Integrating Alternatives

Assessment into Your Materials

Compliance Strategy

Cory Robertson

HP Inc.

The Law That Changed Everything

EU 2006

RoHS

• Lead (Pb)

• Mercury (Hg)

• Cadmium (Cd)

• Hexavalent Chromium (Cr6+)

• Polybrominated Biphenyls (PBB)

• Polybrominated Diphenyl

Ethers (PBDE)

2

Logo from companion

regulation

Waste Electrical and

Electronic Equipment (WEEE)

Directive Are the alternatives better?

More Regulations Coming

• Substance restrictions

have become a major class of regulation for

finished electronic products

• More substances

• More jurisdictions

• More reporting

3

Avoid Future Regulation: HP wants to use

materials no one cares about

4

•GHS Criteria

•R-phrases

•H-phrases

• IARC

•Prop 65

•Data

• i.e. LD-50

•Proxy

Chemicals

•QSAR

•Expert

Judgment

Hazard

Table U.S. EPA Alternatives Assessment:

Partnership to Evaluate Flame

Retardants in Printed Circuit Boards

Training Available

Decision

Logic

5

Shift to Hazard

Reduction 12 Principles of Green Chemistry

• Reducing risk through hazard

reduction is more effective and

efficient than exposure reduction

• Better to use inherently safer

chemicals rather than trying to

make a hazardous substance

“safe enough” by limiting

exposure

6

Aligns with Regulators

Normalizes Stakeholder Inputs

8

Fate Ecotoxicity

GS Benchmark P B AA CA

Chem #1 2 H L L H

Chem #2 4 L L L H

Chem #3 2 L L H M

Chem #4 1 L L H dg

Chem #5 3 L M M dg

Simple 1-4 score (1=bad, 4=good)

• Expert knowledge is required to generate and peer review the score

• Once generated, the simple score can be used by others even if they have no technical training

9

10

11

Aquatic Toxicity R50/53 Bioaccumulation

Persistent LD50 = 2150mg/kg Mutagenicity

12

13

Avoiding extra substitutions saves money

DEHP

Any unrestricted

Incrementally better

Best

Phthalate 1 $X

Non-ortho-phthalate $X

Phthalate 2 $X

Non-ortho-phthalate $X

Phthalate 1 $X

Non-ortho-phthalate $X

$3X

$2X

$1X

Transition

Costs

RoHS 2

Added 2015

Restricted 2019

GreenScreen™ for Assessing

Replacements for Restricted

Substances in Electronics

15

Structural Plastic

Database Supplier Supplier

Material ID

Composi

tion

Recycled

Content

Risk Phase

Assessment

for the FRs

Green Screen

of Additives

HP

Confidential

HP GSE

Rev. O

RoHS

2.0

Rev. F

BFR/PVC

Free

Meets

TCO DT

3.0 and

AiO 1.0

R50/R53,

based on

FR

Eligible for

EPEAT 4.1.6.2

optional point?

FR eligible for EU

Ecolabel?

Notes ABS, PC,

PC+ABS,

PC+20GF

, etc.

generic

resin

composit

ion

Virgn or

Recyled

with XX%

post

consume

r content

Directive

67/548/EC

Benchmarks

shown have

been reviewed

by HP Green

Screen Team

Table 1

Page 7-9

Spec for

Plastics

Spec for

Plastics

R40, R45,

R46, R48,

R50/R53,

R60, R61;

only for

parts > 25

g

R40, 45, 46, 50,

51, 52, 53, 60,

61, 62, 63 and

their

combinations;

only for parts >

25 g

Numerous Risk

Phrases--Refer to

Declaration Letter

only for parts > 25

g

Supplier 1 Plastic 111 PC/ABS Virgin none 2 Yes Yes Yes Yes - FR's

meet req. Yes

Yes - FR's meet

req.

