Author Archives: Chris Jellen

Informational Matrix of Tools for Green Chemistry

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Looking for tools to evaluate chemical ingredients in products — for greener chemistry, safer products, a healthier workplace and a more viable supply chain?  Recently GC3 designed and published a matrix of tools for green chemistry and an attendant summary document.

Use the matrix here:  portal database

Some tools listed are free, some are not.  In these matters you typically get what you pay for, but what you want to pay for depends on how big your supply network is and what your sustainability goals are from a product risk management and brand management point of view.

The Green Chemistry and Commerce Council (GC3) is out of the University of Massachusetts, Lowell.  It bills itself as a business-to-business forum that advances the application of green chemistry and design for environment across supply chains.

GC3 has realized, rightly, that many businesses lack the resources to educate themselves about the tools and systems available for managing greener chemistry.  The matrix at the link above will help businesses educate themselves about the choices in tools for evaluating chemical ingredients.  Use it, the matrix is free.

Data safer in the cloud?  Increasing regulatory requirements and consumer and media pressure to sell safer or “green” products are driving retailers to understand more about the chemical ingredients in the products they sell and to find safer alternatives to chemicals of concern. Some retailers are developing their own tools or systems to evaluate the chemical content of the products they buy and sell, which is an arguably short-sighted approach because it lends significant problems with lack of standardization of data, ergo inability or extreme difficulty with reporting and for suppliers who have to add resources to distribute the data.  The alternative is to work with developers of 3rd party evaluation systems to develop customized tools, and others are working collaboratively to develop tools useful to a whole industry sector.

Some think that keeping data “in-house” is safer, but company “proprietary” data is just as easy to hack as is data in the cloud, or data hosted elsewhere.  Viruses and malware occur more often in in-house systems. And data losses are more common (and expensive) in on-premises systems.  So the data-is-safer-in-house point is mute.

In fact, an Aberdeen study recently revealed that data are actually safer in the cloud.  Which means you have more choices, is all; you are no longer tied to your IT team, their capabilities, legacies, politics and budget.  Be free!

Chemical ingredient tool matrix  GC3 says that the tools included in the matrix are either free or commercially available and enable retailers to evaluate chemicals or chemical-containing products for their potential human health and environmental impacts and identify chemicals or materials that are regulated or are of concern and not yet regulated.

Most of the evaluative systems go beyond ensuring compliance with existing environmental regulations and provide additional information to retailers and manufacturers whose goal is to “green” their product lines by selling chemicals and chemical-containing products that are safer throughout the supply chain.

ECHA’s New Website Is Good But Not Perfect

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The European Chemicals Agency (ECHA) has finally updated its website for a more user-friendly, intuitive and let’s call it what it is: functional user experience.

The new site is easier to use, for sure.  The site still errs on the side of delivering editorials about REACH and related topics rather than providing the tools we need to execute tasks (it’s very European to want to talk more about it, while Americans want to get right to the action).

So if you’re looking for the Substance of Very High Concern (SVHC) candidate list — you’ll find a lot of pages talking about the list but you’ll pull your hair out trying to get to the list itself.  The list is here:  http://echa.europa.eu/web/guest/candidate-list-table

Tip: Google is a quicker way to find tables, tools and lists on the site rather than using the ECHA search box.  Search for “ECHA Candidate List” on both Google and ECHA — and you’ll agree.

12 new SVHCs  ECHA says committees have unanimously agreed to add 12 new chemicals of very high concern to that candidate list, so you’ll want to know where to find it.  Today, the list stands at 53 SVHCs today, also kept up to date at websites besides ECHA’s.

Overall, people will appreciate the improvements.  It’s getting better all the time, as the Beatles said.

EPA Publishes More Confidential Business Info

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Last June, EPA removed confidentiality protection for more than 150 chemicals. EPA’s declassification trend toward substance-level material disclosure is similar to the culture around chemical information in Europe under REACH and RoHS.

