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Implementation Challenges

Off all the environmentally preferable procurement requirements, reducing purchasing and potential exposure to toxic chemicals most clearly relates to and supports our primary missions of disease prevention and human health promotion.  Yet guidance for reducing procurement of toxic products is scant and there are daunting obstacles that must be overcome before measures to reduce procurement and use of hazardous and environmentally damaging substances can be designed and broadly implemented:
·        Basic terms such as “toxic product” and “less toxic” have not been clearly defined in procurement regulations.  Do these refer to human toxicity, animal toxicity and/or environmental toxicity?
 
·        Assessment of toxicity requires detailed, uniform data on the composition of products and emissions from services, which is often not available.
 
·        Some products may not contain identifiable toxic or hazardous substances as manufactured or delivered but may form or emit these during storage, use or disposal.
 
·        From a sustainability standpoint, emissions, toxicity and other risks must be evaluated throughout the product’s entire life cycle, from the supply chain, during use and to recycling or disposal at the end of its useful life.  Such life cycle toxicity data is rarely available.
 
·        The toxicity and potential for emissions and human exposure posed by a specific chemical can be significantly affected by its use, form and other substances in a product’s formulation and present at its point of use. Some substances are used in many diverse applications, which may pose significantly different hazards and risks.  Accordingly, substance related restrictions and guidance on safer alternatives must be use-specific.
 
·        Selection of “less toxic” services and products requires the application of uniform and objective procedures for data collection and protocols for comparative toxicology that have not been developed.
 
·        Risk assessments should be a primary basis for identifying SoCs and reduction priorities but they are difficult and resource intensive to perform.  Thousands of different substances, formulations and products are used in NIH facilities and mission activities.
 
·        Before recommendations for replacement of mission critical products containing or releasing objectionable substances can be made, suitable alternatives must be found and validated.  Particularly for products used in health care and biomedical research applications, lengthy testing and approval processes may be required before for alternative products can be used.
 
·        The precedence and weighting to be assigned to toxicity reduction in the hierarchy of a multi-attribute sustainable acquisition decision matrix has not been established.

 
This page was last updated on Apr 26, 2013