2015 TFA Green Chemistry Barriers & Accelerators

Advancing Green Chemistry:
Barriers to Adoption &
Ways to Accelerate Green Chemistry
in Supply Chains
A Report for the Green Chemistry & Commerce Council
Researched and written by:
T. Fennelly & Associates, Inc.
March 2015

Advancing Green Chemistry: Barriers to Adoption &
Ways to Accelerate Green Chemistry in Supply Chains
T. FENNELLY & ASSOCIATES, INC.
GREEN CHEMISTRY & COMMERCE COUNCIL
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About the Organizations
GREEN CHEMISTRY& COMMERCECOUNCIL
The GC3 is a cross sectoral, business-to-business network of companies and other
organizationsworking collaboratively to advance greenchemistry across sectors and
supply chains. The GC3 is based in the Lowell Center for Sustainable Production at
the University of Massachusetts Lowell. The GC3 commissioned this researchto
support its efforts to mainstream greenchemistry by understanding barriers and
opportunities to accelerating greenchemistryadoption across supply chains.
Contact Information:
Web: www.greenchemistryandcommerce.org
Email: GC3Info@greenchemistryandcommerce.org
T. FENNELLY& ASSOCIATES,INC.
TFA is a consulting firm focused on helping clients with value creationand market
access in the renewable and traditionalchemical industry Eightypercent of TFA’s
work is in specialty and renewablechemicals and their relatedmarkets. TFA has
over two decades of consulting experience in the evaluation of and strategizing for
these areas. Tess Fennelly and BryanLuftglass werethe lead authors on this report:
Tess Fennelly – has over twentyyears of consulting experience in specialty chemical and polymer related
fields. Tess also has eleven years of industry experience with positions in Sales, Business & Market
Development, Marketing & Communications, StrategicPlanning, and Mergers& Acquisitions. Her
extensive background in traditionaland sustainable chemistries includes adhesives, coatings, plastics,
specialty fibers and specialty chemicals. She worked for Segetis, Air Products and Chemicals, American
Cyanamid (Now Cytec) and Stauffer Chemical Company. Tess has a B.S. in Chemistry from Purdue
University and an MBAfrom Lehigh University.
Bryan Luftglass –has over twentyyears of consulting experience relatedto chemicals, environmental
technologies, energyand fuels plus fifteen yearsin operating companies introducing, developing and
growing new products and businesses. Hehas also focused on work with multi-national chemical
companies on programs relatedto strategyand corporatesustainability. Bryan worked for BOC Gases and
Linde, Fuel Tech, Environmental BioScience Corp., CPI Consulting (now IHSChemical), Chem Systems (now
Nexant)and his own consulting firm, Eco Logic Inc. Bryanhas a B.A. from Colgate University and a M.S.
from the Scripps Institution of Oceanography.
Contact Information:
Email: TFennelly@comcast.net
Phone: 763-559-1863

Advancing Green Chemistry: Barriers to Adoption
& Ways to Accelerate Green Chemistry in Supply Chains
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Table of Contents
ExecutiveSummary 4
I. Introduction 10
A. Backgroundand Project Goal 10
B. Project Objectives 10
C. Project Methodology 10
D. ResearchMethods 11
II. Factors Inhibiting Adoption ofGreen Chemistry 13
A. Situation Analysis 13
B. Defining GreenChemistry 14
C. Complexity of Supply Chains 17
D. Incumbency 19
E. Confusion 20
F. Switching Risk 22
G. Price/Performance 23
H. Supply & Demand 25
I. Transparency 26
J. New Technology: Access and Placement 29
III. Existing Drivers for Change(Factors Promoting Green Chemistry) 31
A. Government Regulation 31
B. Consumer Awareness 34
IV. Accelerating Adoption ofGreen Chemistry 36
A. Introduction 36
B. GreenChemistry Accelerators 37
C. Collaboration 38
D. Technology Forcing: Regulatory& Non-regulatory 40
E. Compromise 41
F. Enhanced Education 44
1. Consumer Education 44
2. Industry Education 45
V. Conclusions 46
VI. Appendix 52
A. Potential Ideasto Implement theAccelerators 53
B. What Can RetailersDo? 55
C. What Can Chemical Suppliers Do? 56
D. What Can the GC3 Do? 57

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Executive Summary
There continues to be a growing interest and awareness in green chemistry. There aresuccessful cases of
adoption of safer alternatives, and scaling of supply in response to demands from regulatorsand
customers. Despite efforts from many stakeholders to accelerategreenchemistryuse, adoption rates
remain low and overall progress is slow, measured in decades.
The GreenChemistry & Commerce Council (GC3) engagedT. Fennelly & Associates, Inc. (TFA) to research
and evaluatereasons for limited availability and slow adoption of green chemistries and the means to
acceleratedemandto pull through new and safer technologies. In thecourse of undertaking this project
TFA researched literatureandspoke with roughly fifty industry experts along the entiresupply chain from
chemicals to processors to fabricators and through to industrial and consumer finished products.
The TFA analysis identified nine key deterrents that have affectedthe slow growthand availability of
greenchemistry. These have been strong impediments to growthof greenchemistry, weighing down the
supply chain and slowing green chemistry adoption.
ES Figure I: Nine Deterrents That Can Misalign Green Chemistry Supply Chains
Nine Deterrents to GreenChemistry Supply
1. Green Chemistry Definitions
Most industries have not established a unified set of “greenchemistry” definitions. It isn’t
criticalto pick a “right” definition. It is Critical to be on the same pagewhen initiating and
advancing discussions and collaborative efforts involving GreenChemistry.
2. Supply Chain Complexity
Supply chain complexity poses enormous barriers to greenchemical adoption. Eachposition
in the chain has its own vantagepoint, a different viewpoint from others positions. This

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createsfragmentationof demand by application, volume, customer expectation, geography,
etc.
3. Incumbency
The existing infrastructureof theestablished chemical industry is so efficient that it is hard for
new entrants, greenor not, to competewith the established supply chain.
4. Confusion
Conflicting information from studies and research, policy uncertainties and conflicting
lobbying efforts continue to confuse the industry. Stakeholders areat times grid-locked, not
making a change due to uncertainty about theacceptabilityof status quo products.
5. Switching Risk
There is concern that switching to green chemistry alternativescould leadto market failures
such as market loss due to a product’s poor performance, brand tarnishing and other hidden
costs such as process or equipment or process changes, materialincompatibility, workforce
training, customer education and others. Thereis also the risk of switching to a “better bad”.
This makes stakeholders cautious and slow to makechemical management decisions.
6. Price / Performance
Price/performance was themost citedreason for the slow adoption of greenchemistry.
Entrenched chemicals of concern (COC’s) have set the standard for price/performance. Often
thereare savings in a total cost analysis such as reduced hazardouswaste handling and
disposal. This canbe hardto quantify for customers focused on $/lb. pricing.
7. Supply & Demand
There is often not enough realor perceived demand to make increased production worth the
investment. Stakeholders are cautious to move forward to commit to demand or to commit
to supply. Supply infrastructure growthwill be slow without compromise, partnership and
collaboration to increase demand and supply in tandem.
8. Transparency
More transparencyis occurring, much by force. Suppliers arelooking for ways to satisfy
customer demands while protecting IP and tradesecrets. Customers have the criticalneed to
mitigatetherisk in handling or selling products with unknown ingredients that could be COCs.
9. New Technology: Access andPlacement
Finding and vetting green chemistry technologies remains a weaklink. Suppliers struggleto
identify earlyadopters. Customers struggleon where to go beyond the traditionalsupply
chain for new technology.
Current Drivers to Green Chemistry Growth
Much of theprogress to datein advancing greenchemistry canbe attributedto two main drivers:
Government Regulationand Consumer Awareness. However, theslow adoption of greenchemistry to
datesuggests that future efforts need to better address the impediments to growth.

