We anticipate that this initiative will be implemented over several years in a series of incremental steps. Full implementation will require development of risk assessment methods and priorities, issuance of policies and procedures for substance listings and restrictions by the NIH Environmental Management System (NEMS); large supporting databases of risk information on services, products and alternatives to inform purchasing decisions; new protocols for comparative toxicology; and integration of attributes relating to SOCs into sustainable acquisition criteria and purchasing systems that are currently in the early stages of development.
DEP’s initial steps in implementing this SOC reduction program and to ensure compliance with related mandates are described here. These will consist of issuing an Interim List of SOCs, general guidance on reduction strategies for listed substances and procurement restrictions for the small number products containing SOCs that have well defined, lower risk alternatives
This is a work in progress and we anticipate the need for corrections and frequent updates. We invite comments from both purchasers and suppliers, and encourage participation in developing and implementing this initiative by NEMS Green Teams, our scientific community and procurement officials.
Interim Use of Substance Lists. Listing approaches as employed here are the most feasible and common strategies currently used in chemical management and regulatory systems, and obviate the need to conduct resource intensive risk assessments. Specific substances meeting listing criteria may be subject to restrictions on procurement, use and disposal. While these approaches are easily implemented for pure chemicals they have many shortcomings for uses in managing procurement of services and products, which may be of unknown composition or contain multiple different substances and concentrations.
Another problem encountered with list based approaches such as this is that a specifically listed substance in a product can be replaced with a similar unlisted substance to avoid controls. To reduce the potential for this, SOCs on the Interim List will consist of groups of substances with similar chemical properties and risks, with examples of discrete specific substances included in the group.
Restrictions and Alternatives Based on Specific Use. Some substances are found in a wide variety of products with many different uses. In some of these uses a substance may pose significant risks, while in others the risks are acceptable or undefined. The availability of suitable alternatives for products containing SOCs also varies greatly with their intended use.
To address the limitations of list based systems this procurement initiative will employ an approach that lists groups of SoCs based on the general criteria described below and will establish recommendations and requirements for procurement controls based on specific uses.
Use of the SOC Lists to Promote Supplier Disclosure. There is little information on the presence of SOCs in many products, and information on SOCs in emissions over the life cycle of a product’s manufacturing, use and disposal or recycling is rarely available. This information is needed to inform purchasing decisions. To address this need, purchasers should encourage or require service providers and suppliers to provide information on product toxicity, hazards and emissions. Purchasers can do this by including reference to the Interim List in specifications and include provisions in solicitations requiring disclosure of information about the presence of listed SOCs in products, from services provided and in emissions.