Mandatory planning for substitution

Any company using a chemicai that requires authorisation shouid be required to provide a Substitution Plan, namely an assessment of available substitutes. This should include a full description of the aiternatives available, a comparative assessment of their intrinsic hazards and an assessment of technicai feasibiiity. This substitution assessment would form the basis of a justification of why an intrinsically less hazardous alternative cannot be used to replace the substance of high concern. The Substitution Assessment Pian shouid be transparent as to the methods and data used 

Costs of alternatives may initiaiiy be higherthan continued use of a chemical of very high concern, but increased demand for the alternative will drive costs down, particularly as competition increases among producers to supply the new market demand. Chemical producers will in turn find an expanded market for Green Chemistry products. 

Making companies prepare plans which focus on safer chemical use has proved particularly successful in the USA. The benefits of mandatory pollution prevention planning have been demonstrated in the state of Massachusetts. Here, over 550 companies had to assess toxic use reduction options with technical help supplied by university and government experts. Toxic use reduction strategies included material substitution and product reformulation. Within ten years, industry has reduced the use of toxic chemicals by 40%, by-product waste by 58% and toxic emissions by 80%. A cost benefit analysis reveals that the same companies saved a total of Saved a total of USD 14 million (Euro 18.76 million) overthis period through the adoption of more efficient and safer processes. The programme is ongoing and has been expanded to community outreach and assessment of substitutes forsome hazardous material flows and products within the state. 

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