On Nov. 28, the agency announced the public availability of hundreds of studies on chemicals that had previously been treated as confidential business information (CBI). EPA says that over the next year the agency expects to review several thousand additional studies on industrial chemicals and make many reviews accessible to the public.

Releasing the data, says EPA, will expand the public’s access to critical health and safety information on chemicals that are manufactured and processed in the U.S.  Newly available information can be found using EPA’s Chemical Data Access Tool.

Since 2009, “What’s in your product?” is a question with over 500 answers available now that were previously unavailable. Some 577 formerly confidential chemical identities are no longer confidential and more than 1,000 health and safety studies are now accessible to the public that were previously unavailable or only available in limited circumstances. In 2010 EPA issued new guidance outlining the agency’s plans to deny confidentiality claims for chemical identities in health and safety studies under the federal Toxic Substances Control Act (TSCA) that are determined to not be entitled to CBI status. EPA has been reviewing CBI claims in new and existing TSCA filings containing health and safety studies.

“EPA is increasing the availability of critical health and safety studies on chemicals that children and families are exposed to every day. We are making important progress in making this information public and giving the American public easy access to it,” said Steve Owens, assistant administrator for EPA’s Office of Chemical Safety and Pollution Prevention.

For additional information, please visit: www.epa.gov/oppt/existingchemicals/pubs/transparency.html

The Genius of Apple’s Supply Chain

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A massive competitive advantage for Apple is its operations function. Specifically, its supply chain operations. Apple has a regimented core business vision — built around their supply chain.

“They have a very unified strategy, and every part of their business is aligned around that strategy,” said Matthew Davis, a supply-chain analyst with Gartner (IT), who has ranked Apple as the world’s best supply chain for the last four years, as quoted by Bloomberg/BusinessWeek in a recent story on same.

It’s well known that recently Google paid $12 billion for Motorola’s cultivated, global supply chain. That fact, combined with observations about the genius of Apple’s supply chain — genius which is apparently 90% perspiration and 10% inspiration, by the way — make it clearer why a supply line could be worth so much money.

This is the world of manufacturing, procurement, and logistics in which the new chief executive officer, Tim Cook, excelled, earning him the trust of Steve Jobs. According to more than a dozen interviews with former employees, executives at suppliers, and management experts familiar with the company’s operations, Apple has built a closed ecosystem where it exerts control over nearly every piece of the supply chain, from design to retail store. Because of its volume—and its occasional ruthlessness—Apple gets big discounts on parts, manufacturing capacity, and air freight. — Adam Satariano and Peter Burrows, reporters for Bloomberg

The bottom line, according to Satariano and Burrows, is that Apple plans to double spending on its supply chain, to $7.1 billion — continuing its focus on streamlining and controlling manufacturing.

Relative to Google’s $12 billion to procure part of a new one, once again it seems to make financial sense to invest in current accounts rather than invest in new.

Excellent article on Apple’s supply chain can be found here.

HazMat: An App For That

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The US Department of Homeland Security (DHS) last week demonstrated a cellphone that can detect life-threatening chemical exposures.

The device works using sensor technology made very small — but effective enough to detect, say, dangerous levels of carbon monoxide.

I was walking with my sister recently alongside her residence in Exeter, New Hampshire.  Suddenly, we thought we smelled propane.  We sniffed in widening circles for a while — not long enough to be taken away, but long enough to look silly and realize we had imagined it.

Or had we?  It’s times like those where a device is nice, or an app for your cell phone, that could solve the problem and eliminate doubt.  Such an instant detection device would curb danger to ones you care about — or ones you are are tasked with rescuing, as with a Fire or Rescue team.  In fact, Fire Chief magazine did a nice write-up about this new device.

And with that, we welcome this new device, the DHS “Cell-All,” as it’s called.  “Cell-All” is a play on the words, “Tell-All,” for those who didn’t get it at first, like me.

