Benefits to Sustainable Futures Graduates
- Regulatory Relief
- Reduced Uncertainty
- Sustainable Futures Graduates
- Examples of Benefits to Graduates
Once Sustainable Futures participants have taken training and developed a track record by submitting at least five unregulated prescreened low hazard and/or low risk new chemical notices, they can take advantage of the expedited review of their subsequent Premanufacture Notices (PMNs). As described in the Federal Register Notice announcing Sustainable Futures the expedited review is achieved by allowing the graduate's submission to be considered both as a PMN and a Test Marketing Exemption (TME).
Under the electronic PMN system the Sustainable Futures Graduate will need to create and submit two separate notices, the PMN and the TMEA, as the combined Sustainable Futures submission. Using the electronic PMN submission system, the submitter can "create" the TMEA by doing the following: (1) copy the PMN file; (2) renaming the file; (3) open the new file in the e-PMN software; (4) make the changes needed to meet the requirements of a TMEA (note in the cover letter that you are a graduate of Sustainable Futures and that your submission meets the requirements of a TMEA; PMN page 1 mark it as a TMEA, PMN page 7 change the production volume as needed, etc); (5) finalize the submission and submit the TMEA.
The advantage of the simultaneous submission is that the case will be considered a TME and the submitter will be able to manufacture at day 45 instead of having to wait until the PMN 90 day review period ends. This in effect cuts the review time in half.
The status of PMNs is available on the New Chemicals Web site.
In addition to being able to manufacture sooner, significant benefits can be realized by reducing regulatory uncertainty. Prescreening for hazard and risk concerns helps Sustainable Futures participants anticipate and either avoid or control hazardous conditions related to their chemicals of concern. This is pollution prevention in it purest form.
Additional benefits to participants that increase competitive advantage include:
- Identification and commercialization of safer chemicals,
- Increased Pollution Prevention (P2) opportunities,
- Increased innovation,
- More focused testing,
- More efficient processes, and
- Reduced generation of chemical waste.
Avoiding problem chemicals and the potential high costs associated with those chemicals, sometimes called chemicals "left on the cutting room floor," may well be the source of the greatest cost savings to companies participating in Sustainable Futures. The ultimate identification and commercialization of safer chemicals benefits the participant, as well as the general public and the environment.
Sustainable Futures Graduates:
- PPG Industries
- Eastman Kodak, Inc.
- Cytec Industries, Inc.
- Clariant Corporation
- International Flavors and Fragrances, Inc.
- NALCO Champion, An EcoLab Company
- Chevron Phillips Chemical Company
- Cabot Corporation
- Givaudan Fragrances Corporation
PPG Industries and Eastman Kodak are considered to be Sustainable Futures graduates by virtue of their highly successful participation in Project XL, which provided the foundation for the Sustainable Futures Initiative. Additional companies have graduated since the Initiative was announced. Sustainable Futures graduates have qualified for regulatory relief through submission of unregulated prescreened low-hazard and/or low-risk PMNs. Numerous other companies participating in Sustainable Futures have submitted enough prescreened PMNs to meet the graduation criteria and, as a result, the number of Sustainable Futures graduates is expected to increase.
Examples of Benefits to Graduates
Some examples from Sustainable Futures participants who are seeing significant cost savings associated with identifying problematic chemicals and processes early at research and development are offered below.
Eastman Kodak, under their Project XL, sponsored a cost accounting study by the Tellus Institute which compared Kodak's operations both before and after using the P2 Framework models. Kodak's Tellus Report (PDF) (50 pp, 400K, About PDF) showed that by prescreening their chemicals at R&D, Kodak reduced product development costs by 13 percent to 100 percent; reduced time to market, and reduced generation of chemical waste. Kodak told the Agency, in their Aug. 2003 Project XL Progress Report (PDF) (11 pp, 39K, About PDF) "Kodak has reviewed materials that were possible candidates for commercialization using the P2 Framework. Of the materials that could have been commercialized, 24 percent were dropped early in the product development process."
Cytec Industries used the Sustainable Futures screening methods to evaluate three potential new materials as premanufacture notices, and according to Dr. Randy Deskin, of Cytec, were able to stop development of one problematic material early on and refocus research efforts to look for a more environmentally friendly alternative. The Cytec Industries experience was published in Chemistry Business Dec04-Jan05: Cytec Industries takes Stand on Sustainable Futures (PDF) (2 pp, 84K, About PDF).