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1. Government Regulation
Regulatorybans and restrictions have been and will continue to be a big driver for green
chemistry. However, thedifficult and costly regulatoryprocess for new product registrations
and secondary approvals can act as a hindrance to product availability, demand and adoption.
For a new chemistry, particularlyfrom a small company with limited toxicology or regulatory
support, this canbe challenging.
2. ConsumerAwareness
Awareconsumers can force and drive change to greener chemistry. This changeoccurs
independent of legislation or lobbying. Perception is realityto the consumer. Consumer
education can heightenconsumer awareness and acceleratedemandfor green chemistry.
Accelerationof greenchemistry is difficult due to the deterrentspressuring eachpoint in the supply chain.
Many of these issues arecompounded by industries functioning within the traditionalstructure of the
supply chain as highlighted by Porter’sFive Forces Analysis, developed by MichaelE. Porter in the1970s.
This type of analysis is also instructive in assessing theforces at play in greenchemistry.
ES Figure II: Porter’s Five Forces
The Five Forces model is a tool companies use to assess their competitive position within industry supply
chains to understand where power lies. It is based on a protectionist approach employed to assess and
anticipatethreatsto the business from existing competitors, bargaining power of suppliers and buyers
(customers) and the threat of new entrantsand new technology. The Five Forces model is a planning tool
used to build a position of defense and deflection of these threats. It is not a cooperativeor collaborative
approach to business positioning. This traditional focus on competition and bargaining power for
customers and suppliers limits transparency, innovation and availabilityof performance and cost-effective
new materials.

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TFA has concluded that there arefour acceleratorsthat canchangethe current paradigmand createa
new paradigmthat can lead to faster growth of green chemistry:
1. Collaboration
2. Technology Forcing
3. Compromise
4. Enhanced Education
These elements arenot entirely new and all exist in some form. However, to transcendthe existing
“stuck” conditions, they need to be applied both more forcefully and in combination with one another.
Individual companies need to be competitive, but thereis a way to use the acceleratorstomodify the
traditionalFive Forces awayfrom a purely adversarialapproach to a more cooperative framework.
Adopting this new model can lead to sustainable change when companies commit to this approach.
ES Figure III: Cooperative Five Forces Model
1. Collaboration
Involving a broad rangeof stakeholders earlyand sustaining collaboration among themis the
first and potentially most important step in a new greenchemistry effort. It provides a way to
close thegap betweenwhat players in the supply chain say they want and their lack of
understanding of the impact of changeat each position in thesupply chain. Collaboration can
be beneficial when it occurs in virtually any combination within these five force areas, as well
as outside the direct supply chain with key influencers such as NGOs and government
regulatorybodies.
Collaborative efforts canhelp lift some of the barriers that have slowed theadoption and flow of green
chemistry. Collaborative discussions along the supply chain can ensure that

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o Green Chemistry Definitions and goals areestablished
o Price/Performancetrade-offs are reviewed (within appropriatecompetitive and anti-trust
guidelines)
o Transparency isaddressed
o Expectationsof Supply & Demand areshared
o A path is paved for New Technology Access andPlacement
o Some measureof Risk sharing is agreedupon.
2. Technology Forcing: Non-regulatory
Marketplacedecision makers with considerable “buyer power” force change. In effect, they
createde factoregulations. Technology Forcing can, like government regulations, drive
changeto green chemistry. Largeretailersand consumer product companies have a great deal
of market power to leverage. Exercising power should involve an appropriate level of
collaboration and compromise in order to ensure project goals areappropriately set and met.
This includes internalcollaboration betweenthe sourcing and sustainability groups at
consumer products and retailer organizationsto ensure greenchemistry and
price/performance needs are examined in tandem.
3. Compromise
When compromising, companies can acceleratetheadoption of greenchemistry by
embracing the principle of reasonable trade-offs. Accepting continuous improvement will
acceleratetheadoption of greener chemistry. Something “better enough” is better than the
status quo. It will not represent theultimate goal, but provides a step in the right direction.
This caninclude establishing timetablesfor economic improvement; evaluation of which
performance parametersarekey and which canbe relaxed; and temporaryeasing of business
standards like inventory turns, supply terms, etc.
4. Enhanced Education
Educated, informed and impassioned consumers can fuel the growth of greenchemistry. The
easiest way to acceleratetheavailabilityand adoption of greenchemistry is to start with a
greenchemistry design by way of an educatedwork-force. Consumer facing companies can
help drive growthby educating consumers about greenchemistry.

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ES Figure IV: S - Curve Model of Green Chemistry Adoption
Applying the four acceleratorsin a Cooperative 5-forces model can help to diffuse the supply chain
inhibitors and fuel the availability and adoption of greenchemistry.

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Advancing Green Chemistry:
Barriers & Ways to Accelerate Green Chemistryin Supply Chains
I. INTRODUCTION
A. Background and Project Goal
adoption of safer alternatives, and scaling of supply, in response to demands from regulatorsand
customers. However, overall progress is slow, measured in decades.
Numerous chemicals of concern (COC’s) have been identified: chemicals that are under regulatoryor
market pressures due toemerging science or consumer concerns. Many of these COCs, which are
considered by many to be in need of phasing-out, arestill widely used today.
The GreenChemistry & Commerce Council (GC3) commissioned T. Fennelly & Associates, Inc. (TFA) to
study factorsencouraging and inhibiting broad adoption and largescale use of green chemistry
innovations. TFA is a consulting firm focused on helping clients withvalue creationand market access in
the renewableand traditional chemical industry (see Appendix VII).
TFA spoke with leading industry experts and seasoned professionals on the subject. Many chemicals and
product categorieswere screened. Three specific COC s wereselected for case study review: Bisphenol A,
Formaldehyde and Phthalates. Detailedlearnings from those cases weredeveloped as a basis for
subsequent research and analysis. TFA utilized the researchto identify key barriers, drivers and elements
needed to acceleratethemarket availability and adoption of safer, greener chemistry.
B. Project Objectives
1. Provide insight on why greenchemistry and/or safer alternativesdo or do not reach scale, displacing
chemicals of concern.
2. Identify the role of market forces, incentives, policies, and other factors.
3. Profile threechemicals of concern, where efforts to build demand have or havenot worked and
identify lessons learned.
4. Outline the elements that can inform the development of a customer or market pull/supply
partnership project.
C. Project Methodology
In order to select the3 COC’s to profile, TFA began the project by compiling a list of 33 potential chemicals
and/or market segments that arecurrently being considered for market or regulatoryrestrictions. A
number of relevant, non-chemical examples were included that showed a migration towards more
sustainable solutions. These helped to provide a broader perspective on how industrial “greening”
practicescan occur. After discussion, TFA and principles of GC3 selected 13 of the 33 for brief review.

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13 Cases for Mini-Profile and Ranking
Phthalates
Phosphates
Halogenated Flame Retardants
Arsenic
Tributyl Tin
Isothiazalone
Dyes & Pigments
Lubes/Greases
Polystyrene
Bisphenol A (BPA)
Formaldehyde
VOC Solvents for Cleaning
Organic Cotton
TFA prepared a high level profile of the 13 cases that described the following:
• Sector
• Description
• Drivers
• Key Issues/Barriers
• Progress
• Potential for lessons learned
Finally, using co-developed criteria, TFAand theGC3 selected the threechemicals for case study research:
Phthalates, BPAand Formaldehyde.
D. Research Methods
Data for this project were gatheredfrom secondary and primary industry sources. All work was conducted
by experiencedchemical industry and supply chain personnel.
Secondary Research
TFA utilized secondary data sources for background to profile and analyzechemical casestudies and as
background for subsequent personal interviews.
Secondary Sources Utilized
Tradejournals
Published research
Industry/trade organizations
Government documents
Annual reports
Internet sources
Subscription databases
Non-confidential TFA files
Primary Research
Direct interviewing of industry participantswas conducted throughout thestudy. TFA relied on this
information to a great extent to ensure the quality and reliability of the secondary research and to obtain
specific information criticalto the GC3. Interviewquestionnaires weredesigned to meet the objectives of
this study and provide flexibility to obtain additional relevant information. Individual respondents’
identities and responses werekept confidential.
TFA startedthe interviewing process by speaking with a number of GC3 member companies to discuss
company experiences regarding greenchemistry. The remaining interviews wereused to flesh out the