Supplier 1 Plastic 222 PC/ABS Virgin R53 1 Yes Yes Yes No No

Yes

Supplier 2 Polymer

9099 PC 65% none Unknown

Yes Yes Yes Yes Yes Yes

16

Electronics Cleaners

•Spot cleaners have little exposure control •Field repair

•Rework stations

•New material type = manufacturing chemical (not product material)

•Worked with formulators to develop effective cleaners that meet hazard criteria

•Challenges •Dealing with mixtures

•Synergistic effects

•Efficacy may require small amounts of GreenScreen™ Benchmark 1 chemicals

Repair and rework spot cleaners

used in the manufacturing

process

18

PVC-Free Power Cord GreenScreen™ Pilot

• PVC being phased out voluntarily

• Screening mandatory, in addition to all standard and regulatory requirements

• Full disclosure under CDA

• Supplier Training

• Over 30 materials screened

• Several approved

Integrated Alternatives

Assessment

California Safer Consumer

Products

BizNGO Project

California Safer Consumer

Products Regulation • Became effective October 1, 2013

1) Is this chemical necessary?

2) Is there a safer alternative?

• Manufacturers of Priority Products required to produce alternatives assessments on Candidate Chemicals

• Brand reputation is a key driver

21

Alternatives Assessment

Pilot Project

22

Purpose: Gain useful experience to inform public comments on Safer Consumer Product regulations and guidance documents by completing an Alternatives Analysis that meets requirements of Article 5 of the SCP Regulation

Summer 2012 to Winter 2013

BizNGO

bizngo.org

23

• Collaboration of representatives from leading companies and non-governmental organizations (NGOs)

• Launched in 2006 by Clean Production Action

• Mission: To promote the creation and adoption of safer chemicals and sustainable materials, thereby creating market transitions to a healthy economy, healthy environment, and healthy people.

Decabromodiphenyl Ether

(DecaBDE)

24

• Successfully substituted already

• Data rich

• Allowed for focus on the process

25

• BizNGO Framework

• Phased/ordered steps

• Hazard first

• LCA and exposure

BizNGO Chemical Alternative Assessment Protocol

26

Stage 1 Process Observations – Many Alternatives

MDH - Magnesium di-hydroxide DfE Hazard Table, Known Alternative

RDP Resorcinol bis (diphenyl phosphate) DfE Hazard Table, Known Alternative

TPP - triphenyl phosphate DfE Hazard Table, Known Alternative

Zinc Borate DfE Hazard Table, Known Alternative

Aluminum housing material Material Change

Added sheet metal fire enclosure Material Change

High PC content PC/ABS Material Change

Tris-(2-ethylhexyl) phosphate Representative--Alkyl Phosphate Group

sil icon dioxide Representative--Fil ler Group

ZnHS - Zinc Hydroxystannate BFR Synergist

Antinomy trioxide BFR Synergist

APP Ammonium Polyphosphate (coated) Duplicate

APP Ammonium Polyphosphate (with synergists) Duplicate

Boehmite (Aluminium oxide hydroxide) Group--Aluminum tri -hydroxide

DEEP - Diethylethane phosphonate Group--Alkyl Phosphate

Expandable graphite Group--Fil ler

• Over 100 Alternatives

• Group alternatives and analyze a representative from the group

• Allow any reason for de-selection in stage 1

• Advanced multiple alternatives into stage 2

• Objective is to find better alternatives not necessarily the “greenest”

GreenScreen® Hazard Assessment Tool

27

27

Hazard endpoint Criteria Cutoff Group I Human High

Carcinogenicity GHS Category 1A (Known) or 1B (Presumed) Mutagenicity/Genotoxicity GHS Category 1A (Known) or 1B (Presumed) Reproductive Toxicity GHS Category 1A (Known) or 1B (Presumed) Developmental Toxicity GHS Category 1A (Known) or 1B (Presumed) Endocrine Activity Evidence of endocrine activity

Group II Human Very High High Acute toxicity GHS Category 1 or 2 GHS Category 3 Systemic Toxicity/Organ Effects and Neurotoxicity; single exposure

