For decades, American Finish and Chemical Co. (AFCO), Chelsea, Mass., was in the shoe business, supplying cements and solvents to footwear manufacturers. When much of the shoe business moved overseas into developing countries, however, AFCO needed a new business plan. President and CEO Leon Pinstein turned AFCO into a high-technology manufacturer of nontoxic, water-based coatings and adhesives.
"Solvents were getting a bad name, and the volatile organic compound (VOC) regulations were getting stiffer," said Pinstein, whose family-owned business employs 30 people. "VOC emissions from waterborne materials are much lower. These materials are not flammable; you could put a cigarette out in this stuff. There are no special warning labels because these are not hazardous materials."
Besides coatings and adhesives, solvents and cleaning products are prime candidates for converting to less hazardous materials. Water- and citrus-based products are generally better for worker and environmental health than petroleum- and hydrocarbon-based materials.
"Industry can use almost anything safely, but we should be looking for materials that are progressively less hazardous," according to Lindsay Booher, CIH, CSP, section head of site characterization and remediation for Exxon Engineering, Florham Park, N.J. He said "materials that could come in contact with people" such as solvents, degreasers and parts cleaners should be the focus of material substitution efforts. "Raw materials used in a closed process" such as materials used in plastics manufacturing are less of a concern, he said.
"There is a lot of lower-hanging fruit that people can pick off if they start to look at the alternatives," according to Agis Veroutis, project manager with Roy F. Weston's strategic environmental services group in West Chester, Pa. He noted, for example, that the personal products industry can eliminate alcohol from anti-perspirants, and "still have the function of that material" by substituting water and a special preservative. This also results in a cost reduction, which he said makes the substitution "very close to common sense."
Chemical companies and many businesses in the industrial and service sectors can benefit from hazardous materials substitution. Such a strategy can reduce compliance burdens and PPE and training costs, and increase worker protection, productivity and corporate image. In some cases, production costs will be less, and companies can gain an advantage over competitors by offering less hazardous, but equally effective, products.
To reduce their OSHA compliance burden, for example, companies could use materials other than benzene, 1,3-butadiene or methylene chloride which are covered by comprehensive health standards. DuPont's carpet fiber plant in Camden, S.C., replaced methylene chloride and perchlorene with more benign chemical mixtures for cleaning parts.
Although some companies try to avoid using materials that OSHA regulates, the agency does not push companies into replacing hazardous materials, insisted Adam Finkel, the agency's health standards director. "With all of the pressure from small business and Congress," he said, "we bend over backward to make sure we don't require measures that are not economically feasible. The market determines what's viable." Sources said substitution is prevalent where the regulations keep getting tougher, such as with vinyl chloride, PCBs and asbestos.
On the environmental front, right-to-know laws, concerns about air toxics and VOC emissions, and expedited permitting have fed an interest in material substitution. AFCO's Pinstein said some states, including California, New Jersey, Tennessee and several in New England, are particularly aggressive. The four-county South Coast Air Quality Management District in southern California, for example, has a deadline of Jan. 1, 1999, for eliminating the use of hazardous solvents.
While many manufacturers rue stricter OSHA and EPA standards, AFCO's Pinstein says, "the government definitely is helping us. The change to waterborne products is coming."
Besides the mandatory targets and standards compliance, EPA in particular is promoting a voluntary approach to reducing the use and disposal of hazardous materials. For several years, the agency has been signing up companies to participate in the 33/50, Green Lights, Design for the Environment, Common Sense Initiative and Project XL programs.
More recently, EPA's Division of Hazardous Waste Minimization and Management has developed a Windows-based software program to help companies evaluate the relative risk of materials. The software factors the persistence, biocumulation and toxicity (PBT) of materials into a relative risk ranking. The division wants industry to reduce use of high-PBT-rated materials 20 percent by 2000, and 50 percent by 2005. (The Waste Minimization Prioritization Tool software can be downloaded from the EPA Web site at www.epa.gov/hazwaste/minimize/index).
"This is not a sign-up program," said Doug Heimlich, a divison program analyst. "We're trying to set basic national goals and give industry tools to meet them."
The federal government as customer, especially the Defense Department's interest in purchasing "green weapons systems," is also making material substitution more viable. "Most weapons that are created are never actually deployed and have to be replaced," Veroutis pointed out. "This makes a great case for materials substitution, and it will trickle down the supply chain."
Sometimes, industry itself drives the material substitution engine. The DuPont plant mentioned earlier, for example, reduced the amount of oil used to finish carpet fiber. As a result, Technical Manager Gordon Maynes said, "there is a lot less mist in the air for DuPont employees, and our customers, the carpet mills in Dalton, Ga., reduced their effluent by 30 percent." Even the workplace floors now pose less of a slips and falls hazard. The plant, which manufactures 350 million pounds of Antron and Stainmaster carpet fiber per year, is also working with its carpet mill customers to take back and recycle old carpets.