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case studies and solidify findings.
The following tabledepicts thenumber of interviews completed:
Primary Research
Calls Completed
Total = 49
Sampling of Interviewee Titles
GC3 Member Companies 8 • Director of R&D
• Marketing Manager
• ProgramLeader Sustainability
• Air Pollution Specialist
• ExecutiveVP
• CEO
• Senior Toxicologist
• Director of Sustainability
• Chief Sustainability Engineer
GreenChemistry Suppliers 14
Formulators/Fabricators 11
RegulatoryExperts 6
Certification Organizations 6
Industry Experts/TradeGroups 3
Other BrandOwners/Retailers 1

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II. FACTORS INHIBITINGADOPTIONOF GREEN CHEMISTRY
A. Situation Analysis
Despite efforts from many stakeholders to accelerategreenchemistryuse, including those shown on the
accompanying figure, adoption ratesremain low.
Figure I: Current Green Chemistry Efforts
These multiple stakeholder efforts to drive the growth of greenchemistry havebeen slow. So, when there
aregreen chemistry alternativesavailable
• Why aren’t moregreen chemicals in use?
• What arethe barriers?
• What is the means to accelerate adoption?
In the course of undertaking this project and answering these questions, TFA has considered the entire
supply chain from chemicals to processors to fabricators and through to finished products both industrial
and consumer. TFA identified major drivers and deterrentsto growth. The complexity of supply chains is
enormous, consisting of thousands of chemicals formulated into literally millions of products. This
complexity inherently createsbarriers.
Eachposition in the supply chain provides a different a viewpoint for companies. This is trueabout many
things including greenchemistry.

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Figure II: Supply Chain Positioning Produces Different Vantage Points – Often at Odds
Complex supply chains areconnected and woven together withestablished incumbents. They have
developed an optimized and entrenched infrastructure, strong supplier-customer relationships and
maturecost positions. As such, the supply chains already have what can be defined as high degreesof
internal “alignment”. Thealignment is a balanceof an efficient operating infrastructurewithin thesupply
chain. Greenchemistries typically upset that alignment. Customer needs are multifacetedat each stage
and may resist or not support the demand for greenchemistry coming from other points in the chain. A
changeat one point in the chain may disrupt theestablished flow and practicesof therest of thechain.
For example, a change from a phthalateplasticizer to a new non-phthalate may require a change in
processing time, temperatureandequipment. If the materialis part of a foam layer, it may have different
adhesion properties; this could require a changein adhesives and coatings. The final product may have
different densities, requiring new packaging, shipment terms, etc. Understanding supply chain
positioning/alignment and the implications of changeat eachpoint in the supply chain is critical in
successful invention, modification, flow and adoption of greenchemistry.
These issues canbe called simply Supply Chain Misalignments. TFA has concluded that addressing these is
required for thesuccessful flow of greenchemistry. Nine significant supply chain alignment issues were
identified:
1. Defining GreenChemistry
2. Complexity of Supply Chains
3. Incumbency
4. Confusion
5. Switching Risk
6. Price/Performance
7. Supply & Demand
8. Transparency
9. New Technology: Access and Placement
These arenot in order of priority. Ininterview feedback, Price/performancewas cited most often as a
barrier to the adoption and flow of greenchemistry. However, these alignment issues areinherently
linked.
B. Defining GreenChemistry
Lack of agreement on how to define “GreenChemistry” canbe a hindrance to green chemistry flow and
adoption. Although often overlapping, there aremany definitions for “greenchemistry” in the
marketplace.

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Figure III: Varying Definitions of Green Chemistry
There areno universal metrics for greenchemistry. Metrics varyby industry and by company. For
example, one company will define greenchemistry products as those that are“safer”. Another company
will define greenchmistry as products that are renewableand biobased. Even these metrics areunclear.
If products are biobased, must the product be 100%biobased? How much is enough?
Figure IV: What is Green?

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Key take-aways on defining “green chemistry”:
1. It isn’t essential to pick a “right” definition for greenchemistry. It is essential to be on the same
page.
2. When starting a discussion, ask “How do you define GreenChemistry” ?
3. Coherent dialogue requires a common defintion of green chemistry. Without this, discussions,
messages, and conclusions canand will be misinterpreted.
IntervieweeFeedbackon “How do you defineGreenChemistry”:
“12 principlesof green chemistry although renewablemayor maynotbepartof it. Isittakingfoodoff the
table?”
“Need to havea perspectiveon whatyou areusing,when andwhere. Isita solventused to removebenzene
fromtheground or oneto putin a hospital cleaningformulation?”
“Chemicalsthatdon’tadverselyimpacthealth”
“Green Chemistry isproductsthatarenotPBT(persistent,bio-accumulativeandtoxic).”
“A productthatisderived insomepercentfromplantbased renewablefeed-stocks,environmentally friendly
and does notdegradeinto bad actors.”
AdditionalIntervieweeFeedbackon the definition ofgreen chemistry
“Productratingmethodologiesareflawedandbiased. They usea petroleumbasedlensthathasaltered the
viewfor novel non-petroleumbased technologies.”
“A leadingpolymerproducer marketstheir material asa biopolymer:<40%isbio-derived,>60%ispetroleum
based.Isthisgreen?”
“Our customer,a fabricatorof automotiveaftermarketproducts,said thata retailerwanted more
environmentallysoundproducts.Webidwith anon-phthalate,non-halogen stabilizer compound.Welostthe
bid dueto price. Weanalyzed thewinningbidproduct. Itwasmore“environmentallysound”in thatitwas
madefrom100%recycledmaterial. However thematerial wasrecycled wire& cablejacketingfromChina
which wasloadedwith DOPphthalatesand heavy metals.”

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C. Complexity of Supply Chains
Complex supply chains hinder shifts to new and often safer materials. Materialsuppliers must respond to
a diverse and complex set of needs, requirements, qualifications and demands for their products for the
many different applications and end-use markets. Conversely, many final customers like mass retailers
must traversea complex supply chain for the wide array of products on their shelves. Additionally all must
conform to industry requirements, standards, regulationsand customer perceptions and demands.
Figure V: Moving Tiers of Complex Supply Chains
BPA is one of the threeCOC cases reviewed for this work. BPA is used as an intermediatein ETP
(engineering thermoplastic)production for polycarbonate (PC) and structuralepoxy thermoset resins; as
an intermediatein epoxy coatings and as an additive in developers used in thermal receipts. Each supply
chain is different than theothers, with a complex network of varying participants (sellers, buyers, and
distributors), influencers and decision makers.

