The European Chemical Industry Council (CEFIC) has taken a significant step towards implementing a Safe and Sustainable by Design (SSbD) approach. They published a report that outlines the process for industry players to adopt such an SSbD approach in their innovation process. This report provides important guidance in the industry’s journey towards operationalizing SSbD. The current version is open for testing and feedback from stakeholders.

CEFIC’s guide for industry to implement SSbD in a five-step process

CEFIC has recently published a report(PDF) describing five separate activities for industry to perform when they want to use an SSbD approach in their product development. The activities fit within an innovation process based on a stage-gate approach. The first activity involves defining the product’s performance needs. This is followed by setting limits to the safety and sustainability characteristics of substances relevant to the type of product being developed. Subsequent activities involve assessing the potential impact on safety and sustainability and subsequently evaluating different outcomes. A multi-criteria decision-analysis (MCDA) aids to gain insight into the trade-offs of each option’s various safety and sustainability aspects. In this way it helps to select the optimal solution.

CEFIC aims for safe and sustainable products beyond regulatory requirements

The CEFIC Guidance incorporates the process of innovation through the use of a stage-gate innovation approach. Furthermore, the element of ‘design’ is tackled by inclusion of design principles which sets limits to the safety and sustainability characteristics of the substance. Such limits are depending on the type of application. This means e.g. that a consumer application does not allow for the use of substances with potentially severe adverse effects such as carcinogenicity. Related to assessments in SSbD, also trade-offs between different aspects of safety and sustainability are addressed in the guidance. A multi-criteria decision-analysis (MCDA) which aims to determine the best alternative by considering more than one criterion, can help in dealing with such trade-offs.

CEFIC’s primary goal is to ensure thorough safety implementation through a risk-based assessment. This should take into account the hazards, use, and exposure in accordance with REACH regulations and preparing for future regulatory changes. By promoting SSbD, CEFIC aims to go beyond legal requirements. CEFIC is committed to advancing knowledge about toxicological risks for humans and the environment, particularly in consumer use, while also considering end-of-life and circularity needs.

Guidance open for stakeholder feedback

CEFIC has released the report for consultation to gather feedback from stakeholders. They encourage the stakeholders to apply the CEFIC SSbD activities on case studies or research and innovation projects. CEFIC does not limit such case study projects to any stage of the innovation process. One of the aims is to use the feedback received through this survey to provide input for the 2024 SSbD JRC framework feedback phase of the European Commission. This feedback phase started on May 15th, 2024.

Reflections by RIVM

Industry involvement in developing and operationalizing SSbD is not only welcomed but also necessary. SSbD is an evolving approach, and industries are already preparing and testing its application. The development of industry guidance is a promising step in this process. To understand how SSbD can work, we need an iterative process involving ‘learning by doing’ and gaining hands-on experience. Practical experience and learning from case studies are essential. Industry guidance is one tool to move this process of learning by doing forward.

There are currently two outreach activities regarding SSbD. One is led by the European Commission. Here the second reporting phase for feedback for the EC JRC SSbD Framework is ongoing. The other one is led by CEFIC. They set out a survey with a deadline for June 16th, 2024. It will be important to combine and compare the results of these two outreach activities, as they both add to the current thinking on SSbD but from different perspectives. The CEFIC guidance is based on the innovation process of product development. In contrast, the EC JRC SSbD Framework refers to methods set by regulations such as REACH and CLP for hazard assessment and data-rich methods for environmental sustainability assessment. Examples of such data-rich methods are lifecycle assessment (LCA) and product environmental footprint (PEF).