"We think these programs give us a competitive advantage over other fiber producers," Maynes said.
Keys to Success
Companies need an organized, well-managed approach to evaluating and using safer materials, according to Exxon's Booher. He recommends that companies consider the impact of materials on:
- Worker health, including risks from exposure, and the need for protective equipment and training.
- Safety, including slips and falls, and explosive and flammable hazards; and
- Environment, including emissions and waste.
"If you make a substitution just for worker health," Booher said, "you haven't done a good job. It could be hard to dispose of or cause major housekeeping problems. Look at the conditions of use throughout the process."
Maynes said DuPont uses a decision tree to make sure new materials can be safely used, and disposed of or recycled. He said it can take years for new materials to work their way through approvals by the engineering, operations, safety and health, environmental, and marketing functions.
"Companies should be designing for the entire life cycle of a product or material," Weston's Veroutis said. He said "take-back initiatives" in the electronics industry are encouraging companies to design products for disassembly and recycling. "Harmonizing the type of materials" and using less hazardous ones make recycling easier, he said.
Companies interested in material substitution should start on a small scale, advised Pat Doughty, co-owner and chief operating officer of Mirachem Corp., a Tempe, Ariz., manufacturer of water-based cleaning products. He said this could involve starting with small parts cleaning operations or trying a materials substitution strategy in a pilot plant.
A major Mirachem customer, for example, started with one plant and now has about 10 plants converted to water-based parts cleaning. Eventually, all 50 of the customer's facilities will make the switch because of health, safety and environmental considerations, as well as improved products cleaning.
"Companies are just beginning to see what's possible," Doughty said.
Words of Caution
Despite the many possible benefits, materials substitution is not as easy or automatic as continuing to use traditional materials. Here are some of the major challenges:
Alternative materials must "do the job as well as the existing materials, not just 80 percent of the job," according to Charles Walton, a senior manager at the Chemical Manufacturers Association (CMA).
Even in recent years, some less hazardous materials have had a reputation for not being strong enough, not being adaptable to various uses, not being of consistent quality, and not reacting to other materials as industrial customers would prefer.
AFCO's Pinstein insists that technological advances have allowed many less hazardous materials to have "equal performance" and, in some cases, improve productivity and quality.
Safer materials are not as widely available and applicable as some experts would like.
AFCO, for example, is a small, laboratory-oriented manufacturer of custom coatings and adhesives. So far, AFCO's products are designed to meet the needs of specific customers, such as safer waterborne paint developed for plastic model kit manufacturer Revell-Monogram. This customer even owns the technology.
"Eventually," Pinstein said, "we will have a full product line with some off-the-shelf solutions."
Materials substitution certainly is not a seamless process. For example, using water-based solvents requires that spray nozzles be stainless steel. These solvents also tend to take longer to apply and dry.
Safer materials often cost more than traditional materials.
"It will always be a little more expensive to use acrylics and urethanes rather than acetone," Pinstein said. He argued, however, that those direct costs can be offset by indirectly saving money on compliance, liability and waste disposal.
Consumers and industrial customers want environmentally friendly products, but they generally do not want to pay extra for them. Weston's Veroutis said, "Right now, the environment is a tiebreaker. All other things being equal, people want to protect the environment."
No matter how hard companies work at it, hazardous materials cannot be eliminated from all applications.
"We don't want to take substitution too far," Exxon's Booher warned. He said discussions about what materials to replace, and how to do it, should consider the "cost, effort and impact" of the alternatives.
Hazardous materials are "an intricate part of commerce in general," CMA's Walton said. Substitution could lead to elimination, which could "put some businesses out of business."
Walton also believes that "there is not a lot of brand-new chemistry on the market. You can't all of a sudden redesign a chemical mixture like you redesign a tennis shoe."
He recommends that companies focus on product stewardship to ensure that chemicals, including potentially hazardous ones, are manufactured and used as safely as possible.
OSHA's Finkel said some chemical manufacturers and users are "hooked on hazardous materials. They have too narrow a perspective and don't even want to think about substitution."
New materials need to be evaluated to make sure they are not more hazardous or pose different types of hazards.
"It's the chemical manufacturer's job to make sure there is no smoking gun," Mirachem COO Pat Doughty said. "When we think we have a new product for a customer, our first call is to the industrial hygiene or safety group, not the purchasing department."
Exxon's Booher believes new materials need to be more carefully tested in the laboratory and in pilot projects before they are used regularly. A few years ago, a new formulation for liquid foam used in manufacturing a consumer product was designed to perform better and be less hazardous. Unfortunately, Booher recalled, workers were left unprotected and developed urinary tract infections.
"Pre-testing is not going to tell you everything you need to know," Booher said. "You should keep a close eye on anything new. Make sure you know how to handle the new materials." Even safer materials have risks and must be manufactured and used in a safe manner, he pointed out.