A spokesperson for the device said, “Cell-All detects and alerts individuals and public-safety authorities to the release of specific toxic chemicals into the environment, putting environmental threat detection within reach of anyone who has a cell phone.”

Stephen Dennis, Cell-All’s program manager, envisions a chemical sensor in every cell phone in every pocket, purse, or belt holster.

With over 85,000 unique chemicals flying around the world now in various forms and interactions, this gadget stands to revolutionize HazMat safety, and offers another level of security for those of us with propane heat and active imaginations.

Read more here.

How to Get the EPA DfE Label

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The US Environmental Protection Agency’s program that reviews, recognizes and labels (effectively certifying) best-in-class wet chemical-based formulations and products is known as the Design for Environment or DfE Program.  See bottom of this post for an overview of DfE*.

So how does a product qualify for a DfE label? By being made of the safest known ingredients.

If you’d like a DfE label for your product, EPA reviews your formula.  They’re looking at each ingredient in a formulation in its distinct functional class, whether surfactant, solvent, etc.

There are two qualified third-party profilers for DfE: NSF, International and ToxServices, LLC.  Contact either entity directly to get started.

Reviewing your ingredients for DfE label. The reviewers then compare toxicity and environmental fate profiles to identify safest known ingredients for man, beast and world.  The safest ones get the DfE label.  Sounds simple enough, right?  Truth is, many get snagged on the chemical disclosure part of the process, either because of reluctance to disclose chemicals or — surprisingly often — due to lack of organized data on the ingredients in formulas.

As an industry example, EPA’s DfE Program entered into a voluntary partnership with representatives of the electronics industry to evaluate the environmental impacts of tin-lead and lead-free solders.  The idea was to address the information gap on the environmental impacts of leaded and lead-free solders.  The list of EPA’s lead-free solder partners includes Hewlett-Packard, IBM, Intel and Cookson Electronics.

This type of partnership can work across industries.

Know your DfE entity. For background and context, review EPA documents on the subject such as “When you see the DfE label on a product, what does it mean?” If you’re a cleaning product manufacturer, read over “Standard for Safer Cleaning Products (SSCP)” (PDF) (31pp, 177K) and the Standards for Safer Ingredients to get a sense of program goals, framework, criteria, and to determine if your product may qualify to bear the DfE label. For manufacturers of other products, read DfE’s “Discriminating and Protective Approach to Product Review and Recognition” (PDF) (12pp, 160K) which includes the DfE criteria in matrix format.

(Note, with respect to Step 3, that DfE has not yet developed a component class screen for active ingredients in pesticide products.)

Profile formulation ingredients for DfE. Applications for partnership must include a full disclosure of all ingredients and ingredient profiles.

A profile is a compilation of all hazard information available on a chemical and includes:

  1. detailed structure
  2. physical-chemical properties
  3. human health and environmental toxicology
  4. regulatory/administrative status

To be able to work with all of the companies that request partnership, DfE retains third-party profilers. Qualified third-party profilers have the expertise and objectivity needed to ensure a quality review, with high confidence in the accuracy and reliability of the profile information. NSF, International and ToxServices, LLC are qualified third-party profilers for DfE. 

Assessing ingredients and identifying safer alternatives. After third-party profiling, DfE assesses potential health and environmental effects of each ingredient in your formulation and may identify areas for improvement, safer alternatives, or additional information needs.

In the context of its functional class, DfE evaluates each ingredient in a formulation based on critical health and environmental endpoints.

Functional-class criteria define and more fully explore the safer end of specific ingredient-class continuums. Using the Master Criteria as a guide, the functional-class criteria tailor the health and environmental endpoints in the Master Criteria in a way appropriate to the specific functional class, designate key distinguishing characteristics and adjust thresholds as necessary. Developing the Criteria improves the general understanding of the characteristics of safer ingredients in the class and helps identify green-chemistry opportunities and successes.