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Figure VI: BPA Multiple Complex Supply Chains
Supply Chain: BPAResin Intermediate
Supply Chain: BPAEpoxy Can Coating
Supply Chain: BPAThermal Receipts

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Key take-aways on supply chain complexity:
1. Eachsupply chain position has its own vantagepoint, a different viewpoint from others in the
chain. Working to understand thecomplexities and challenges that eachset of stakeholders face
in the supply chain can improve communication and eventual flow of greenchemistry.
2. Complex supply chains createfragmentationof demand by application, volume, specification,
customer expectation, geography, etc.
3. Suppliers and customers must be knowledgeable about and work with many different supply
chains.
4. In complex supply chains, demand for new innovative technologies is diffuse. This challenges the
development and adoption of these innovative new technologies
5. Processors, formulators, part manufacturersand other intermediatesin the supply chain often
block or cloud communication flow in the channel.
6. Complex supply chains arealigned. Steps areconnected. A changein one point of the chain can
impact supply dynamics at other points in the chain.
D. Incumbency
The chemical industry is anchored by multi-billion dollar petroleum-based incumbent companies that have
built global capabilities. Many have integratedrawmaterialstreamsand products with optimized and
proven process economics, well-understood product performance data, market expertiseand established
customers. They know how to compete globally. They have multiple production sources for the same
product. They have global regulatoryregistrations. Some capitalizeon their country’s natural resources,
low labor costs and government subsidies or ownership.
Customers know their suppliers and the supply chain. Strong working relationships have been established
at many points in the chain: Tier 1, Tier 2, Tier 3 and in some cases back to theraw materialsupplier.
This infrastructureis a challenge for all new entrants, greenor not, to compete withthe established
supply chain. However, greenchemistry has some added challengessuch as confusion, risk,
IntervieweeFeedbackon Complex SupplyChains:
“Choosecarefully- complex supply chainsarealigned;stepsareconnected;a changeinonepointof thechain
can impactsupplydynamicsinother partsinthechain.”
“Need to strengthen thecommunicationin themiddleof thechain. Itisvery difficultto getmaterialsthrough.
The processorsareresistant.“
“Footwear and apparel arearchaic industries. Thesupplychainisvery complexanddoesn’tlenditself to
change. When ithappens,changeisslow.“
“Processors/fabricatorshaveinvestmentincapital equipmentthatmay notwork withthenew
materials/innovation.Re-trainingiscostly too.”
“Understandhowtheproducts/processesareconnected andthechannelsarewoven together.”
“Supply chainshavealwaysbeen complex,butnowthey aremorecomplex with theretailersactively involved,
tryingto offer whatisrightfor theconsumer.”

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price/performance, supply & demand, transparencyand access and placement of new technology, which
aredescribed below.
Key take-aways on incumbency
1. Incumbency createsenormous barriers to change, barriersinclude
a. Entrenched supplier-customer relationships
b. Low costs, generallyfacilitatedby largescale production and logistical efficiencies
c. Low totalcost of ownership which may be facilitatedby manufacturing equipment
optimized for the incumbent product
d. Availability of multiple suppliers and sources that createsprice competition and lowers
risks of shortages
2. Incumbents will generally resist changeout of self-interest. Incumbents don’t want their assets to
become obsolete.
E. Confusion
Although the term“toxic chemical” produces a universal reactionof “bad”, conflicting campaignsare
producing widespread confusion about what specific chemicals fall into that category. This uncertainty
and confusion has slowed and stalled the adoption of greenchemistry.
BPA is an example of this uncertainty. BPA is used in such diverse applications as
IntervieweeFeedbackon Incumbency:
“Choosesegmentswhereyou can effecta change. Itisanuphill battleto getvertically integrated producersto
change.” (I.e.particleboardproducerswho harvestwoodandalso makeformaldehydebased binders;
polycarbonateproducerswho producetheir own BPA)
“Over 11Blbs.of phthalatesareused globally inPVC compounds. “Newplasticizer supplierscan’tbringusthe
volumeweneed globally,price/performanceandknowledgeof our performanceprofile.”
“A new supplier can’toffer us consistentquality volumefastenough or guaranteemorethan onesource.”
“PC and epoxy areperformancepolymersthatwecan sourceglobally. They havetheprice/performanceprofile
we need. There areno effectivealternativestoday and mostapplicationsarenotconcernedaboutBPAasa
productionintermediate.”
“The overhead isverycostly to bringnewgreen chemistry productsto market. Theincumbentshaveno incentive
to changethis. Itkeeps competition outof themarket.”
“The existinginfrastructureisso efficientthatitishard for newentrantsor technologiesto catch up. Itwilltake
timeand often thecustomersarenotwillingto wait.”
“Largeincumbentshavetheinfrastructure,processtweaked,volumes/scaleand costadvantage. Green chemistry
needs to do someseriouseconomiclandscapingto competewith incumbentsupplyandeconomics.”

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• An intermediatein the production of polycarbonate engineering thermoplastics and epoxy thermoset
resins
• An intermediatein the production of coatings like food can coatings
• A developer for thermalretailreceipts and tickets
Chemically, BPA resembles synthetic estrogen and thereis concern that BPA is an endocrine system
disruptor. There is a deeply divisive tug-of-war going on today regarding thesafety of BPA and BPA
substitutes:
• Studies & Research: Conflicting safety information has clouded and confused the industry. Thereare
hundreds of toxicological studies and researchwith diverging results regarding its link to cancer, heart
and kidney disease, prenataldevelopment and behavioral disorders.
• Policy: Therehas been a largeinternational and national movement to restrict BPA from baby bottles
and children’s products, in largepart driven by consumer demand. However, theUS FDA recently
declared that "at current levels of exposure"1
BPAis safe in all other food packaging. As of January
2015, France banned theuse of BPA from food packaging and thermal receipts2
. But, in January 2015,
EFSA (European Food Safety Authority) published its latest comprehensive re-evaluation of BPA3
.
They concluded that exposure and toxicity from BPA poses no health risk to consumers of any age
group (including unborn children, infants and adolescents) at current exposure levels.
• Rigorous Lobbyingfor and against BPA’ssafety and use areclouding and confusing the market.
o Against Restrictions: AmericanChemistry Council (ACC) and their website FactsAboutBPA.org,
Bisphenol A REACH Consortium, GroceryManufacturers Association (GMA), North American
MetalPackaging Alliance (NAMPA) and others
o For Restrictions: Japan MetalIndustry, AmericanMedical Association, certainbrand
manufacturers, HealthyHospitals, other environmental and consumer healthNGO’s
• Viable technology andCost/PerformanceSubstituteshavenot yet been clearly identified:
o EPA DfE conducted an alternativeassessment to BPA for thermalreceipts which did not
identify clear options as thermal developer substitutes.
o Infrastructureof thermal printing machines makes replacing with a non-thermal technology
cost prohibitive.
o Polycarbonate and epoxy arework-horse polymers that the industry is reluctant to change.
In another example, thereis confusion createdby the rigid rating methodologies of some programs. TFA
heard from a number of greenchemistry interviewees that there is a concern that programs like EPA’s
Design for Environment Program(DfE), now called Safer Choice, can do more harm to a new technology
than good by labeling a type of new greenchemistry as a potential hazardbased on historical
petrochemicaldata. Intervieweesdescribed receiving a Yellow triangleby default based on a
chemical functionality. (“The chemicalhas met DfE criteria for its functional ingredient-class, but has
some hazardprofile issues.”4
)

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Key take-aways on confusion
1. Conflicting information continues to confuse the industry.
2. Stakeholders areat times grid-locked, not making a changedue to uncertaintyabout the status
quo.
F. Switching Risk
There is concern that switching to green chemistry alternativescould leadto market failures such as poor
performance, brand tarnishing and other hidden costs such as process or equipment or process changes,
materialincompatibility, workforce training, customer education and others.
For example:
• A PVC blood tube manufacturer switched to a citrateplasticizer from thephthalateplasticizer; the
high migration of the citratecaused theadhesive on the tube clamp to fail.
• A furniture manufacturer substituted traditionalfiberboard with a green board to eliminate
formaldehyde based binders. When laminated, the greenboard had inferior impact resistance and
dented when heavy objects wereplaced on it.
• PepsiCo took a chancemaking their Sun Chip bag with a compostable biopolymer. The brand took a
hit when the public pushed back on the “noise” of thebag.
• A metalcleaning operator switched to a greener solvent option, but found that throughput was
significantly slowed due to longer dry times.
There is also therisk of adopting a “better bad”. Those who switched from DOP to DINPplasticizer are
finding they must now switch out of DINPfor similar toxicology concerns. Similarly, those who switched to
Bisphenol S from Bisphenol A have found there is little toxicological profile improvement.
IntervieweeFeedbackon Confusion:
“Conflictingtoxicologyreports& conflictinglegislation keepstheindustryandthoseconsumingconfused.“
“Very partisan and absurd conclusionsaredrawn by conflictingsides. Thisconfuseseveryoneinthechain.“
“Consumershavebeen askingus aboutepoxy powder coatingon ourproductsand exposureto BPA. ThereIs
BPAatthe surfaceanditcan comeoff. Wearetryingto understandtherisk.”
“Itis notblack andwhite.Hospitalsstarted banningBPA,butitisused ineyeglasses,medicalequipment,DVDs,
etc. Customers werenotwillingto givetheseup,so they wentback andrelaxed thestandardsfor theseareas
of less concern.”
“The industry isswitchingto DOTP which isaterephthalate. Isn’tthatstilla phthalate?”

