s specifications and agreements with factories and vendors reflect RSL requirements, which are in addition to Nike’s Code of Conduct, quality standards and other health and safety standards. Testing. Nike notifies its suppliers and its vendors that it may request product testing at any stage of the manufacturing process, including development and production, or testing of the finished product. The testing may be part of a routine

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testing schedule or a random selection of samples. Suppliers and vendors are expected to test items that Nike identifies in order to identify problems stemming from the production process or product content. For apparel, equipment, and footwear products, Nike has developed standardized testing guidance, including specified test methods, test request forms and failure resolution forms. Some of the key provisions of these guidelines are summarized below. Testing guidance for toys, electronic and electrical equipment, and food contact materials are handled on a case-by-case basis. Nike-initiated routine testing. Each season, Nike identifies a list of materials and/or styles that must be tested at a Nike approved laboratory. The supplier is responsible to pay for this testing. Once testing has been initiated, suppliers are prohibited from shipping materials or products until they have received a test report that meets the Nike RSL requirements. If an item fails, Nike expects the supplier to conduct an investigation into the source of the failure and report the results back to Nike using a Failure Resolution Form. The supplier must indicate the source of the failure (including chemical name), action taken to prevent the failure in the future, and acknowledgment that these changes will be implemented on future production. Random testing. Nike randomly selects and tests products at all stages of production. Nike pays for this testing. Failures are discussed with suppliers in order to identify and correct the cause. Factories are also encouraged to randomly test materials prior to production. Supplier initiated testing. Nike encourages suppliers to conduct their own testing, with the intention that the results will be kept confidential between the lab and the supplier. Laboratories. Nike will only accept test reports from suppliers if the tests are conducted at laboratories that have been audited and approved by Nike. Currently, these approved labs are located in Asia and Germany. Test Data Management and Analysis. Nike RSL approved

testing labs are equipped to enter test data directly into the Nike RSL Database. The labs generate test reports that are sent to Nike and the supplier. This database, accessible only to Nike Inc., allows the company to mine the data and generate supplier “scorecards” that enable evaluation and comparisons of alternative suppliers. In addition, Nike has used the data to analyze materials and specific colors of materials to determine which tend to contain restricted chemicals or Chemicals of Concern, and which do not. This information has also been used to drive future RSL testing and communication.

B. Reducing the use of toxic chemicals in manufacturing operations Nike gathers chemical information from its environmental, safety and health (ESH), and engineering teams at contract manufacturing facilities to feed into decisions on the choice of process chemicals used to manufacture products. This work has led to the reduction of toxic chemicals such as solvents in manufacturing operations. C. Evaluation of material platforms to develop environmentally preferred materials Nike is engaged in an on-going effort to develop environmentally preferred material platforms. Chemical ingredients are evaluated for environmental, health and safety hazards and high hazard chemicals are prioritized either for elimination, if possible, or substitution with a safer chemical. This process requires full disclosure of chemical ingredients. Using this approach, Nike evaluated the ingredients used to make a rubber outer sole for footwear. The effort resulted in the creation of a new, environmentally preferred material that uses more benign accelerators, vegetable oils, and modified processing chemicals and methods. Chemical substitutes were selected based on low toxicity, performance, processability and cost. The company is currently evaluating alternatives to solvents used to produce synthetic leather for footwear products. The goal is to identify more benign, waterbased chemical alternatives. The process used for chemical evaluation is complex, costly and slow, particularly when hazard data is difficult to find. A significant portion of the cost comes from the use of toxicology consultants to evaluate the hazards of chemicals in the original material and potential substitutes. Nike is currently developing a streamlined process to reduce the cost and time required to conduct the chemical evaluation portion of the work. This system is described in the next section. D. Chemical review system to evaluate individual chemicals—under development Nike is developing a new system to evaluate the risk posed by individual chemicals. The system will be used to identify and prioritize hazardous chemicals either for elimination or control through Nike’s RSL Program. Results from chemical evaluations will drive new additions to the RSL and help set priorities for substitution of toxic chemicals. The system will also be used to evaluate possible substitutes for hazardous chemicals to ensure that they are truly better alternatives. An important objective for the development of this system is to increase the efficiency of the chemical evaluation process at Nike so that the company can evaluate the sizable

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universe of chemicals that are currently used in Nike products, and chemicals that might be used in the future. The system builds upon the environmentally preferable material development work described in the previous section. Once fully developed, the system will support those continuing efforts. The system employs a risk-based approach to evaluate the chemical ingredients of materials, considering chemical hazard and potential consumer, worker and environmental exposure to the chemical (risk = hazard x exposure). The system requires chemical formulation and hazard data. Nike has developed a blueprint for this new chemical review system and some of its key components. The system, illustrated in Figure 1, proceeds according to a number of steps as described below.

existing RSL guidance or is a Nike Additional Chemical of Concern (Section 9 in the Appendix describes this designation). If not, the chemical goes on to Step 2. Step 2. Preliminary Assessment

A preliminary assessment is conducted by a Nike toxicologist to determine whether a more detailed, formal review of the chemical is necessary. If the chemical is considered acceptable for use, i.e., it is a well known chemical that is generally accepted as safe, no further evaluation is done. If the chemical cannot be deemed acceptable in this stage, it proceeds to a formal review. Step 3. Formal Chemical Review Process Step 3a. Chemical Hazard Assessment

Step 1. Filter

The process starts with the identification of a chemical, either during a systematic review of a material or product or through a request by a field-based environmental health and safety team to evaluate a chemical. The reviewer determines whether the chemical is already restricted by the

Nike’s approach to chemical hazard assessment follows the Organization for Economic and Cooperative Development (OECD) Harmonized Integrated Classification System for Human and Environmental Hazards of Chemical Substances and Mixtures. Nike chose the OECD system because it has gained wide acceptance among several countries,

Figure 1. Nike Chemical Review Process Chemical Review Request from Field-Based EH&S Team

Systematic Review of a Material of Product

Chemical

Chemical

Chemical Subject to Nike RSL or Additional Chemical of Concern Requirements

Filter Yes

Chemical on NIke RSL or Additional Chemical of Concern List? No

Formal Review Necessary?

Preliminary Assessment

Yes

Chemical Hazard Assessment • Human toxicity • Environmental toxicity • Climate hazard • Other environmental hazards

Potentially Significant Hazard? (Category 1)

No

Nike Exposure Assessments • Consumer • Environment • Worker

Yes

No No Database of Chemical Hazard Data

Potentially Significant Exposure? Yes

Chemical Acceptable for Use

Nike RSL

Nike Additional Chemicals of Concern

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toxicologists and environmental chemists and has become an internationally recognized standard for the analysis of mammalian and aquatic toxicity. Nike’s assessment scheme evaluates chemicals across 18 hazard characteristics, listed below. Chemical Hazard Characteristics • Acute toxicity • Irritation of skin • Eye irritation • Skin or respiratory sensitization • Genetic Toxicity/Mutagenicity • Carcinogenicity • Reproductive/Developmental Toxicity • Specific target organ toxicity following repeated exposures • Endocrine effects • Chemical interactions/reactions • Aquatic toxicity—Acute (Fish, crustacean, algae)

Chemical Hazard Characteristics contintued • Bioaccumulation potential • Degradability/Persistence • PBT Classification (Persistent Bioaccumulative Toxicant) • Halogenated Organic Compound (AOX) • Heavy metal content • Climatic hazard (greenhouse gas) • Other environmental classification (toxicity to soil organisms, terrestrial plants) Each characteristic is given a category designation from 1 to 4, or inadequate data, as follows in the box on the following page. For each of the 18 characteristics, Nike has developed criteria for assigning the category designations. As an example, the criteria for the hazard characteristic “Irritation of Skin” are presented in Table 1. Nike seeks out five data points from recognized data sources to evaluate each characteristic. Examples of these

Table 1. Criteria for the Evaluating Hazards Related to Irritation of Skin Ranking Priority

Category

Category 4

Non-irritating Irritation of skin (2) [Also for long-term, or "cumulative" irritation (e.g. human patch tests) and phototoxicity] Regulatory Review Effect Definition

