HAZMAT Raw Materials' Substitutions in the Chemical Industry

Introduction
As chemical R&D teams and manufacturing facilities take steps to reduce the potential for chemical hazards to occur by replacing substances of very high concern, collaboration among regulators, chemists, and engineers is required.
WHITE PAPER
Development process from regulatory pressure.
R&D Solutions for Chemicals
The Inevitability of Chemical Substitution





"With substitution rising in necessity for many facilities,

these guidelines aim to direct the implementation so that it is conducted safely and effectively."
　




Executive Summary
In situations in which hazardous chemicals can be replaced by potentially less dangerous compounds, it’s only logical to avoid hazardous chemicals as much as is practical, and replace them with chemicals as different as possible from the originals. In fact, chemical substitution is an essential good laboratory practice (GLP) in labs around the world, and it is a cornerstone of basic occupational safety.




Substitution is an especially crucial measure when the chemicals involved are known to cause cancer, trigger allergic reactions, damage nerve tissue, or induce reproductive harm over the long or short term. While less dangerous chemicals

may still require the use of protective equipment and safety procedures,

the overall reduction in hazard is well worth any organizational and technical alterations necessary to achieve it.
　
In fact, increasingly stringent regulations make chemical substitution not only a rational practicality, but an inevitability. Even so, many facilities struggle to put these concepts into action, although administrators recognize how essential they are.




To reduce the challenges of chemical substitution, the chemicals should be assessed to decide whether substitution is a worthwhile process for that specific facility. Laboratories can then proceed

with the implementation by reviewing the hazard and risk inherent in substitution. Throughout these steps, it is important

to remember that collaboration between R&D teams with plant managers is necessary for the long-term aims of the chemical industry. With substitution rising in necessity for many facilities, these guidelines aim to direct the implementation so that it is conducted safely and effectively.
　

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I. Substitution will become increasingly unavoidable as regulation increases
Laboratories and other chemical facilities control chemical-related risk in a

wide variety of ways. They may isolate dangerous chemicals, enclose them in contained sub-environments, provide systems for air filtration and removal of hazardous fumes, sterilize and safety- check equipment, mandate specific handling procedures, and require all workers to wear protective gear. In fact, many of these GLPs are now explicitly required by regulatory bodies around the world, including the U.S. Food and Drug Administration (FDA).




However, the only way to entirely remove the risk of a chemical hazard is to eliminate that chemical altogether. The most obvious reason to replace hazardous chemicals with less hazardous ones is

to remove or reduce the likelihood of
　
workers’ exposure to toxic or otherwise dangerous substances. Although the

risk of a hazard does not always result in actual harm, the presence of chemicals known to cause damage to human health is still a cause for serious concern in any laboratory environment, especially when safer alternatives are available.




Equally importantly, the likelihood is high that the pressure to substitute hazardous chemicals will continue to increase

as regulation tightens. The European Chemicals Agency (ECHA) has already outlined a list of active chemicals which are candidates for substitution in order to ensure that substances hazardous

to health and/or the environment

are phased out and replaced by more suitable alternatives over time. Agencies around the world are likely to follow suit, further emphasizing the inevitability of substitution within the coming years.
　
II. R&D labs can respond by selecting chemical products with greater care
The mere act of substituting another chemical for a hazardous one does not necessarily guarantee that the hazard has been eliminated. Some alternative chemicals may
actually be more hazardous than the originals. Others may initially appear to offer a reduced risk of hazard while heightening risk in certain stages of the production process. Still, others may seem to offer no hazard at all, but they reduce the effectiveness of the final formulation.
For all of these reasons, it’s crucial to examine the material safety data sheet (SDS) and other documentation on any chemical under consideration. This allows for a comparison of the value of a chemical substitution in the following five key areas:
1. Effectiveness: Will the substitute chemical maintain the same quality in the end product after being subjected to all steps in the manufacturing process?
2. Compatibility: Will the substitute react as needed with other compounds in the process without interfering with any reaction?
3. Existing control measures: Can the substitute be controlled using existing safety measures, or will new measures need to be drawn up to control vapors or other by products?
4. Waste disposal: Can the substitute be disposed of through an existing disposal system without compromising regulatory compliance?
5. Hazard assessment: Will the substitute produce risky reactions or byproducts not produced by the original chemical?
　

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III. Manufacturing plants can respond by proactively identifying and eliminating risks
Any decision about re-engineering a chemical manufacturing process may have to take place from the company or on a branch level. Such a decision involves intensive examination, risk analysis, process analysis, and consideration of possible substitutes.
To help guide this type of decision procedure, the Health and Safety Executive (HSE) of the United Kingdom has outlined a seven-step process for preparing to implement chemical substitutions. The steps are as follows:
　
Identify hazards and assess risks: Take note of potentially hazardous chemicals currently stored and/or used on-site, and calculate the likelihood of a hazard resulting from continued usage with each of them.
Identify alternatives: Examine safety data sheets and other documentation on possible substitute chemicals to be used in product redesigns.
Consider the implications of each substitution: Plan out any alterations your facility will have to make in terms of workflow, equipment, parts, ventilation, disposal, and other areas in order to handle each substitution.
Compare alternatives: Weigh the risks and benefits involved in the usage of different states of each substitute chemical. Also, consider the possibility of redesigning a manufacturing process to eliminate unnecessary chemicals altogether.
Decide whether to substitute: Gather input from workers who will be handling the chemical in question and make a balanced decision.
Introduce the substitute: Once you’ve made your choice, immediately begin preparing the facility and workers as needed.
　
Assess the change: Check in on any alterations in your facility’s process, as well as on the safety of your staff and their confidence in working with the new substitute. Make further adjustments as necessary.
　

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IV. R&D teams and plant managers can collaborate on substitutions in a variety of ways
The most obvious way to eliminate a hazardous chemical might be simply to remove it from a given production process. For example, an R&D team might replace certain organic solvents

with water-based paints or ester-based products. A similar tactic is to redesign a process to incorporate safer materials and techniques; for example, to switch from vapor degreasing to high-pressure hosing in a closed system.




However, the truth is that chemical- related risks can creep into facilities in a wide range of ways—all of which can be addressed effectively through different forms of substitution. Plant managers can combat hazards by using safer
　
methods for paint removal; for instance, blasting with steel sand in a contained environment. They might replace adhesive-based bonds in the plant’s architecture with mechanically locking parts or avoid electroplating with nickel

altogether. When choosing furniture, they might switch to untreated wood.




In all of these ways, R&D teams can work together with plant managers to eliminate hazardous chemicals from processes and facilities alike. As regulatory compliance makes chemical substitution

a higher priority than ever, this level of collaboration will become increasingly necessary to any chemical project’s long- term success.
 

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