23
Key take-aways on switching risk
1. Stakeholders arecautious to make sure they have the information needed to make sound
chemical management decisions.
2. No one wantsto adopt a “better bad” or introduce a greener product that fails due to switching
risks.
3. This slows themarketplace’sdrive toward greener chemistries.
G. Price/Performance
Typically a new entrant or new technology introduction is driven by some improvement in
price/performance, e.g.:
• Better heat performance, scratchresistance, easier to fabricate, better impact resistance,
reduction in processing steps, cheaper rawmaterialstream, regionalavailability, volume
economics, etc.
In contrast, thedrive for “greenchemistry” is often aimed at displacing a current technology that is
working well. The new products may have a better EHSprofile, but often areinferior in performance or
higher cost. Thereareadded switching costs beyond the price/lb. such as cost-in-use, customer re-
qualifications, changes in formulation, changes or investment in processing equipment, throughput, etc.
Many of the target products being replacedare commodity materials. Even though long termcost profiles
may in fact be better (reduction in hazardhandling, disposal costs, intangible benefits like reduced toxic
exposure) this can be a harder “sell” as a replacement for theoptimized volume-ready commodity.
Although largeretailersand brand owners arepushing for greenchemistry, therecontinues to be limited
willingness to accept any changein price/performance.
IntervieweeFeedbackon SwitchingRisk
“Weasked our supplier to taketolueneandother VOC’soutof theadhesivesforour products.Thesupplier
chosewater based systemfor theconstruction,butused THF (a knowncarcinogen).”
“There is alwaysthedanger of impactinga product. No onewants to tarnish their brand.”
“Wearecautiousaboutswitchingto a non BPAink developer. Wedon’twantto choosea ‘better bad’.”
“Bigconsumer productscompanieswantgreen,butarevery cautious. If they arefirstinandthe
supply/technologyisa “flash inthepan”they arecompromised.Thelargeplayersarelookingfor a guarantee
of supplylongevity to maketheswitchingcostsworthwhile.Thishasslowed adoption.”
“Weswitched awayfromtheDOP plasticizer to DINP. NowDINP ison Prop.65.“
“For 80 yearstheindustry hasformulated inoneway and nowthey arebeingasked to change.Thereis a
resistancedueto thecosts,requalificationsandpotential failure.”

24
IntervieweeFeedbackon Price/Performance
“The biggestissuewith green chemistry developmentisa lack of viablealternatives thathavethenecessary
cost/performance.”
“Wefind thatthegreener productsareeither poorerperformanceand/orhigherpriceandthemarketcan’t
sustain this. Itisgettingworsewith thelowoil prices.”
“There arenotany plasticizersthathavethepriceperformanceprofileof phthalates.Thisisthebiggestreason
why therehas notbeen moregrowth in replacingphthalateswith bioplasticizers.”
“Wehaven’tbeen ableto eliminateformaldehydedueto cost/performance.Theformaldehydefreepanels
don’thavetheimpactresistanceneeded.”
“There areoften savingsinusinggreen chemistry:reduction inhazardousdisposal,reduction in recovery
equipment,water treatment,handlingconcernsandothers. However thistotal costsolutionisa toughto
quantifyfor customersfocusedon $/lb.”
“Even atprice/performanceparity,selectinga newmaterial iscostly:requalification,lab costs,certification
costs,processingand equipmentchanges,training,etc.”
“Performanceisfirst;EH&S is nextand then sustainableisa niceadd-on.”
“Retailersactschizophrenic. In onebreath they say they wantgreen and in anotherthey want
cost/performanceand supply parity.”
“New materialsarenotdrop-inreplacements:UVstability,migration,smell,colorandother factorscan change
the production processand finalproductperformance.”
“Many of thebiobased solutionsarenotasgood and are$1-$2moreper pound.”
“Our customersdon’twantto pay more. If therewerea cost/performancesolutionoutthere,wewould useit
to makeformaldehyde-freebinders.”
“Our newmaterial for cleanerswasnota drop in replacement. Theproductwasn’tmoving. Wediscovered
thatformulatorsneeded formulationsuggestionsfortheirmicro-emulsions.”
Largeretailers:
“Say they wanta greener productbutwon’tbudgeon price.Consumersarethesameway.”
“Green is nottheir priority-priceis”
“When we delivered therequested green solutionfor a lawnand gardenproductto our customer(a large
retailer),they rejected itinfavor of thelower priced phthalateplasticized PVC product.”
“The sustainability panelswithin largeretailerswork to drivenewtechnology and sustainablesolutions. Then
the sourcingagentsturn thealternativeproductsaway becauseof price. Thereneedsto bealignmentand
communicationwithintheorganization.”
“Everyonewants to do therightthing,butwecan’tbealtruistic. Sustainability mustbeaffordable.Weareall
financiallydriven.“
“Larger wood companies havestuckwith UF becauseof thespeed of curingpolyvinyl acetateincreased curing
timecosts too muchfor largescalewood board production.”

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Key take-aways on price/performance
• Price/performance was themost citedreason for the slow adoption of greenchemistry
• Significant degradationin performanceis unacceptablein most cases. On the other hand, there may
be room for some compromise on price and performance.
• Often thereare savings in a totalcost analysis such as reduced hazardouswaste handling and disposal.
This canbe hard to quantify for customers focused on $/lb. pricing.
• Entrenched COC’s have set the standard for price/performance.
- Change will continue to be slow without leadership, a game-changer or catalyst.
H. Supply & Demand
New technology supply and demand is a “chicken and egg” dilemma. Newchemical plant investments
takeyears and may cost hundreds of millions of dollars. Materialsuppliers often find thereis not enough
realor perceived demand to justify the investment. Conversely, producers and customers expect a new
technology to ramp quickly, perform seamlessly, be available from more than one source and meet large
volume needs. Uncertainsupply and demand commitments can jeopardizetiming and investment in the
supply, thus slowing the availability of and adoption of greenchemistry. These lower volumes mean poor
economies of scale that inhibit cost competitiveness with incumbent solutions.
Materialsuppliers must identify, qualify and quantify the demand needed to invest in new material
production, while getting management buy-in and meeting return on investment needs. Often a new
technology will require step changeimprovements, quality modifications and staggeredinvestment to
reachscale. Building scale is costly with product development and commercializationcosts,
environmental and compliance testing and regulatoryregistrationslike TSCA and REACH.
Processors and producers arekey to building demand and areoften reluctant to change due to concern of
sole sourcing and limited or lack of global supply. Incurring transition costs and requalification costs for a
source that maynot growis risky. Once thenew product is approved or qualified, the fabricatorsand
customers are often impatient at the slow growth of a supply infrastructure and products.