Inadequate Data (To be judged)

Category 1 Severe irritant or corrosive

Category 3

Category 2

Mild irritant

Irritant

No review available

• reversible adverse effects in animal tests, persistent inflammation [mean Draize score in 2 of 3 animals for erythema/ edema between 2.3–4.0] • reported from human experience • based on valid in vitro test • indicated by existing data in animals (from acute toxicity tests)

• visible tissue Review of destruction/ technical litnecrosis erature may observed in be used as at least one an ancillary animal, or source for reported from classification. human exDocument perience in chemical • based on valid summary in vitro test sheet. • ph≤2, or ≥11.5

• reversible ad• as observed verse effects in in animal tests decimal tissue or human [Draize score in experience 2 of 3 animals • based on valid for erthema/ in vitro test edema between • indicated by 1.5–2.3 existing data • or as reported in animals in human (from acute experience toxicity tests) • based on valid in vitro test • indicated by existing data in animals (from acute toxicity tests)

Reference (Data Source) [Merck Index, ACGIH, NIOSHTIC, HSDB, RTECS, IUCLID, TOXNET, MSDS sheets, TLV or MAK value documentation, USEPA HPV Database, ESIS] OECD Based primarily on animals tests conducted in accordance with OECD protocol; however, a host of other data based on human experience, acute (dermal) toxicity studies in animals, in vitro assays, and alkaline/acid nature of chemical (pH). Surrogate or SAR/ SPR data may also be considered and used to esimate the irritant potential of a chemical.

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Chemical Hazard Assessment Categories Category

Definition

Category 4

Safe

Category 3

Low level of hazard

Category 2

Low to moderate hazard

Category 1

Moderate to high level of Hazard

Inadequate Data

Unable to categorize hazard characteristic due to lack of data

recognized data sources are listed in the References column in Table 1. If the chemical falls into the range of a Category 1 for one or more characteristics the chemical proceeds to exposure assessment. Finding five data points can be challenging given the limited availability of hazard data. John Frazier, Nike Director of Considered Chemistry, stated that he hopes the European Union’s REACH2 system and other regulatory programs will make data more available in a consolidated, easy-tosearch format. Nike would like to automate this process to more rapidly and cost-effectively assess chemicals. The automated system would be designed to enable Nike to simply enter a CAS3 number or a chemical name and the system would electronically retrieve hazard data (ideally five data points) for each of 18 hazard characteristics from a set of designated sources of hazard data. Nike would like to develop this system in concert with other companies since there is a general need for this data across all sectors. As stated by John Frazier, “we all are paying to have the same chemicals reviewed over and over with little to no data sharing. If a tool like this was available, this money could be spent on other efforts.” Step 3b. Exposure Assessment

The Exposure Assessment examines potential consumer, environmental and worker exposure to high hazard chemicals using exposure models developed by Nike for apparel, footwear and equipment. The apparel exposure model is often used, even if the chemical is present only in footwear and equipment, because it produces a more conservative estimate of exposure (i.e., if a chemical passes the exposure assessment for apparel, it will pass for footwear and equipment as well). High hazard chemicals with high potential exposure are added either to Nike’s Chemical of Concern list or one of the sections of Nike’s RSL. Nike will use this chemical review process to evaluate chemical substitutes for materials or products to determine whether they pose less risk than the chemicals they would be replacing. The company does not produce a list of

“acceptable” or “safe” chemicals for its suppliers. According to John Frazier, doing so would be fraught with problems since the safety of a chemical depends on the specific application. Nike will also use this framework to determine whether to require a reduction in the allowable concentration of an RSL chemical, or to eliminate its use entirely. This process will begin with chemical testing of a product to determine actual concentrations of RSL chemicals. Using a safety factor, Nike will compare the actual concentrations to the acceptable concentrations, as indicated in the existing RSL guidance. If the actual concentration exceeds the RSL acceptable concentration, Nike will either lower the acceptable level in their RSL guidance or restrict the chemical entirely. Lessons Learned Nike has learned a great deal about the significant challenges to, and opportunities for, improving the chemical safety of its products in a complex supply chain environment. • Getting complete and reliable chemical information from suppliers remains a challenge. In some cases, contract factories or vendors do not have full chemical information from their suppliers on the chemicals, chemical mixtures, textiles or other materials that they procure. Even if information is provided, it may not be correct. In some cases, suppliers are simply unwilling to provide the information.    John Frazier described an instance when Nike tried to get chemical information from a company that supplied dyes to a facility that dyed textiles for Nike products. The supplier, a formulator of dyes from chemical ingredients, was unwilling to provide the dye ingredients. Since sales to Nike made up approximately 5% of the suppliers total sales, Nike did not have sufficient leverage to get the information. • Finding hazard data on chemicals is challenging. Nike aims for five data points from recognized sources to evaluate each hazard characteristic. Locating this data can be difficult and costly. • The importance of verification. While certification of compliance has become a standard component of corporate RSL systems, Nike recognizes that it is not enough. Certification is not a guarantee of compliance with RSL policies. With hundreds of factories, each supplied by five to ten material vendors, it is impossible for Nike to audit all companies in its supply chain. The testing program is critically important to verifying compliance with RSLs. • Data collected from material and product testing under Nike’s RSL program can inform future supplier and material selection. Analyzing test data helps Nike identify

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reliable suppliers and choose safer materials for future products. • The importance of building partnerships with suppliers. Nike recognizes that they will not achieve their goals simply by dictating terms to their suppliers. When possible, Nike works in partnership with suppliers to find a solution to a problem. They recognize that over time, greater partnership will result in a more reliable supplier base. Clear communication with suppliers is a critical component of these efforts. Nike has learned that it must clearly communicate its goals to suppliers in order to achieve the desired outcome. • Restricting chemicals used in manufacturing can have unintended consequences. When trying to restrict the use of certain chemicals in manufacturing, Nike has found that it must be careful to not simply “push” the use of the chemical to a different part of the supply chain. There is a risk that suppliers will simply “outsource” a process that uses the restricted chemical, thereby making it invisible to Nike. • The importance of sharing best practices with peers. Nike has benefitted from its participation in the Apparel Footwear International RSL Management Group, or the AFIRM Group. AFIRM is a working group that shares best practices on RSL management programs. Members include

multiple apparel and footwear companies with RSL as well as regulatory, product safety and chemistry experts. AFIRM’s aim is to reduce the use and impact of harmful substances in the apparel and footwear supply chain and to provide a forum to advance the global management of restricted substances in apparel and footwear.4 Nike has also benefitted from its participation in the Green Chemistry and Commerce Council (GC3), an organization of more than 120 representatives in various industries, seeking to integrate Green Chemistry and Design for Environment approaches into product development. — Monica Becker, Monica Becker & Associates Sustainability Consultants and Lowell Center Fellow

Sources Information for this case study was gathered from the following sources: 1 Interviews with John Frazier, Nike Director of Considered Chemistry. 2 Nike Considered Design—Products That Redefine Performance and Sustainability, October, 2008, http:// www.nikebiz.com/media/pr/2008/10/28_Considered.html 3 Nike’s website on RSLs http://nikeresponsibility.com/ #environment-design/rsl and the RSL document http:// www.nikeresponsibility.com/rsl_downloads/CorpRSL_ Jan_2009.pdf

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Appendix A Description of Nike’s Restricted Substances List Nike’s RSL has nine sections, as described in the sections below. 1. Nike Finished Product Restricted Substances List (RSL) The Nike finished product RSL contains numerous chemicals organized by category (e.g., azo dyes, disperse dyes, and flame retardants). The list is available on the internet so that Nike suppliers and anyone interested can easily access the most current information. A table containing the list of restricted substances indicates the following:

• The reason for the restriction (legislated or Nike requirement) • Nike’s maximum allowable concentration limit (either prohibited, not detected, or an amount typically expressed as a concentration of the substance in mg per kg of component5 material) • Required laboratory reporting limit (i.e., laboratory equipment detection limit) for testing of components • The specific test method that must be used for testing. Table A-1 is an excerpt from the Nike Finished Product Restricted Substances List (RSL).