The DfE functional class context allows DfE to view ingredients as part of a continuum of improved ingredient choices. Functional Class standards define and more fully explore the green end of specific ingredient-class continuums. DfE has issued three functional-class standards:

  1. the DfE Standard for Solvents
  2. the DfE Standard for Surfactants
  3. the DfE Standard for Fragrances (Human Health)

and is currently developing standards for fragrances (environmental toxicity and fate) and additional functional-use classes in partnership with broad stakeholder workgroups. Additionally, there are specific environmental toxicity and fate standards for ingredients used in direct release products (products that are used outside and do not go through sewage treatment).

Flowchart courtesy of EPA’s Design for Environment program or DfE

DfE is along the lines of Green Chemistry — focusing on full, positive material declaration for safer products throughout their lifecycle and beyond.

*The Design for the Environment (DfE) label is an EPA effort to enable consumers to quickly identify and choose products that can help protect the environment and are safer for families.  The label indicates that the DfE scientific review team has screened each ingredient for potential human health and environmental effects and that—based on currently available information, EPA predictive models, and expert judgment—the product contains only those ingredients that pose the least concern among chemicals in their class.

EPA’s Design for the Environment Program (DfE) has allowed use of the logo on over 2000 products. These products are formulated from the safest possible ingredients and EPA says they have collectively reduced the use of “chemicals of concern” by hundreds of millions of pounds.

The label has the look, look for the label, the label looks like this:

Hope this was informative.  You may email me privately with your thoughts.

EPA Finds More Time for Glymes

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There’s now an extension of time allotted for comments on glymes.

In July, the US Environmental Protection Agency (EPA) issued a proposed rule in the Federal Register concerning a proposed significant new use rule (SNUR) under section 5(a)(2) of the Toxic Substances Control Act (TSCA) for 14 glymes.

EPA’s list of 14 glymes is here for view or download, in an article written by one of the preeminent Professional Chemical Engineers in the field, Kal Kawar.  The article is called “The Worst of Glymes” (who says chemists can’t be funny?).  This list is easier to read than anything on the EPA site.

Since publication of the proposed rule, EPA has received a request for additional time to submit comments. Now, EPA will extend the comment period for 30 days, from September 12, 2011 to October 12, 2011.

Deadlines for comment: Comments, identified by docket identification (ID) number EPA–HQ–OPPT–2009–0767, must be received on or before October 12, 2011.

In the Federal Register of July 12, 2011 (76 FR 40850) (FRL–8877–8), EPA proposed a SNUR for 14 glymes, designated proposed significant new uses for the 14 glymes, and asked for public comment on several topics. EPA requested comment on whether any of the chemical substances included in the identified glyme category are sufficiently dissimilar from the rest such that they should be removed from the category, or whether any additional chemical substances are sufficiently similar such that they should be added to the category. Comments were also requested on whether any of the additional unconfirmed uses listed in the proposed rule are actual ongoing uses in a consumer product, and whether there are any other ongoing uses in a consumer product of the other chemicals listed in the SNUR.

For further information, see the contact names in the Federal Register here.

Tin Liability: Careless Whiskers and Toyota Acceleration

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A failure mode is reemerging that has been responsible for the loss of billions of dollars worth of satellites, missiles and other equipment — the culprit is the electrically conductive entities known as ‘tin whiskers’.  Now one research group says that tin whiskers may be responsible for the sudden acceleration in Toyota Camry models from the year 2002 and possibly beyond.

Earlier this year we reported that the US Department of Transportation (DOT) said that Toyota’s problem was not in electronics.

Now, University of Maryland’s Center for Advanced Life Cycle Engineering or CALCE researchers have found the potential for tin whiskers in the electronic control module or ECM.  Circuits Assembly broke the story, quoting the CALCE report as follows:

“The ECM contains surface mount electronic devices connected with tin-lead solder to a multilayer PCB. … Interconnect terminals of the perimeter leaded devices were found to be plated with tin. In addition, tin plating was found on terminal pins of the edge connections. As previously discussed, tin-finished leads can grow tin whiskers which can lead to unintended electrical shorts.”