26
Key take-aways on supply & demand
1. There is often not enough realor perceived demand to make increased production worth the
investment.
2. Stakeholders arecautious to move forwardto commit to demand or to commit to supply.
3. Supply infrastructure growthwill be slow without compromise and collaboration during the
planning process and mutual long-term corporatecommitments.
4. Strong partnerships can ensure this occurs.
o For a sustainable partnership, both partiesmust see a win/win.
I. Transparency
Transparencyincludes thefull disclosure (visibility) of all ingredients in a finished product. Demanding
transparencycan stifle innovation. Blocking transparencycan createconcern and potential liability for the
unknown ingredient. It canslow industry acceptanceespecially in segments or programs requiring
transparency. This “us vs. them” strugglehas slowed the flow and adoption of green chemistry.
IntervieweeFeedbackon Supply&Demand
“The productshavenotdelivered thehopeof morestablesupply and price.Fluctuatingpriceand availability of crops
for biobased productshaveplaguedtheindustry.”
“Weneed millionsof poundsof plasticizerfor each application. Thisisabighurdlefor newtechnology plasticizers.
Wemusthavethatand a qualified 2nd
and3rd
source.”
“Findinginnovation partnerswhocanprovideproductglobally isdifficult”
“New technology comingoutof universitiestakesa longtimeto commercializeandbecomea viablesupply.”
“The newthermal paperis20%moreexpensive. Thepricewill comedown when wescale,butweneed the
demand.”
“Often the newbiobased products also haveissueswith their startingrawmaterial supply. Withouta supplyof cost
effectiverawmaterials,biobased productswill struggleto makeheadway.”
“Often new green chemistry technologiesdon’thavethesupply,can’tgetthefundingto build theplantor the
processeconomicsdon’twork. They end up notproducing aspromisedor go outof business. Wespend a lotof time
and money to testand go through all thehoopsto getthenew technologyto work with a zero outcome.”
“Priceandcommitmentto build a newchemical plantishuge.Itisa ‘trickle-up’demand:builda $600MMplantand
then get the sales. Thisisrisky.”
“Weneed to havevolumeandreliability of supply. Thegreen chemistryfeedstock sourceandproductionhasnot
caughtup.”
“Volumeand availability arecrucial. Wecannotswitch materialsuntil itisthere.”
“Customers arereluctantto committo a newsupplythatmaynotgrowor mayclosedown.”

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Materialsuppliers arestriving tomeet the demands for innovation, greener supply and transparency.
Often the need to protect IP and/or Trade Secretsis criticalin the positioning and availability of new
technology. Releasing this information too early can result in
• Loss to low-cost imports & technology knock-offs
• Loss to largecompetitors that blanket patent around thenew IP and tie up commercialization
• Loss from costly IPbattles with larger corporations to defend thenew technology
• Loss of competitive position when tradesecret formulations are madepublic
Product manufacturers, consortiums and retailcustomers aredriving transparency. Thecriticalneed is to
mitigatetherisk in handling or selling products with unknown ingredients that could be COCs. They need
transparencyto
• Eliminate chemicals that canharm human healthand environment.
• Identify chemicals that might introduce liability and/or tarnish brand and company image. This
also includes avoiding product recalls or disruption in supply and distribution.
• Respond to consumers’ demands -“right to know”.
• Comply with EHS standards both from a safety standpoint and to meet the global, complex and
changing legislation landscape. California Air Resources Board(CARB) and Prop 65 are really
driving this in the US.
This need for transparency has fueled a growthin stakeholders issuing mandatesbased on restricted
substances lists or incentives for purchasing or product placement. Some examples include
• BrandOwner Transparency Programs: Nike, Apple, Patagonia, Googleand others
• Conventional TradeOrganizations Driving Transparency: BIFMA, OIA
• Industry Groups formed to drive GreenChemistry & Transparency: ZDHC, HealthyHospitals,
Bluesign, Personal Care Products Council, Sustainable Packaging Coalition, US GreenBuilding
Council (HPDs and EPDs) , others
• Retailer DrivenTransparency: Wal-Mart’s“CorporateChemical Policy” and PrivateBrand DfE
(Safer Choice) labeling , Target’s“Sustainable Product Standard”, others
• Certification Procedures/Databases/OrganizationsDriving Transparency: Green : GreenScreen
from NGO Clean Product Action, Pharos(Building & Construction materialevaluation), C2C (Cradle
to Cradle)Product Standards, WERCs (GreenWercs, SmartWercs) (assesses formulation chemicals),
CleanGredients (from DfE), LEED, MaterialIQ(via Greenblue), IMDS (MaterialData System for
Automotive Materials), INCI (Cosmetic Ingredients), Leather Working Group, others
• Government TransparencyPrograms: Safer Choice, California Safer Consumer Products
Legislation, others
These many programs often require different certification procedures, disclosure mandatesand testing
requirements. Identifying which certifications topursue and obtain is a costly and timeconsuming
process for suppliers.
In an effort to protect IP and tradesecrets, materialsuppliers have required CDAs (Confidential Disclosure
Agreements), MTAs (MaterialTransfer Agreements)and 3rd
party testing or certifications. When
programs mandatedisclosure, new innovations and technology introduction can be slower as companies
look to commercializein areas that don’t require disclosure.

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Key take-aways on transparency
1. More transparencyis occurring, much by force.
a. Suppliers are looking for ways to satisfy customer demands while protecting IPand trade
secrets. This can result in slower new technology offerings as companies wait to secure IP.
b. Customers areskeptical of the chemicalindustry’s reluctanceto be open and transparent.
2. Transparencyconformance and certificationprograms and agenciesabound. This is a costly and
time consuming process for suppliers.
a. Eachmarket has its own NGO/agencyor certificationrequirements – often more than one.
IntervieweeFeedbackon TransparencyIssues
“Emphasison secrecy isoverdone. There’sa need for willingpartnersto gettechnologyoutwithoutfeeling
threatened.”
“Itis very hardto collaboratewithmaterial suppliers. They play thecompetitorgameand will notbetransparent.“
“IP is our breadandbutter. Wetry to patentandprotectasmuch aswecan,butsometimesa “recipe”isrequired
and wemustdecidewhether to reveal ornot. Often certificationsask forour formulaeand itcanbea problem.”
“The demand for transparency ismakingithardto surviveinthemarket.Bigincumbentsarepredators. They enter
the spaceand blanketpatentandpricearound ourpatentsandtradesecrets. Thisplacesa block on themarket. It
makes itvery tough and takesvalueoutof themarket.”
“Wewanttransparency,buteven NDA’s withcustomersdon’talwayswork. Customersoften don’tknow
everythingintheirformulations.”
“Wego all theway up theline:Tier1,2,3 to therawmaterial supplier and demandfull formulation ingredient
disclosure. Ahigh percentwillnotdiscloseeven under NDA.”
“The newCARB requirementsarekillingus. The2013 ConsumerandCommercial ProductsSurvey compliancedate
is March1,2015. Wemustreportdetailed revenuedataand formulationinformation. Thereisa box to check to
keep theinformation confidential,buttheindustryisvery worried.”
“Fragrances areanissue.Wedon’talwaysknowwhatisin thefragranceformulationgoinginto ourproducts.”
“Tests found highlevelsof formaldehydeinchildren’sclothingfrommajor apparel brands. Thelevelsexceeded
industry standardsandwerenotapprovedby thebrandowner. Thereisan issuewith policingtheproducts,even
when transparency isin place.”
“China hasposed problemsforus. Wehaveclear ingredientand COC restrictionlists,buttherestricted chemicals
still showup in theproducts- example:hexavalentchromium. Itisveryhard to monitorandregulate.”
“As a fabricator,weneed to eliminateCOC’sfor ourproductdisclosuresto our retail customers.Even with NDA’s
our suppliersdon’tknowtheexactingredientsin theformulation.”
“SinceTheHealthy Hospital Initiative,wearegetting1-2 requests/week fortransparency in ingredients.”

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J. New Technology: Access and Placement
Finding and vetting green chemistry materialsremains a weaklink. Materialsuppliers struggleto identify
early adopters. Customers struggleon whereto look for new solutions beyond thetraditional supply
chain. An additional blockage is theconventional level of secrecy within the supply chain among
formulators, compounders and processors (outlined above as a lack of transparency). This searchfor and
identification of a home for new technology can be hit or miss and slows the flow and adoption of green
chemistry.
New materialsuppliers often have limited access to a maturesupply chain. Truly new technologies within
an existing company can have a slow start, dwarfed by base business or outside current target markets. In
both cases these companies struggleto:
• Identify markets, segments and segment leaders
• Identify early adopters
• Choose certifications necessary to enter a segment
Customers, formulators/compounders & processors may want alternativesand access to greener
products, but they have limited access outside their established supply chain. These companies struggle
to:
• Find alternativesoutside the existing supply chain.
• Make decisions to add suppliers or products, when corporateobjectives to reduce suppliers or
qualify suppliers are barriers.
• Understand the viability and relativeattractivenessof the options that are out there. (Thereare
hundreds of eco-labels which cancreatefurther confusion.)
• Make theright choice. There is a fear of choosing a “better bad”. Also thereis “Greenfatigue” –
i.e., a perception that if everything is green, nothing is green.