Table A-1. Excerpt from the Nike Finished Product Restricted Substances List Restricted Substance or Group Name (CAS #):

Reason for Restriction

Legislated Phthalates All esters of –phthalic acid including but not restricted to: di-isononyl phthalate (DINP) (28553-12-0) di(ethylhexyl) phthalate (DEHP) (117-81-7) di-n-octyl phthalate (DNOP) (117-84-0) di-iso-decyl phthalate (DIDP) (26761-40-0) butyl benzyl phthalate (BBP) (85-68-7) dibutyl phthalate (DBP) (84-74-2)

NIKE LIMIT: Maximum allowable concentration in component5 Apparel and Equipment: For children < 36 months: all materials <500 mg/kg (total)

Required Laboratory Reporting Limit Per substance concentration in product 50 mg/kg for each phthalate

Footwear: For shoes < 160 mm <500 mg/kg (total)

Test Method and Comments Nike – In-house Method Determination of defined Ortho-Phthalic Esters in Synthetic Fibers and Thermoplastics by LC-DAD-MS or GC-MS Confirmation of failure by fragmentation HPLC-MS

Apparel and Equipment: For children < 36 months: all materials Footwear: Limits apply for the following shoe size Shoes < 160mm (Nike size 10C and smaller) Polyvinylchloride (PVC) (9002-86-2)

Nike Requirement

Apparel, Equipment, Footwear: All products, all materials*: not detected

PVC 10% (Due to complexity of analysis, Nike defines detection limit as 10%)

*Apparel Only— Screen Prints: All screen prints for children < 7 years: not detected

Infrared Analysis*: Spectroscopy (IR) with or without solvent extraction (Positive results for both tests indicate PVC): * PVC test methods are “qualitative”— the 10% limit is estimated sensitivity

* Program to phase out all other PVC containing screen prints: ongoing.

Short Chain Chlorinated Paraffins (SCCP) with C10–C13 (85535-84-8)

Legislated

1000 mg/kg

Two tests for confirmation Beilstein’s test*: Burning test for the presence of chlorine

100 mg/kg

Solvent extraction, followed by GC/ECD analysis and GC/MS confirmation

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2. Nike Corporate Odor Management Material Guidelines & Scented Material Guidelines Odor management materials are defined by Nike as antimicrobial agents (biocides, antibacterials and biostats), odor capture technologies and scented ingredients. Nike restricts the use of scented materials and odor control technologies in apparel, footwear and equipment. In order to be used, scented materials or odor control technologies must: • Not leach or release chemicals in order to be effective6 • Meet global legislative standards • For microbial technologies, be registered under the EU Biocide Directive • Pass a corporate toxicity review • Be proven effective • Comply with the Nike Corporate RSL (Restricted Substances List) 3. Nanotechnology Material (Nanomaterial) Guidelines Nike reviews and controls the use of nanomaterials within apparel, footwear and equipment product lines. Nanomaterials are chemicals, compounds or components that derive their function from their extremely small size, between one to 100 nanometers (one nanometer is one-billionth of a meter). This restriction applies to any nanomaterial containing a substance or product component that is intentionally applied to a Nike product, either used to impart desirable physical properties to the final product or that remains in the product stemming from the manufacturing process. Nike requires that products to which nanomaterials are applied must not leach or release chemicals or particles to be effective or as a result of wear, unless safety data are available and deemed acceptable. In addition, nanomaterials must meet global legislative standards, be either registered with a government body or the manufacturer/supplier must analyze consumer safety, pass a corporate toxicity review, be proven effective and comply with the Nike Corporate RSLs. 4. Nike Corporate Animal Skins Policy Nike has set out specific requirements for animal skin materials and products used in products including requirements for sourcing some skins from U.S. sources, certification of compliance with the Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES) and prohibitions on the use of skins from certain animal species. 5. Restricted Substances in Electrical and Electronic Components Nike has established a set of chemical limits specifically for Electrical and Electronic Equipment or components, focused on heavy metals in batteries and in other components, as well as certain flame retardants.

6. Packaging Restricted Substances For all packaging components7,Nike directs its suppliers to comply with legal restrictions for heavy metals8, forbids the intentional introduction of heavy metals and limits the combined incidental concentration of heavy metals to 100 ppm. Nike requires suppliers to test for heavy metals using specified tests and maintain formal certification of compliance with applicable laws. In addition Nike puts the onus on its suppliers to identify and minimize dangerous substances according to specific lists of dangerous chemicals. These substances must be identified on Material Safety Data Sheets (MSDS). The lists of dangerous substances provided to suppliers are the Nordic Council’s N-CLASS Database on Environmental Hazard Classification9 and the Finish Standards Association’s SFS-EN 13428 standard addressing toxics in packaging. Nike restricts the use of formaldehyde to 150 mg/kg and prohibits the use of polyvinyl chloride (PVC). Packaging must be tested for formaldehyde and all plastic and paper packaging with a plastic laminate must be tested for PVC. Nike has additional design requirements for packaging including: minimum recycled material content requirements; restrictions on the number of packaging layers; recoverability by either recycling, energy recovery or composting; a prohibition on the use of expanded polystyrene packaging for small electronics and all toys; and preferences for sustainably harvested wood-based products. 7. Manufacturing Restricted Substances List (MRSL) Nike prohibits suppliers from the intentional use of certain chemicals in manufacturing. A portion of the list is presented in Table A-2. While suppliers are working on eliminating the chemicals, Nike advises companies to minimize exposure to the worker, environment, and consumer. Suppliers are reminded that MSDS’ for the chemicals that they are purchasing may not disclose the presence of these chemicals if their concentration is 1000 mg/kg or lower. Nevertheless, the suppliers are still responsible for ensuring that worker exposure does not exceed Nike’s exposure limits for contract factories. 8. Toys10 The toy section of Nike’s RSL is based on the European Union’s Toy Safety Directive 88/378/EC11. Nike provides suppliers with a list of chemicals and their maximum allowable concentrations for specific types of toys, toy components and toy materials. Toys must meet these limits as well as the Nike RSL for finished products, including a prohibition on PVC. Toys must also pass mechanical and safety testing.

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Table A-2. Excerpt from the Nike Manufacturing Restricted Substances List (RSL) Restricted Substance or Group Name (CAS #):

Synonym(s)

Common Potential Uses

Cresol ( 1319-77-3) m-Cresol (108-39-4) o-Cresol (95-48-7) p-Cresol (106-44-5)

Cresylic Acid

Nylon and plastic primers and resins

N,N-Dimethylacetamide (127-19-5)

DMAC

Solvent in Primers, Adhesives and Resins

Dimethylsulpoxide (67-68-5)

DMSO

Solvent Cleaner

Dimethyl formamide (68-12-2)

DMF

Solvent Cleaner

Ethylene glycol monobutyl ether (111-76-2)

EGBE/Butyl cellusolve

Solvent Cleaner

Formaldehyde (50-00-0)

Formic aldehyde

Solvent cleaner, anti-shrinkage resin, mold inhibitor

Methylene Chloride (75-09-2)

Dichloromethane, Methylene Dichloride

Solvent Cleaner

n-hexane (110-54-3)

Hexane

Solvent Cleaner

n-methyl pyrrolidone (872-50-4)

NMP, 1-methyl-2-pyrrolidinone

Solvent Cleaner

4,4’-methylenebis (2-chloraniline) (101-14-4)

MOCA

Press Pad

Phenol (108-95-2)

Carbolic acid, phenyl alcohol, phenyl hydroxide

Solvent in primers, adhesives and resins for nylon and plastics

Tetrachloroethylene (127-18-4)

Perchloroethylene, PERC

Solvent cleaners

1,1,1-trichloroethane (71-55-6)

1,1,1 – TCA, methyl chloroform

Solvent Cleaners

Toluene (108-88-3)

Methylbenzene

Solvent in primers, adhesives, paints and inks

2,4-toluene diisocyanate (584-84-9) Toluene-2,6-Diisocyanate (91-08-7)

TDI

Activator in some polyurethane foams

Trichloroethylene (79-01-6)