“We know whiskers can form on tin finished terminals,” said Michael Osterman, senior research scientist and director of the CALCE Electronic Products and System Consortium. said.  “In this case, Toyota has tin plating in a rather sensitive area, where the system relies on changes in resistance to provide a signal for acceleration.”

The studied pedals furthermore have been shown to cause shorts known to spur sudden unintended acceleration.

The odds of tin whiskers: 140/million. Someone known to this blogger recently drove a 2010 Camry and noticed subtle but perceptible decelerations that were not led by the driver. Was it tin whiskering?  Hard to say, even CALCE’s study figures that the whiskers would only form in 140 cars per million, which is statistically very significant but als makes it statistically unlikely that my friend’s only Camry experience would be on the wrong side of those odds.

It’s also worth noting that the whisker syndrome is probably not limited to Toyotas.  Nonetheless, the spotlight has fallen where it has fallen, and tin whiskers pose a serious problem in that warrants attention.

Tin whiskers. Tin whiskers develop — or may develop — on any product type that uses lead-free pure tin coatings.  Thus, in greener, lead-free products, tin whiskers can pose a major safety, reliability and potential liability threats to all makers and users of high reliability electronics and associated hardware. The CALCE brain trust concluded that existing approaches are not sufficient to control tin whiskering in high-reliability systems such as automobile electrical systems.

US Secretary of Transportation said Toyota is “all clear” in February. The official blog of the US Secretary of Transportation on February 8, 2011 stated:

NASA engineers pored over more than 280,000 lines of software code looking for potential flaws that could initiate an unintended acceleration incident. Alongside NHTSA, they bombarded vehicles with electromagnetic radiation to see whether it could make electronics systems cause the cars they control to gain speed.

And today, their verdict is in. There is no electronic cause behind dangerous unintended acceleration incidents in Toyotas.

To read more about it: http://supply-chain-data-mgmt.blogspot.com/2011/02/us-dot-says-toyota-problem-was-not-in.html

We will continue to follow this story.

Carbon Disclosure, Meet Plastics Disclosure

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Environmental Leader and the New York Times are reporting that hundreds of companies and institutions should expect to receive a questionnaire in early October about their use of plastic. The Plastic Disclosure Project, right ahead.

Why?

Industry estimates state that 300 million tons of virgin plastic are made every year. If just one percent can be saved through efficiencies, better design, or increased recycling, then 3 million tons could be saved, which is roughly what some conservative estimates say are floating in the middle of the Pacific Ocean. -Plastics Disclosure Project (PDP)

Some companies have already made progress in better managing plastics.  Electrolux, the Swedish appliance maker, for example, introduced a range of vacuum cleaners in February that are made from recycled plastic. Coca-Cola has devised a plastic bottle that contains some plant-based materials, a small step for which the soda company seems to be wringing significant PR traction.

Most interestingly perhaps, as the New York Times points out, Procter&Gamble has the long-term aim of using 100% recycled or renewable material in its products and packaging.

Better managed plastics appeals to some of us as a resource-saver if nothing else — for too long we’ve treated plastic as an almost-infinite supply of cheap material, both raw and article.

Remember the Carbon Disclosure Project — which is not gone but currently forgotten?  Well, this plastics program seeks to inspire organizations to approach plastic consumption in much the same way as we’ve begun to approach carbon consumption:  more awareness, some conservation.  Fair enough.

Targeted big users of plastic include:

  • companies
  • universities
  • hospitals
  • sports groups

This October, the plastics questionnaire will ask organizations to report how much plastic they use and how they recycle.  Further, organizations will be asked what policies they have to:

  • reduce consumption
  • increase recycling
  • increase the use of biodegradable plastic

Plastic Disclosure blog is here, if interested.