30
Key take-aways on newtechnologyaccess andplacement
1. Finding and vetting green chemistry technologies remains a weaklink.
a. Suppliers struggleto identify early adopters.
b. Customers struggleon whereto go beyond the traditionalsupply chain.
2. The flow is slow, but collaborations and other activitiesare beginning to open up the flow and
access to technology.
IntervieweeFeedbackon Access/PlacementofTechnology
“Wetried to find a sustainableparticleboardformaldehydefreeproduct. Weused a wheatboard fromDow
Bioproductsin Canada. Theplantclosed. Weswitched to a soy board fromAgristrandinMankato,MNand
they closed.Itisexpensiveto testand approvetheproducts,passthemin thefield,commercializeandthen
startover when productsbecomeunavailable.”
“Findingnewtechnology isachallenge. Wearedoingmorecollaboration with individual suppliersand now
with a group of majortraditional chemical suppliers,butthey don’twantto collaborateon a real partnership
basis. Thereisdifficultywith theinvestmentand reward.”
“Findinga placeforour newtechnology canbechallenging- especiallyfindingtheearly adopters.”
“Wehavea hard timefindingnewtechnologies. Wehavetheexistingsupply chain,Dow,DuPont,BASF,but
the flowof truly newinnovationsisslow.”
“If we do go with somethingreallynewand thecompany doesn’thavethetestingcapabilities,weincurhigh
costs to testand wearenotan R&Dcompany.”
“The EPA BPAalternativeassessmentprogramdid notuncovercommercially viablealternatives. Whereare
the alternatives?”
“Wehave“partnerships”with our currentsuppliersand areprotectiveof that. However,they don’thave
accessto someof thenewesttechnology.”
“Wehavea corporatepracticeof enteringinto technologycollaborationswith newsuppliers.Ourcompetitors
lay in waitto seewhatwecomeup with.”
“Werely on our currentsupply chainto bringusinnovation.It’s notworkingso well.”
“Welook to universities,tradeshows,technologyscouts,patentfilingsand ourcurrentsupplychainfor new
technology. Itisa slowprocess.”

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III. EXISTINGDRIVERS FOR CHANGE
The issues that createbarriers for broader adoption of greenchemistry identified in this report are
obvious strong impediments to growth. They can cause misalignment. They haveweighed down the flow
of new greenchemistry adoption.
Figure VII: Nine Issues That Can Misalign Green Chemistry Supply Chains
Much of theprogress to datecan be attributedto two main drivers, Government Regulation and
Consumer Awareness. Beforeevaluating growth acceleratorsthat canbe leveragedto createnew
approaches, it is worthwhile reviewing theexisting drivers.
A. Government Regulation
Governmental policies have forced the elimination of certainchemicals of concern, often in specific
applications. In other cases they have simply forced reductions to exposure to these chemicals. The U.S.
government has also encouraged theuse of bio-based products with programs like USDA BioPreferred.
Regulationcan drive new technology availability, demand and adoption. In one examplefrom thethree
subject COCs studied in this project, the Center for InternationalEnvironmental Law5
found that therewas
a spike in patentednon-phthalate inventions that correlatedwith European REACH regulations.

32
Figure VIII: REACH Phthalate Regulations Correlate with a Spike in Non-phthalate Patents
Source: 2013 Article: Driving Innovation: How stronger laws help bring safer chemicals to
market (The Center for International Environmental Law)
5
In another example, therecent listing of DINP6
(Diisononyl Phthalate) on California Prop 65 has spurred
increased production and demand for non-phthalate plasticizersas reported to TFA during interviews with
fabricators.
Although regulations and other government policies (such as purchasing) can drive the development of
new chemistries, they canalso be a factor in thebottleneck of greenchemistry availability. New
chemistry triggersnew chemicalnotification and potential regulatoryrequirements. If the chemical is
used as an intermediatein the manufactureof downstream derivatives, this mayalso trigger new
chemical requirements for each of the derivatives. Costly delays due to insufficient models that
overestimatehazards canoccur. For a new chemistry, particularly from a small company with limited
toxicology or regulatorysupport, this can be challenging.
RegulatoryRegistration ofaNew Product:
• In theUS, the main lawregulatingchemical production isTSCA(ToxicSubstancesControl Act),which is
implemented by theEPA.Similarrequirementsarein forcearoundtheworldsuch asREACHin Europe.
• The TSCAInventory isa listof morethan 80,000chemicalsincommercial productionanduseintheUnited
States. If a chemical isnoton it,a company generallymustfilea pre-manufacturenotification (PMN) with
the EPA.
• In theabsenceof chemical testinginformation (astestingisnotrequiredunder thePMNprocess),EPA
mustusemodelsto predictchemicaltoxicity andpotential exposures. Thismodelingmayoverestimate
hazards.If thereviewshowspotential concerns,theagency canplacerestrictionson marketingof the
chemical.ThePMNprocesscanthen bedelayed or specific testingor reviewrequirementsknown asa
“SNUR” – significantnewuserules may beinstituted. Additionalsecondaryapproval requirementssuch as
thosefromtheFDAand FiFRA(Insecticidesand pesticides) aswell asstatelevel reportingrequirements on
products(WA,ME) may alsoberequired.

33
TSCA is seen by many stakeholders as flawed, discouraging the growthof newer, safer materialsand
having fallen behind in its ability to provide for protection against COCs. Appropriate revisions or
modifications to EPA’s review process for new chemicals might help fast trackthe reviewprocess for
greenchemistry.
Statesalso have regulatoryrequirements for chemical use and reporting. They arenot harmonized and
have varying registrations, standards and reporting requirements. Compliance is an especially heavy cost
for smaller companies. California leads the states in its regulatoryrequirements. One such regulationis
the California Safer Consumer Product Regulations intended to improve the healthand safetyof all
Californians by providing theDepartment of Toxic Substances Control (DTSC) with theauthority to control
toxic substances in consumer products. The DTSC has identified 1,200chemicals of concern and is
required to identify priority chemical-product combinations for which manufacturerswould be subject to
conducting alternativesassessment.
California standards areoften adopted by other states. California requirements also drive material
suppliers to unify their offerings based on California standards. This is referred to as the “California
Effect“andis fostering the growthof greenchemistry. As mentioned earlier, California standards arealso
driving transparency in certainareas.
IntervieweeFeedbackon GovernmentRegulation
“The EPA picked themoleculesfora readacrossinour TSCAsubmission even when wesuggested thatwasnot
good comparison. Theproductwasflagged. In order to avoid a SNUR,reworkandadditional costly testswere
required. The90 day processturned outto beover a year.”(Similarcommentswerementioned by 3
companiesinterviewed.)
“Our producthasthesamechemical structureasthepetroleumproduct;thedifferenceisthatweare
producingitfrombiobased,renewableresources. TheEPAsayswearenewchemistryandmustfilea PMN.
This iscostlyandtimeconsuming.”
“Weneed an efficientand effectiveregulatory reviewprocessthatdoesn’tpenalizeinnovation. Weneed to be
ableto moreeasily commercializeinnovativenewchemicalsthatcan provideimproved and safer productsfor
consumers.”
“Companies arestrugglingto meetall thedifferentstaterequirements–varyingregulations,differentcountry
registrations,overhead of theregistrations,meetingall thepaper-work,costs,keepingup with thestandards,
and thereporting. Itisall veryexpensive. Thismakes itextremelydifficultfor newtechnologyofferings.”
“If regulationsforceusto stop usingphthalates,wewill.Otherwiseitislikepushingstringto getour customers
to change.”
“MN passed theToxicFreeKidsActin 2009 which bansproducts likeformaldehydeincertain children’s
products.”
“Modify EPAprocessto fasttrackgreen chemistryregistrations.”
“Reach is drivingour textilematerial choices. Itismorerestrictivethan TSCAandimpactstheglobalsupplyand
complianceof theindustry.”