TCE, trichlorethene

Solvent cleaner

Xylene – all isomers (1330-20-7)

Ethylbenzene, o,m,p-xylene

Solvent in primers, adhesives, paints, inks

Trichloromethane (67-66-3)

Chloroform

Solvent Cleaner

1,1,2-Trichloroethane (79-00-5)

Vinyl trichloride

Solvent Cleaner

1,1-Dichloroethylene (75-35-4)

1,1-dichloroethene

Solvent Cleaner

Additional Chemicals of Concern Nike has developed a list of chemicals that while not prohibited by the company, are identified as chemicals that are the focus of governmental, academic and/or NGO research and may in the future be legally regulated or put on the RSL. Nike requests that suppliers review the list internally and with their chemical suppliers, determine if these substances are likely to be found in their product, understand the function(s) they serve and if possible, avoid intentional use of these chemicals. Suppliers may be asked why and how the chemical is used and what can be done to eliminate its use. Currently, this list contains several categories of alkylphenol ethoxylates12 and certain Organotin Compounds.13

Endnotes 1 In this case study, the term “factory” refers to Nike’s contract manufacturers. These companies are independently owned manufacturing facilities that are under contract to Nike to cut, sew or assemble Nike products. These factories purchase the chemicals, materials, components, and dyeing services that they need from “vendors.” Vendors enter into contracts with factories for the supply of these materials and services. The term “suppliers” refers collectively to factories and vendors. 2 REACH, or Registration, Evaluation, Authorization and Restriction of Chemicals, is a European Union law addressing the production and use of chemical substances and their potential impacts on both human health and the environment. 3 CAS, or Chemical Abstract Service registry numbers are unique numerical identifiers for chemical elements, compounds, polymers, biological sequences, mixtures and alloys. 4 See http://www.afirm-group.com/

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5 “Component” is defined as any single part/layer of a product that is visibly distinguishable from other parts/layers and separable by simple physical means e.g. knife and tweezers. 6 Substances could include the heavy metals Copper, Silver, Tributyltin (TBT), Triclosan and Pentachlorophenol. 7 Nike defines packaging components as individual assembled parts of a package, including, but not limited to, interior/exterior blocking, bracing, cushioning, weatherproofing, exterior strapping, coatings, closures, dyes, pigments, adhesives, stabilizers, inks, labels and additives. 8 Cadmium, Mercury, Lead and Hexavalent Chromium. 9 The N-CLASS Database on Environmental Hazard Classification is compiled by the Steering Group for the Nordic Council of Ministers project on Hazard Classification and Labelling. The database contains substances, 7987 at present, that have or are being discussed by the European Commission Working Group (CWG) on classification and labeling for environmental effects. The database includes substances that have been assessed as dangerous to the environment and substances that have not been classified (either because they have been classified as not dangerous to the aquatic environment or because there is insufficient data). See http://www.kemi.se/nclass

10 A toy, as defined by Nike, is any product or material with play value by children of less than 14 years of age. 11 The European Union’s Toy Safety Directive 88/378/EC draws on EU standards EN 71-3:1994 Specification for migration of certain elements, EN71-9:2005 Organic chemical compounds, EN71-10:2005 Organic chemical compounds - Sample preparations and extraction, and EN7111:2005 Organic chemical compounds - Methods of analysis. 12 Alkylphenol ethoxylates (APEs) are used as surfactants in manufacturing of textiles and other products such as emulsifiers, detergents and pesticides. APEs do not biodegrade easily and are toxic to aquatic organisms. See for example, Environment Canada, Health Canada. “Nonylphenol and Its Ethoxylates: Priority Substances List Assessment Report.” 2001. 13 Tributyltin, or TBT, is used as a biocidal preservative for wood, cotton, textiles, paper and paints and stains for residential homes. It has been used since the 1960s as an antifouling agent in marine paints. TBT is persistent and bioaccumulative in aquatic environments and highly toxic to aquatic organisms. See for example The Inter-Organization Programme for the Sound Management of Chemicals (IOMC), “Concise International Chemical Assessment Document 14, Tributyltin Oxide.“ 1999.

Chemicals, alone or in combination, are the platform upon which key elements of the global economy have been built, and have been incorporated into millions of products used every day. Many chemicals may have inherently harmful characteristics that can impact ecological and human systems as they are used throughout supply chains. A growing number of companies are discovering that the approaches of green chemistry and Design for Environment (DfE) allow for a transition to safer alternatives. The Green Chemistry and Commerce Council provides open conversation about the challenges to and opportunities for this successful transition. The GC3 is a project of the Lowell Center for Sustainable Production at the University of Massachusetts Lowell.

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S.C. Johnson Is Transforming Its Supply Chain to Create Products that Are Better for the Environment Case Study for the Green Chemistry and Commerce Council (GC3)

S

.C. Johnson is a formulator of chemical-intensive products that are used in millions of households each day. The company does not produce the ingredients that go into their products. Rather, individual chemicals or chemical mixtures are selected by company chemists and procured from suppliers. The evaluation and selection of these supplied raw materials is of paramount importance to the company, determining whether products will perform, be cost-effective and better for consumers and the environment. In this case study we examine how S.C. Johnson, through its Greenlist™ process, is transforming its supply chain to create products that are better for the environment. S.C. Johnson is a company with a long, proud history. Founded in 1886 as a parquet flooring company by Samuel Curtis Johnson, S.C. Johnson is now a diversified consumer product company selling home cleaning and storage, air care and pest control products. From its headquarters in Racine, Wisconsin, five generations of the Johnson family have grown the business into a sizeable, global company. The company generates more than $8 billion in sales, employs approximately 12,000 in more than 70 countries and sells products in more than 110 countries.1 With brand names like Shout®, Windex®, Ziploc®, Glade®, Raid®, OFF!®, Pledge®and Scrubbing Bubbles®, few consumers are unfamiliar with S.C. Johnson’s products. S.C. Johnson’s Product Development and Supply Chain The majority of the product development work at S.C. Johnson is done in Racine, with a small development effort in China. All development for global products is done in Racine. The company aims to create standard formulations that are sold globally but in some cases, products need to be tailored for different markets. S.C. Johnson has one “global formulary” or chemical information system, which is the basis for all chemical selection. Chemical ingredients

are chosen by product development chemists from the formulary database, which contains information on chemical structure, physical properties, composition, CAS2 number and a Greenlist™ environmental, health and safety rating. Once selected, procurement staff purchase materials based on price, quality and delivery. S.C. Johnson’s primary suppliers are the larger chemical companies—Dow, DuPont and BASF—but the company also purchases from smaller, specialty chemical companies that supply surfactants, fragrances and other specialty components. Many of the company’s suppliers are global, which contributes to the uniformity of the products that are manufactured worldwide. Greenlist™ In 2001, S.C. Johnson launched an innovative chemical classification process called Greenlist™ that rates raw materials based on their impact on the environment and human health. Greenlist™ scores are reported alongside performance and cost information in the company’s chemical formulary so chemists can choose materials in consideration of their environmental and health properties. Using the scores, materials can be easily compared. S.C. Johnson chemists around the globe have instant access to data on the score of ingredients for product formulation and reformulation. The Greenlist™ program was developed with input from other organizations such as the U.S. EPA, Forum for the Future, chemical suppliers and university scientists. Greenlist™ has received a number of awards, including the Ron Brown Award for Corporate Leadership and the Presidential Green Chemistry Challenge Award. S.C. Johnson was awarded the U.S. EPA Safer Detergents Stewardship Initiative (SDSI) Award for the elimination of all nonylphenol ethoxylate surfactants from products. This was accomplished through the use of Greenlist™.

