Development of a comprehensive program to identify and reduce procurement of products and services containing or emitting Substances of Concern will be a long term effort requiring additional resources, large supporting databases and extensive collaboration among multiple agencies and the suppliers of goods and services in the private sector. Major elements of this innovative program have been proposed by DEP but are not yet in place. These will include development and operation of efficient NEMS processes for:
· Establishing and maintaining the SOC listings based upon the most current scientific data and rapidly evolving regulatory requirements.
· Collecting and maintaining accurate, standardized data on the presence or release of SOCs from specific uses of the myriad products and services purchased by NIH.
· Accessing the comparative toxicology of products and alternatives in defined, specific uses.
· Integrating and weighting restrictions on SOCs with other sustainable acquisition criteria in making purchasing decisions.
· Maintaining required SOC inventories and tracking compliance with SOC restrictions using online purchasing systems.
· Training purchasers on SOC reduction requirements.
· Open and transparent communication of SOC listing actions, reduction guidance, requirements and specifications to suppliers and the public.
Until this program can be fully implemented the DEP has established an Interim Listing of Substances of Concern and is developing methods to identify and track purchases of services and products containing these SOCs using the NIH Purchasing Online Tracking System (POTS). The purposes of this listing are to:
· Improve awareness by purchasers and suppliers of SoCs, alternatives in commonly products and services, and requirements to reduce procurement of SoCs.
· Comply with requirements of regulations and Executive Orders
· Serve as the official source of NIH Environmental Management System (NEMS) requirements relating to procurement and use of Substances of Concern by contractors and suppliers to NIH. This was authorized by the above referenced Federal Acquisition Regulation (FAR) Interim Rule of May 31, 2011 that requires contractor compliance with the procuring agency’s EMS.
To develop this list DEP has used numerous references and databases. These include the National Library of Medicine’s Hazardous Substance Data Base (HSDB) and Household Products Database; previous lists from the NIH Pollution Prevention Plan and NIH chemical reduction plans; lists developed by regulatory agencies, e.g., EPA and OSHA for similar purposes; CDC biomonitoring data; the National Toxicology Program (NTP) reports on Carcinogens; hazardous waste generation reports from NIH facilities; and information on chemicals used in common building materials and other commodities likely to be used in NIH facilities that are not likely to be disposed of as hazardous waste or included in related reports.