What is Product Stewardship, Exactly?

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What does product stewardship mean in the business world, exactly? Sometimes it seems to indicate product end-of-life measures, specifically regarding electronics or e-waste policy. Sometimes it is defined as a person to make sure a product is RoHS compliant or otherwise is clean of toxic chemicals such as lead, cadmium and mercury.  Other times it seems to mean a more Sustainability Manager type of role. The fact is that product stewardship can contain all these things and more.

We recently came upon this job description for a Product Stewardship position. We’re running it here to show specific job requirements.

Product stewardship job description. DuPont defines product stewardship as “a principle that directs all participants involved in the life cycle of a product to take shared responsibility for the impacts to human health and the natural environment that result from the production, use, and end-of-life management of the product.”

DuPont, for instance, and this is not atypical, approaches product stewardship through the American Chemistry Council’s Responsible Care program. DuPont sees product stewardship as an “inclusive effort that considers the interests of all important stakeholders, including customers, regulators, academics and advocacy groups.”

Product stewardship software. Product stewardship software is more or less a “steroid infused” chemical counter — or substance audit platform — with the added twist of:

  1. Automating chemical data collection from suppliers.
  2. Screening materials and B.O.M.s against regulatory lists vis a vis REACH, RoHS, WEEE, Prop 65.
  3. Functions such as MSDS distribution.
  4. Other document and agency reporting management.

Increasingly, product stewardship personnel is required to have expertise with related software, just as Finance Administrators are required to have familiarity with financial systems.

DuPont’s Product Stewardship Job Description
DuPont says its vision is to be world class in Product Stewardship and Regulatory efforts and to be recognized as a key contributor to DuPont business success through the development and management of safe, sustainable products.

The average product stewardship annual salary is said to be around $85,000 by Glassdoor.com, but if the regulatory compliance piece is taken seriously it is often higher, into the low six figures. The salaries are respectable relative to other “fields of green,” but there is still some insecurity around how long companies will nurture the stewardship side of manufacturing — so the tenure of these positions, like the tenure of so many positions these days, is indeed a question mark.

Product Stewardship Focus Areas and Responsibilities

  1. Provide a variety of consulting services to the businesses in areas such as the determination of product misuse, product safety, health hazards and potential environmental impacts. Other areas may include advising the businesses on appropriate labeling requirements; facilitating the auditing process at toller, manufacturer and other partner locations and the analysis of public perceptions and reactions to the businesses products.
  2. May oversee implementation of the Responsible Care Management System and Corporate Product Stewardship standards.
  3. May obtain, organize and assemble data and information from various internal personnel, databases, external sources, etc. to enable global regulatory submissions.
  4. Understanding regulatory requirements and the purpose of submissions to ensure compliance with national and state submission requirements.
  5. May Prepare forms, letters, labels and other documents necessary for regulatory submissions.
  6. May develop MSDSs that comply with local standards.
  7. Assisting in the preparation of responses to inquiries from regulatory agencies, customers, internal DuPont personnel, and others.
  8. Assisting in the management of products and/or regulatory projects, including the independent management of sub-projects.
  9. Monitors and analyzes regulatory trends and positions of industry and stakeholder groups.

Job Requirements

  1. Strong networking and leadership skills.
  2. Chemistry, Biology, Science, Public Health, Occupational Health, Toxicology, Environmental Science degrees preferred.
  3. Outstanding problem solving, analytical and interpersonal skills.
  4. Excellent writing/verbal communication and presentation skills.
  5. Accomplished computer skills including Microsoft office and applications and database experience.
  6. Strong work ethic and the ability to work in cross-functional teams to deliver concrete project deliverables in a timely manner.

DuPont says it is an equal opportunity employer, and as of now this job is posted here but these posting come and go so don’t be surprised if the link is broken. We’re not in DuPont’s HR department; we just want to illustrate what product stewardship looks like.