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The Framework. Greenlist™ currently has unique rating criteria for 19 material categories (see box, right). The S.C. Johnson formulary has Greenlist™ scores for more than 98 percent of the raw materials currently used by the company. Each of the 19 chemical categories is scored based on four to seven criteria. Criteria for each chemical category are unique and determined by use pattern and the environmental media impacted (i.e., air, water, soil). Criteria include ultimate biodegradability, acute human toxicity, aquatic toxicity and European Union environmental classification (also known as EU Risk or R Phrases). There are four Greenlist™ scores. 3 Best 2 Better 1 Acceptable 0 Restricted Use Material (RUM)

Greenlist™ Material Categories • • • • • • • • • •

Surfactants Solvents Propellants Chelants Preservatives Waxes Insecticides Fragrances Inorganic acids Inorganic bases

• • • • • • • • •

Resins Organic Acids Dyes Colorants Thickeners Packaging materials Non-woven fabrics Silicones Sawdust and plant materials

Greenlist™ Examples of Other Significant Concerns

First, the material is rated according to the appropriate criteria. As an example, the table below presents the Greenlist™ criteria for surfactants. Next, scores for the criteria are averaged. The average score is then adjusted for “Other Significant Concerns,” which vary by material category (see box, right).

• • • • • •

Possible endocrine disruption Carcinogenicity Reproductive toxicity EPA’s PBT Profiler classification Other environmental concerns Ban by countries where SCJ does business

Table 1. Greenlist™ Surfactant Criteria Scoring Criteria Endpoints Categorical Criteria Aquatic Toxicity

Acceptable (Score = 1) • LC50/EC50 ≤1 mg/L • 1–2 species

Better (Score = 2) • LC50/EC50 > 1 mg/L • 1–2 species

Best (Score =3) • LC50/EC50 > 1 mg/L • 3 or more species

Acute Human Toxicity

Rat Oral LD50 < 500 mg/L

Rat Oral LD50 500–2000 mg/L

Rat Oral LD50 > 2000 mg/L

Ultimate Biodegradability

≤ 60% within 28 days

> 60% within 28 days

• Classification of “readily biodegradable” by OECD 301 test methods • > 60% within a 10 day window

EU Environmental Classificaiton

Any combination of EU environmental classifications (N; R50; R51; R52; R53)

• No adverse EU environmental classification • Classification as “Readily Biodegradable” by international test methods • Aquatic toxicity > 1 mg/L

• No adverse EU environmental classification • Classification as “Readily Biodegradable” by international test methods • Aquatic toxicity > 100 mg/L

Source/Supplier

Source: < 25% preferred source Supplier: no environmental management standard in place

Source: 25–75% preferred source Supplier: an internal company environmental management standard in place

Source: >75% preferred source Supplier: internationally recognized environmental management standard in place (ie. ISO 14001 or Responsible Care)

Other Significant Concerns

• • • • •

EPA classification as a PBT/POP chemical3 Classification as an endocrine disruptor Classification as a known, probable, or possible human carcinogen according to IARC, EPA or NTP Classification as a reproductive toxin according to Proposition 65 Considered a “Chemical of Concern” with official or unofficial bans in one or more countries or by relevant trade associations

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If S.C. Johnson determines that the material carries other significant concerns, the score is reduced by one class (for example from a 2 to 1). A material with a score of “0” is designated as a “Restricted Use Material” or RUM. S.C. Johnson works to replace these chemicals with alternatives that have better environmental and health profiles and are more biodegradable. The use of a RUM chemical requires approval of top management and is granted in limited cases when alternative chemicals are unavailable. This element of the system provides flexibility to “downgrade” a material’s Greenlist™ score if additional concerns exist. The score can only be lowered, not raised. The criteria are adjusted as new information emerges. The Data. The environmental, health and safety (E,H&S) data required to score materials are provided to S.C. Johnson by the supplier. Generally, suppliers provide what are called “toxicology summaries” with all the information needed to evaluate a chemical. S.C. Johnson toxicologists receive the data and develop the scores. If additional information is needed to, for example, verify certain data elements, the toxicologists request additional data. In a small number of cases, as we describe in the coming section on Managing Supplier Confidentiality, suppliers conduct the Greenlist™ scoring and submit the score to S.C. Johnson. In some cases, suppliers have been unwilling to disclose sufficient ingredient or toxicological information for S.C. Johnson to devise a Greenlist™ score. In these cases, materials must be assigned a score of 1. Suppliers are told that they will be at a competitive disadvantage and sometimes this leads to greater disclosure. Managing Supplier Confidentiality. Some suppliers are guarded when it comes to sharing the E,H&S data that S.C. Johnson needs to evaluate a material under Greenlist™. Over time, S.C. Johnson has developed protocols to deal with these confidentiality issues. There are essentially three levels of confidentiality. Some chemicals purchased by S.C. Johnson are in common use in industry and are not considered proprietary by their suppliers. For these chemicals, suppliers provide S.C. Johnson with EH&S data freely. Certain chemicals or formulations are considered proprietary by their suppliers, but these suppliers are willing to provide S.C. Johnson with EH&S data under a non- disclosure agreement. Under these agreements, only S.C. Johnson toxicologists get access to the data for the purpose of scoring the material in Greenlist™. Polymers and dyes typically fall under this category. Finally, some suppliers regard their products as highly proprietary. This is typically the case with fragrances. In these cases, the supplier determines the Greenlist™ score

and provides only the score to S.C. Johnson. The company audits these submittals. S.C. Johnson has had difficulty at times getting complete information on suppliers’ Material Safety Data Sheets (MSDS). As stated by Daniel Lawson, Sustainability Innovation Manager for S.C. Johnson, “the typical MSDS prepared for the U.S. market is two pages long. In contrast, a typical MSDS prepared for the European Market is 16 to 20 pages long, containing significantly more chemical and E,H&S information.” David Long, consultant to S.C. Johnson, believes that the implementation of the European Union’s REACH program will over time lead to greater disclosure of chemical information by suppliers, even in the U.S., and that companies like S.C. Johnson and consumers will benefit from greater data availability. Addressing Unintended Contaminants. In some cases supplied materials may contain small amounts of preservatives, contaminants, unreacted chemicals or unintended by-products from chemical reactions. S.C. Johnson typically addresses these by adjusting the Greenlist™ score of the supplied material under the “Other Significant Concerns” element of the Greenlist™ process. The purity of the material supplied can be addressed in the specifications written during the procurement process. Suppliers are required to provide chemical analysis and certification of the purity of the product supplied and S.C. Johnson can prohibit certain substances. For example, S.C. Johnson uses caustic soda (Sodium Hydroxide or lye) in some of its formulations. Some caustic soda is produced in chlor-alkali plants that use a mercury cell process. Caustic and other products derived from this process can be contaminated with mercury. To ensure that the caustic purchased by the company is free of mercury contamination, S.C. Johnson will not purchase caustic or sodium hypochlorite made by the mercury cell process and has put in specifications that caustic cannot contain mercury above the part per billion level (ppb or 0.0000001%). Other Greenlist™ Program Features Relationship to Regulatory Compliance. Greenlist™ goes above and beyond what is required by current regulation and is forward-looking, anticipating future chemical regulations and seeking to phase out hazardous chemicals in advance of regulatory action. Greenlist™ has not replaced S.C. Johnson’s environmental, health, safety and risk management programs. Rather, it compliments these efforts by eliminating chemicals before they are banned or otherwise regulated. Tracking Overall Corporate Progress. In addition to providing a scoring system for materials, Greenlist™ also provides metrics for tracking S.C. Johnson’s corporate-wide