GHS Category 1 GHS Category 2

Systemic Toxicity/Organ Effects and Neurotoxicity; repeated exposure*

GHS Category 1

Skin Sensitization* GHS Category 1A

Respiratory Sensitization* GSH Category 1A

Skin Irritation GHS Category 1 (Corrosive)

GHS Category 2 (Irritant)

Eye Irritation GHS Category 1 (Irreversible)

GHS Category 2A (Irritating)

Ecotoxicity Acute Aquatic Toxicity GHS Category 1 GHS Category 2 Chronic Aquatic Toxicity NOEC < 1.0 mg/L NOEC < 1.0 mg/L

Fate Very High High Persistence (P) Days:

Soil: t1/2>180 Water: t1/2>60 Air: t1/2>50

Days Soil: 60 < t1/2 < 180 Water: 40 < t1/2 < 60 Air: 2 < t1/2 < 5

Bioaccumulation (B) BAF/BCF > 5000; Log Kow > 5.0

1000 < BAF/BCF < 5000 4.5 < Log Kow < 5.0

Reactivity Equally or less reactive than chemical of concern Flammability Equally or less flammable than chemical of concern

Benchmark 1 prohibited - Benchmark 2 or higher is

required - Converted the

Benchmark 1 criteria into endpoints

Stage 2 Product Function and Performance

28

• Performed finite

element analysis

• All of the alternatives

performed adequately

• Ultimately, prototypes

will determine

suitability

• Important to have

many alternatives

Stage 2 Economic Impacts

29

29

• Used 2006 study by Washington

State Department of Ecology

• Predicted an $80 benefit per

person

• Based on hazard assessment all of

the alternatives are expected to

have lower economic impact

• Would be very different if we had

proposed continued use of the

chemical of concern

Deeply Problematic

No Data Sources

No Methods

Summary Matrix

30

30

A Adverse Environmental Impacts B Adverse Public Health Impacts C…

Project Conclusions

31

31

• Provided feedback and lessons learned to CA

DTSC

• DTSC provided a completeness review

• Sufficiency is still an open issue—how do you

know when you are done

• Brand reputation is an important driver

• Guidance and standards are needed

http://www.bizngo.org/alternatives-assessment/model-assessments

A Framework to Guide

Selection of Chemical

Alternatives

National Academy of Sciences

Why Hazard Assessment

First? • Hazard assessments are faster, easier to

complete than complete LCA or Risk

– Narrower, endpoints are relatively well defined

– Science-based, facilitates relatively quick

chemical assessments

– Can screen out hazardous options before investing time and money

• Regulatory bodies are increasingly using hazard

as a screen for substances of concern, so useful an indicator of future restriction

– Aligns business process with regulatory

process

35

Lessons Learned

What has changed?

37

If we articulate

environmental

requirements to our

suppliers we get

better materials

“Maybe we should pre-screen

our materials before we send

you our formulations.”

--Polymer formulator

“Our customers are asking us

about HP’s requirements.”

–Flame retardant supplier

39

•Just asking our suppliers to do the

GreenScreen™ assessments motivated

suppliers to remove chemicals from

some formulations.

Surprises? •Many suppliers have similar frameworks

that they use internally.

•Suppliers have additional toxicology data

that isn’t publically available.

Ecolabels

40

•Non halogenated flame retardants used in

plastic parts that weigh more than 25 grams

shall be on the publically available Accepted

Substance List for TCO Certified. This means

that the substance has been assessed by a

licensed profiler according to GreenScreen™

and been assigned a benchmark score ≥ 2

41

•Non halogenated flame retardants used in plastic parts that weigh more than 25 grams shall be on the publically available Accepted Substance List for TCO Certified. This means that the substance has been assessed by a licensed profiler according to GreenScreen™ and been assigned a benchmark score ≥ 2

Ecolabels

42

Thank You!

Backup

45

http://www.theic2.org/hazard-assessment

46