Until recently, environmentally related requirements for federal purchasing often referred to as Environmentally Preferable Purchasing (EPP) have largely consisted of single attributes such as recycled material content for a limited number of specifically designated, widely used commercial products e.g., paper. These attributes focused on energy efficiency, renewable (biobased) and recovered (recycled) materials and with some limited exceptions did not address toxicity and other health and environmental hazards posed by chemical substances used or emitted from services or products in the supply chain, during use, recycling or final disposal. For the most of the vast array of products used in our biomedical research mission there are no current EPP requirements and guidance for purchasers has not been developed.
To minimize risks to health, safety and security, prevent pollution and reduce generation of hazardous wastes from its facilities and mission activities the NIH has developed guidance documents, plans and polices to reduce procurement and use of specific laboratory chemicals that posed excessive risks and for which acceptable, less hazardous alternatives were available. Some of these such as restrictions on the use and disposal of mercury were established more than 40 years ago, demonstrating NIH leadership in this area long before regulations requiring such controls were adopted. In more recent times the NIH Division of Environmental Protection began other initiatives to identify and further reduce use of high risk substances. Examples included:
· Issuance of Wasteline, a series of publications and other guidance documents on reducing use of lead, chloroform, picric acid and other problematic chemicals.
· Completion and publication of a collaborative study with EPA and a major pharmaceutical company on the occurrence of Persistent, Bioaccumulative and Toxic (PBT) substances in wastes generated by biomedical research facilities.
· Issuance of a Pollution Prevention Plan that included reduction methods and goals for specific chemicals based on agency use and regional priorities.
· Waste characterization studies leading to development of guidance and mandatory training of investigators on minimization methods, including chemical and radionuclide substitution that resulted in a more than 95% reduction in generation of highly problematic mixed wastes (radioactive hazardous wastes),
· Participation in the development of multiple national standards and guidelines that include recommendations for chemical substitution in laboratory procedures.
· A highly acclaimed voluntary reduction campaign and subsequently formal restrictions on procurement, use and disposal of mercury and its compounds (NIH Manual Chapter 3033).
The acquisition related strategies included in most of these previous initiatives focused on reducing direct procurement of pure chemicals, primarily those for use as reagents in laboratory procedures. The mercury reduction campaign and restrictions were the first efforts that also addressed reductions in procurement of products that contained a chemical as a component or unintended contaminant in specific uses. This new initiative will apply to Substances of Concern that are purchased directly or are contained or released by a service or product anywhere its life cycle – in the supply chain, during use, and at the end of its useful life in reuse, recycling or final disposal.