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progress toward greening its portfolio of products. Each year, the company calculates a weighted average Greenlist™ score for all raw materials used. The overall score is calculated by multiplying the weight of each chemical purchased by its Greenlist™ score, summing these numbers and then dividing by the sum of all raw materials used by weight. A rising score indicates increasing use of environmentally preferable materials. This metric is tracked yearly and yearly goals are set to reach a five year goal. The company also tracks the year-on-year percentage change in the use of materials in each group. S.C. Johnson’s goal is to increase the percentage of raw materials that are rated “Better” or “Best.” At the start of the program (reporting period 2000/2001), a total of 4 percent of materials were “Better” or “Best.” In their 2008 Public Report, the company reported that in the 2006/2007 reporting period, they reached 18%, increasing their use of “Best” materials by 25 million kilograms over the previous year. Use of RUM materials dropped from 17% to 1% during the same period, despite sales growth. Tying Performance Evaluations to Greenlist™ Scores. Greenlist™ scores are linked to employee performance. Each year Greenlist™ goals are established. The goals are aligned from senior managers to the chemists. If targets are not met, employee performance evaluations may be affected. Using Greenlist™ to Communicate to Consumers. The company has begun to put the Greenlist™ logo on packages of certain products, such as Windex® glass cleaner, to communicate information about its Greenlist™ program to consumers. Only products that have been improved significantly through the Greenlist™ process and meet the strict requirements receive the Greenlist™ logo. S.C. Johnson’s innovative new ingredient communication program includes a dedicated website designed to provide helpful information to consumers. The website can be found at www.whatsinsidescjohnson.com. The Evolution of the Greenlist™ Program When S.C. Johnson first began to use Greenlist™ in 2001, the company approached their suppliers and challenged them to create better rated chemicals. Some suppliers got on board immediately. Others pushed back saying that their environmental, health and safety (EH&S) data are proprietary. Greenlist™ proponents were undeterred. S.C. Johnson began meeting with suppliers to train them on the Greenlist™ process. Initially the focus was on the company’s larger suppliers: Dow, Dupont, and BASF. S.C. Johnson requested input from these suppliers on the process. The training covered the overall structure of Greenlist™ as well as the specific criteria used to score the materials that each company supplied. As Dave Long described,

“We said here’s what we buy from you. These products are mostly 1’s and 2’s. We want 2’s and 3’s. We challenged them to give us better ingredients.” Over time, most suppliers embraced the protocol. Today, S.C. Johnson’s Greenlist™ program has evolved to a point where suppliers are designing new chemicals based on Greenlist™ criteria and pitching their chemicals to S.C. Johnson on the basis of Greenlist™ scores. This development is in large measure a result of S.C. Johnson’s open and clear communication with its suppliers about the specific health and safety performance that it is seeking, as embodied in the Greenlist™ criteria. Greenlist™ Accelerates Green Material Innovation. Greenlist™ is helping to accelerate green material innovation in a number of ways. As described by David Long, “Sometimes a supplier will bring S.C. Johnson a chemical that they say has a Greenlist™ score of 3. S.C. Johnson toxicologists evaluate the product to see if they can confirm the score. If confirmed, company chemists try it to determine whether or not it works. If it’s a 3, and it works, SCJ puts it into the global formulary. If it’s new and different, the company puts the word out that there’s a new raw material that they should try. If a supplier is successful approaching S.C. Johnson in this way, and gets the chemical into use at the company, they stand to gain new business. Alternatively, if they are already supplying a chemical to the company, and can get the company to switch over to a greener product, the supplier avoids the possibility of losing sales to a “greener” competitor.” Daniel Lawson described how S.C. Johnson has given suppliers a target Greenlist™ score as well as price and performance requirements. Some suppliers are using state-of-the-art methods such as combinatorial chemistry and high throughput screening (HTS) techniques to create molecules en masse and rapidly test them for desirable properties. Using these breakthrough technologies, suppliers create 150 to 200 formulations in a matter of hours. They provide mini formulas to S.C. Johnson chemists for performance evaluation. Suppliers too are finding innovative ways to market their green materials to S.C. Johnson. As an example, several suppliers have participated in technical briefing sessions that describe their green products and manufacturing practices at the S.C. Johnson corporate office in Racine. These sessions raise the level of awareness about green products among staff in technical and non-technical business groups at S.C. Johnson such as marketing and procurement. S.C. Johnson is satisfied with the Greenlist™ process. The company encounters little resistance from suppliers

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and is getting better and better chemicals. Even in its most challenging ingredient category—fragrances—S.C. Johnson’s efforts to work with fragrance houses is paying off as more and more fragrances offered by suppliers are in the 2–3 range. The Greenlist™ program is paying off in another way: Competitive advantage. Suppliers know what S.C. Johnson is looking for and they often go to S.C. Johnson first when they have developed new, greener ingredients. For example, S.C. Johnson was one of the first companies Dow approached with their new line of ECOSURF™ ingredients. Dow’s ECOSURF™ product line is a series of biodegradable nonionic surfactants based on seed oil materials. With regard to its existing products, S.C. Johnson has already made significant efforts to improve its formulations to achieve improved performance, cost reductions and higher Greenlist™ scores. Daniel Lawson stated, “low-hanging fruit has long ago been picked for our established products. Any additional improvements made today are only incremental improvements on those reformulated products.” However, there is still substantial opportunity to improve Greenlist™ scores through new product development. S.C. Johnson operates in the fast-moving consumer goods marketplace and the company is constantly developing new products. The company is moving the needle on its corporate Greenlist™ goals by leveraging the product development process, choosing high scoring ingredients for new products. In a recent example, in March of 2009 S.C. Johnson announced that it is working to eliminate all phthalates— a class of chemicals that are of concern to some consumers—from its home cleaning and air products. Phthalates are included in some fragrances that S.C. Johnson sources for its products. Working closely with its fragrance suppliers, the company is leveraging its product development process to develop new and reformulated products with fragrances that do not contain phthalates. In S.C. Johnson’s view, however, not all phthalates are unsafe. The company stated that, “making sure consumers know that they can trust S.C. Johnson products was well worth the time and cost to change them.” Other examples of product reformulation at S.C. Johnson include: • Reformulation of Raid® ant powder worldwide with a new active ingredient to eliminate the use of the 0-rated insecticide propoxur. • Reformulation of the European product Mr. Muscle® Shower Shine® bathroom cleaner with a new cleaning ingredient that provides increased biodegradability — 98 percent in standard tests. • Reformulation of the North American product Windex® glass cleaner to replace a 0-rated solvent, removing 1.8 million pounds of VOCs and increasing cleaning power by 30 percent.

• Reformulation of Pledge® Multi Surface cleaner globally to increase biodegradability and reduce VOCs, while at the same time increasing cleaning power by 30 percent. • Elimination of all PVC packaging and all chlorine bleached paperboard from S.C. Johnson packaging globally. Licensing of Greenlist™ to Other Companies, for Free From its inception, S.C. Johnson has been committed to sharing the Greenlist™ system with other companies, including direct competitors in the consumer products market. In an effort to further encourage its use, in February of 2007 S.C. Johnson announced that Five Winds International was chosen as a third-party administrator to license Greenlist™, royalty free, to other companies. Under the agreement, Five Winds works with companies interested in licensing Greenlist™. The company’s motivation for licensing the system is to provide environmental leadership by helping other companies to measure and reduce the environmental impact of their products. To date, Five Winds has given more than 50 presentations regarding the licensing of Greenlist™. A handful of companies making chemically-intensive products are considering licensing the system, others are interested in piloting it. While the framework for Greenlist™ applies to any company making chemical intensive products, the system needs to be customized to fit other manufacturing environments. To get started with Greenlist™ a company must define functional groups of chemicals and develop scoring criteria. A company with a product mix similar to S.C. Johnson would be required to do less customization. Once set up, the system requires a commitment of time and resources to collect the necessary data from suppliers and to score each individual chemical or formulation. Lessons Learned Getting ingredient lists from suppliers remains a challenge. But, since Greenlist™ does not require chemical lists, it can accommodate different levels of supplier disclosure. Greenlist™ runs on toxicological and other hazard data for the individual chemicals or more complex materials that are supplied to S.C. Johnson; companies are not required to divulge ingredient information if they want to maintain confidentiality. Information on preservatives, contaminants or the presence of unintended byproducts is particularly difficult to obtain from suppliers. S.C. Johnson places importance on limiting these unintended ingredients. Clear and constant communication with suppliers on desired green material attributes yields results. Greenlist™ clearly articulates S.C. Johnson’s criteria for greener materials. The company is extremely proactive in communicating

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its desire for these materials through, for example, supplier training, and has been rewarded for these efforts. S.C. Johnson’s supply base is well aware that by proactively introducing green materials to the company they can either gain new business or they can protect their existing business relationship by offering greener materials. Working in partnership with suppliers helps to accelerate the development of greener materials. Suppliers routinely provide samples of new chemicals to S.C. Johnson chemists for performance evaluations and these chemists can quickly determine whether the new products are effective. The company is currently working closely with fragrance suppliers to develop phthalate-free fragrances for its home cleaning and air products. If product greening is a core product design objective, integrated into the product development process, and easily gauged by product developers, it is more likely to happen. S.C. Johnson designs products for performance, cost and for environmental, health and safety. Greenlist™ is a yardstick that product development chemists can use to easily gauge the relative “greenness” of their proposed formulations, just as they gauge performance and cost with well established metrics. The Greenlist™ score is embedded into the company’s global formulary, the chemical information system used by product developers (though the tool does not replace comprehensive risk and safety assessments). Transparent metrics are essential for measuring and communicating corporate-wide progress toward greening of products. The Greenlist™ framework serves double duty as a metric to measure and communicate progress on greening products. It is a transparent metric that company employees can understand and get behind. Furthermore, it forms the basis of S.C. Johnson’s efforts to communicate to its customers the progress it is making as a company.

Actively engaging in and supporting government efforts to promote safer products has its benefits. S.C. Johnson has had a long-standing cooperative and collaborative relationship with regulatory agencies, particularly the U.S. EPA. The company has been an active partner in the U.S. EPA’s Design for Environment Program’s Formulator Program. This initiative encourages individual companies and industry sectors to compare and improve the performance, human health and environmental profile of products, processes and practices. S.C. Johnson has been publicly recognized for its commitment to formulate its products with environmentally preferable ingredients. In addition, the company has had direct access to the expertise of EPA chemists, environmental scientists and risk reduction staff. — Monica Becker, Monica Becker & Associates Sustainability Consultants and Lowell Center Fellow

Sources Information for this case study was gathered from the following sources: 1 Interviews with Daniel Lawson, Sustainable Innovation Manager— Global Environmental Safety Actions, S.C. Johnson & Son, Inc. and David Long of Environmental Sustainability Solutions, formerly Sustainable Innovation Manager—Global Environmental Safety Actions, S.C. Johnson & Son, Inc. 2 S.C. Johnson website at http://www.scjohnson.com 3 Brian Lavendel, The Greenlist™, S.C. Johnson and Informed Choices for the Environment. Unpublished manuscript, 2003. 4 Five Winds International, Greening the Supply Chain at S. C. Johnson July, 2004. 5 S.C. Johnson, The Value of a System of Stewardship: A Product Stewardship Communication from S. C. Johnson. 2005. 6 S.C. Johnson, Doing What’s Right, Doing Our Part. 2007.

Endnotes 1 http://www.scjohnson.com 2 CAS, or Chemical Abstract Service registry numbers are unique numerical identifiers for chemical elements, compounds, polymers, biological sequences, mixtures and alloys. 3 As defined by the U.S. EPA’s PBT profiler, classifying a chemical as either persistent, bioaccumulative, or toxic

Employee goals help create internal commitment to product greening. Linking performance incentives to measurable improvements in the environmental, health and safety of products has accelerated efforts to green products.

Chemicals, alone or in combination, are the platform upon which key elements of the global economy have been built, and have been incorporated into millions of products used every day. Many chemicals may have inherently harmful characteristics that can impact ecological and human systems as they are used throughout supply chains. A growing number of companies are discovering that the approaches of green chemistry and Design for Environment (DfE) allow for a transition to safer alternatives. The Green Chemistry and Commerce Council provides open conversation about the challenges to and opportunities for this successful transition. The GC3 is a project of the Lowell Center for Sustainable Production at the University of Massachusetts Lowell.

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Managing Chemicals of Concern and Designing Safer Products at Hewlett-Packard Case Study for the Green Chemistry and Commerce Council (GC3)

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ounded in 1939, Hewlett-Packard (HP) is the world’s largest information technology (IT) company with revenue totaling almost $120 billion in fiscal 2008. Headquartered in Palo Alto, California, HP operates in more than 170 countries around the world. The company is organized into three business groups.

1. The Personal Systems Group includes business and consumer PCS, mobile computing devices and workstations, 2. The Imaging and Printing Group includes inkjet and LaserJet technologies, commercial printing, printing suppliers and digital photography, 3. The Technology Solutions Group includes storage devices and servers, EDS, managed services and software. HP has another distinction in the IT world: The company has been a leader in integrating environmental and human health concerns into the design of its products. In this case study, we describe how HP works to ensure that its products are free of toxic chemicals and how the company gathers chemical information from its complex supply chain to support these efforts. HP’s Supply Chain HP has the IT industry’s most extensive supply chain. Over 600 suppliers provide materials and contract manufacturing to produce the more than 1.3 million print cartridges, 110,000 printers, 75,000 PC systems and 3,500 servers shipped daily. HP’s suppliers are located mainly in emerging and developing countries. HP’s supply chain configuration follows a direct procurement model; the company procures from its supply chain all items that are part of the finished product such as raw materials, components and parts. HP has contractual relationships with its first tier suppliers, with all terms and conditions spelled out in a contract between the parties. HP’s

relationships with second, third and higher tier suppliers are indirect, with the expectation that first tier suppliers manage second tier suppliers, and so on. With regard to chemical information, first tier suppliers are expected to obtain information needed by HP from higher tiers, unless HP has a direct relationship with a second or third tier supplier. In an effort to be more transparent about its business practices, the company was the first in the IT sector to take the step of publishing a list of its major suppliers, including commodity suppliers, manufacturers and service providers. This list of 103 major suppliers represents 95% of its procurement worldwide. Design for Environment at Hewlett-Packard In 1992, Hewlett-Packard established a Design for Environment (DfE) program to reduce the environmental impact of its products. The three major elements of the DfE program are energy efficiency, materials innovation and design for recycling. Energy efficiency focuses on reducing the energy used in manufacturing and in product use. Materials innovation is focused on reducing materials use and using materials with less environmental impact and more value at end of life. Design for recyclability is focused on making products that can be easily upgraded or recycled. HP’s product design guidelines include: participation of environmental stewards on each design team; reduce numbers and types of materials; standardize plastic resins; use molded-in colors and finishes instead of paints, coatings, plating where possible; minimize energy requirements in product use; increase use of recycled materials in packaging; use fewer packing materials; and design for disassembly and recyclability by avoiding glues and adhesives where possible and using common fasteners. Hewlett-Packard participated in the development of EPEAT (Electronic Product Environmental Assessment Tool),

Green Chemistry and Commerce Council • 978 -934 -2997 • greenchemistryandcommerce.org


which is designed to help institutional purchasers compare computers, notebooks and monitors based on environmental attributes. EPEAT provides a clear set of performance criteria to encourage manufacturers to design environmentally sound products. Products are rated Gold, Silver, or Bronze according to three tiers of environmental performance. Many of Hewlett-Packard’s products have been scored using EPEAT. Identifying, Prioritizing and Evaluating Chemicals of Concern Beginning in the early 1990’s, Hewlett-Packard began to set goals to restrict a range of substances for certain uses, such as PBB/PBDE flame retardants, ozone depleting substances, cadmium, mercury and lead. The company set a timeline for product materials restriction and substitution and updates milestones annually. HP has succeeded in eliminating many chemicals of concern from its products. However, some of the company’s goals have proven difficult to meet because technically and economically viable alternatives are not yet available. This is the case for remaining uses of brominated flame retardants and PVC for computer cables. The requirements for Hewlett-Packard brand products are specified in their General Specification for the Environment (GSE) standard. This standard includes a list of restricted materials, requirements for packaging and requirements for products subject to the European Union’s RoHS Directive. These specifications are for all HP brand products including subassemblies, parts, materials, components, batteries and packaging that become part of HP brand products. The GSE is included in supplier contracts as part of standard terms and conditions. The restricted materials listed in the GSE are mostly regulated chemicals, though some, such as PVC, have been included because of stakeholder and environmental, health and safety concerns. The GSE is updated annually. Hewlett-Packard has formed a team that meets bi-monthly to identify emerging regulations as well as chemicals of concern that may have been identified by stakeholders outside the regulatory process. HP has added chemicals to the GSE with a future effective date to give suppliers time to comply. For example, the company is planning to add three phthalates to the GSE, which will be restricted as of 2012. These chemicals are likely to be added to an expanded list of restricted chemicals under the EU’s RoHS1 Directive. Hewlett-Packard is working to develop a method to screen chemicals of concern and compare these to alternatives that have been identified. The company wants to ensure that replacement substances have improved environmental and health profiles. This screening process will evaluate both the inherent hazard of chemicals and potential exposure routes.

Materials Restricted From HP Products • Asbestos • Cd, Hg, Pb in batteries • Brominated flame retardants (BFRs)— PBBs, PBDEs including DecaBDE • BFRs including TBBB-A in external case plastic parts of products • Cadmium * • Certain azo colorants • Chlorinated hydrocarbons • Chlorinated paraffins • Formaldehyde • Halogenated diphenyl methanes • Hexavalent chromium • Lead * • Mercury • Nickel • Ozone depleting substances • Perfluorooctane sulfonates * • PCBs and PCTs • Polychlorinated naphthalenes • Polycyclic aromatic hydrocarbons (PAH) • PVC (in external case or packaging) • Radioactive substances • Tributyl and triphenyl tin and tributyl tin oxide * exemptions apply

Collecting chemical data and communicating with the supply chain HP requires chemical data for many programs including regulatory compliance under the European Union’s REACH2 and RoHS Directives and other requirements specified in its GSE for development of MSDS’s and green certification programs such as EPEAT and Blue Angel. At this point in time, Hewlett Packard does not ask for 100% disclosure of materials composition, but rather, focuses on collecting data on chemicals of concern in parts, components or products. REACH Chemical Reporting. Under the EU’s REACH Directive, HP must provide information to consumers on the presence of Substances of Very High Concern (SVHC) in specific products. HP’s suppliers are required to provide information on the weight in grams of substances listed on the current3 Annex XIV candidate list of chemicals.4 Suppliers are given the option to indicate where the substances are used in the

Green Chemistry and Commerce Council • 978-934-2997 • greenchemistryandcommerce.org • page 2


product. These data are consolidated by Hewlett-Packard and used to prepare reports required under Article 33 of REACH.5 In addition to the Annex XIV chemicals, HP requests information from its suppliers on approximately 240 additional chemicals. This voluntary reporting list was narrowed from the 67/548/EEC (as amended) Annex 1, as well as other chemical regulatory lists that contain substances meeting the SVHC criteria, such as the Stockholm Convention (POP list) and the Rotterdam Convention (PIC list) list. It includes carcinogens, mutagens, reproductive toxins (CMRs), persistent, bioaccumulative and toxic chemicals (PBTs), and endocrine disruptors that HP determined as possibly used in electronics products. Suppliers are not required to report on these chemicals, but many companies do, and these data provide HP with information on where these chemicals are used in their supply chain should they become restricted in the future. Suppliers must enter the required data on the 15 SVHC chemicals and 240 additional chemicals directly into HP’s web-based supplier portal. Suppliers can also opt to send data via a customized form. The request for voluntary reporting on a larger universe of chemicals has had mixed results. Some suppliers do report on the entire list; some report only on the 15 mandatory SVHC chemicals on the Annex XIV list. Overall, HP interviewees stated that they received more information than they initially anticipated. Some of HP’s first tier suppliers have had difficulty getting chemical information from their second and higher tier suppliers, particularly if those suppliers are small. Interviewees noted that some smaller suppliers find REACH requirements challenging to fulfill without a sophisticated system for data collection and reporting. HP has worked with some of these companies to help them provide the data needed. Cultural and language differences have acted as a barrier to getting chemical data in some cases. Section 5 of the GSE describes chemical substance requirements for suppliers and applies to substances that are currently regulated or under consideration for regulation. This section was written to allow Hewlett-Packard to collect data from suppliers on a chemical that may be newly recognized as being of concern, including information on health or environmental hazards, requirements for safe use and packaging or labeling issues. RoHS Reporting. As an electronics product manufacturer, HP must ensure that its products are in compliance with the EU’s Restriction on Hazardous Substances (RoHS) Directive. HP requires its suppliers to provide chemical data and material or component testing upon request. Suppliers must sign a letter of RoHS compliance and submit it to HP.

Verification of chemical data. Hewlett-Packard uses what they call an “active verification” process to ensure that suppliers and HP products are in compliance with the requirements of the GSE. There are four levels to verifying compliance. Level 1—Suppliers must submit a signed letter as verification of RoHS compliance. Level 2—Based on HP’s long standing Supply Chain Social and Environmental Responsibility program,6 HP works with suppliers on a corrective action plan to correct deficiencies. Level 3—Hewlett-Packard reviews information provided by suppliers and asks them to provide additional information such as analytical test results, as needed. Level 4—Hewlett-Packard business units determine whether to initiate additional analytical testing. HP-initiated testing enables the company to react quickly if a problem arises. Lessons Learned • Obtaining chemical information from suppliers remains a challenge. The difficulty lies in a number of factors, including: language and cultural barriers; difficulty faced by Tier 1 suppliers in getting information from Tier 2 and higher suppliers; system and process sophistication level; supply chain complexity level; and unclear requirements for information under regulatory or green procurement programs. • Providing an easy-to-use web-based portal for chemical data entry has facilitated data collection. This system was developed internally by HP and uses the company’s SAP/Environmental Health and Safety module to process the data. • Training of suppliers can assist in clarifying requirements for data collection. HP has reached out directly to Tier 2 suppliers to clarify data requirements. • Collecting data on chemicals that are of emerging concern is valuable. By asking suppliers to provide data on 240 additional chemicals that may be of concern in electronics, HP is building a database that points to where they occur in the supply chain. This will facilitate future efforts by HP to restrict those chemicals, either because of new regulation or a corporate decision, and to work with suppliers to find safer substitutes. • Patchwork of global chemical regulatory systems is inefficient and detracts from more proactive design for environment activities. In HP’s view, there is a lack of regulatory harmonization across regions and within some countries. Managing the proliferation of variations

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to existing regulations, such as RoHS, can take considerable effort even when the same set of substances is restricted. Interviewees stated that harmonization of regulations would allow this global company to more efficiently track and conduct regulatory compliance programs, freeing up resources to advance green chemistry and Design for Environment opportunities. — Monica Becker, Monica Becker & Associates Sustainability Consultants and Lowell Center Fellow and Sally Edwards, Research Associate, Lowell Center for Sustainable Production

Sources Information for this case study was gathered from the following sources: 1 Interviews with Hewlett-Packard personnel. 2 www.hp.com

Endnotes 1 RoHS, or Restriction of Hazardous Substances (2002/95/EC) is an EU Directive restricting the use of hazardous substances in electrical and electric equipment. 2 REACH, or Registration, Evaluation, Authorization and Restriction of Chemicals (Regulation (EC) No 1907/2006 of the European Parliament and of the Council of 18 December 2006), is a new European Union law addressing the production and use of chemical substances and their potential impacts on both human health and the environment. REACH replaces numerous EU laws related to chemicals. 3 Current as of June 1, 2009. 4 The list can be viewed at http://echa.europa.eu/chem_data/candidate_ list_table_en.asp 5 See for example http://www.hp.com/hpinfo/globalcitizenship/environment/ productdata/reachdesktop-pc.html?jumpid=reg_R1002_USEN 6 http://www.hp.com/hpinfo/globalcitizenship/supplychain/compliance.html

Chemicals, alone or in combination, are the platform upon which key elements of the global economy have been built, and have been incorporated into millions of products used every day. Many chemicals may have inherently harmful characteristics that can impact ecological and human systems as they are used throughout supply chains. A growing number of companies are discovering that the approaches of green chemistry and Design for Environment (DfE) allow for a transition to safer alternatives. The Green Chemistry and Commerce Council provides open conversation about the challenges to and opportunities for this successful transition. The GC3 is a project of the Lowell Center for Sustainable Production at the University of Massachusetts Lowell.

Green Chemistry and Commerce Council • 978-934-2997 • greenchemistryandcommerce.org

Gathering Chemical Information and Advancing Safer Chemistry in Complex  

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