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Key take-aways on government regulation:
1. Regulatorybans and restrictions have been and will continue to be a big driver for green
chemistry.
2. The difficult and costly regulatoryprocess for new product registrationscan act as a hindrance
to product availability, demand and adoption.
3. Additional secondary approval requirements (FDA, FIFRA)and statelevel reporting
requirements on products (CA,WA, ME) canadd additional challenges to greenchemistry
products.
4. This canbe challenging for a new chemistry, particularlyfrom a small company with limited
toxicology or regulatorysupport.
B. Consumer Awareness
As described earlier, thereis a generalcorrelationbetween end consumer awarenessof COCs and their
replacement. Concern over endocrine disruption properties of BPA and phthalatesfueled consumers’
demand for BPAand phthalatereplacements. While other industry applications for BPAand phthalatelag
in adoption, consumer focused applications have had success in driving greenchemistry. These areoften
called “consumer-centric” segments. The generalcorrelationbetween awarenessand replacement is
shown below for BPA.
Figure IX: Consumer Awareness and Demand Drives Green Chemistry Adoption
Researchstudies and results published can also createanup-tick in new technology demand, even in
areaswhere overall consumer awarenessis just starting. For example, a leading thermalpaper supplier
described an increasein demand for their BPA and BPS free thermalpaper: “We have seen a significant
increase in requests for our products as a result of the 2014 University of Calgary study.”

35
(The Calgarystudy reported that both products disrupt normal brain-cell growthand are tied to
hyperactivity7
.)
Consumer awareness canbe generatedby multiple means, but has largely been driven by NGO efforts.
Social media, theinternet, print and television news journalists have also played a role. This effort is likely
to increase in the future. Consumers can force a change.
Key take-aways on consumerawareness:
1. Awareconsumers can force a changeand drive change to greener chemistry.
a. This changeoccurs independent of legislation or lobbying. “Perception is reality” to the
consumer.
2. Consumer education can heighten consumer awareness and acceleratethisgreen chemistry
demand.
IntervieweeFeedbackon ConsumerAwareness
“Consumerswereconcerned aboutformaldehydeinour personalcareproducts. Wehavemadea
commitmentto removethemfromour formulations.”
“Wehavebeen receivinganincreasingnumber of inquiries aboutBPAin foodpackagingand in ourthermal
receipts. Wehaveactively been workingwith suppliersto removetheBPAfromtheproductson our shelves
and fromour thermal receipts.”
“So much is in thepower of theconsumer. They knowlead-free,buthavea very simplisticunderstandingof
other chemicals. Educationiskey.”
“Wearein thefashionindustry. Nicheusers(consumers) careaboutsustainability. Othersdon’tknowor care
as much. Abigeducation effortshould takeplaceto drivedemand.”
“Consumersdrovephthalatesoutof baby itemsand toys.”
“Wehavestarted usingsafer developersin ourthermal papers. Consumersarepushingback becausetheprint
is lighter than thedark printthey getwith theBPAdevelopers. Thecustomer baseneeds to beeducated to
compromisewith a lighterprintto geta saferproduct.”

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IV. ACCELERATINGADOPTIONOF GREEN CHEMISTRY
A. Introduction
Accelerationof greenchemistry is difficult due to the tug of war between and within pro-green chemistry
and entrenched industry “camps”. There arebasic problems of agreeing todefinitions of greenchemistry,
supply chain complexity and other misalignments between stakeholders across thesupply chain. All
indications arethat these forces will continue to bombard regulators, customers, suppliers and other
stakeholders with alternateviewsthat will, in fact, slow related progress. Similarly, this will continue as an
“us versus them” tug of war between those who want changeand those who prefer the status quo. Pro-
greenconsumers are frustratedand angry at the lack of progress, while industry bemoans that consumers
aren’t viewing risks rationally.
Many of these issues arecompounded by industries functioning within the traditionalstructure of the
supply chain as highlighted by Porter’sFive Forces Analysis, developed by MichaelE. Porter in the
1970s.This type of analysis is also instructive in assessing the forces at play in greenchemistry.
Figure X: Porter’s Five Forces
The Five Forces model is a tool companies use to assess their competitive position within industry supply
chains to understand where power lies. It is based on a protectionist approach employed to assess and
anticipatethreatsto the business from existing competitors, bargaining power of suppliers and buyers
(customers) and the threat of new entrantsand new technology. The Five Forces model is a planning tool
used to build a position of defense and deflection of these threats. It is not a cooperativeor collaborative
approach to business positioning.

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B. GreenChemistry Accelerators
TFA has concluded that there arefour acceleratorsthat canchangethe current paradigmand createa
new paradigmthat can lead to faster growth of green chemistry:
• Collaboration
• Technology Forcing
• Compromise
• Enhanced Education
These elements arenot entirely new and all exist in some form. However, to transcendthe existing
“stuck” conditions, they need to be applied both more forcefully and in combination with one another.
Individual companies need to be competitive, but thereis a way to use the acceleratorstomodify the
traditionalFive Forces awayfrom a purely adversarialapproach to a more cooperative framework.
Adopting this new model can lead to sustainable change when companies commit to this approach.
Figure XI: Cooperative Five Forces Model

38
C. Collaboration
The traditionalstructure of the supply chain as highlighted by Porter’sFive Forces Analysis hasn’t enabled
fast growthof greenchemistry in industry. The traditionalfocus of competition and bargaining power for
customers and suppliers has limited transparency, innovation and availabilityof cost-effective new
materials. Consequently, it’s not surprising that collaboration is a key for change.
Strategicalliances, collaborations, co-creationand co-working aretransforming the traditionalsupply
chains and working organization. “Coopetition” is a termused as a model to drive competition and
innovation. Themessage is that thereare ways to achievethe goal while simultaneously being
competitive and collaborative.
Involving a broad rangeof stakeholders earlyand sustaining collaboration among themis the first and
potentially most important step in a new green chemistry effort. It provides a way to close thegap
between what players in thesupply chain say they want and their lack of understanding of how each
position in the supply chain works.
Collaboration canbe beneficial when it occurs in virtually any combination within these five force areas, as
well as outside of it as exemplified by NGOs, government regulatorybodies and other influencers.
Collaborative efforts canhelp lift some of the barriers that have slowed theadoption and flow of green
chemistry:
o Green Chemistry Definitions areestablished
guidelines)
o Transparency isaddressed
o Expectationsof Supply & Demand areshared
o A path is paved for New Technology Access andPlacement
o Some measureof Risk sharing is agreedupon.
Intervieweesprovided anumber ofcurrentexamplesofcollaboration:
Jointinvestment
“Wehavea fund to subsidizegreen technologieswhereweseeeconomy of scalefactors.Weacceptthelonger
term viewand givethemshorttermhelpto grow.”
“Werealizecommitmentsfor volumesareneeded. Wehavean internalinnovation fund to investinnew
technologies.”
“Real partnershipsintheinvestmentandproductionspacearea solution.”
“Wehavean ‘open innovation’program.Wework with companiesto help themdevelop and launcha new
technologythatisof interestto us both.”

39
Key take-aways on collaboration:
1. Collaboration among individual buyers and sellers along the supply chain can
a. Lead to projects wheregreen chemistry substitutes succeed
b. Help overcome the nine identified alignment issues.
c. Help avoid unrealistic expectations and consequent changes
d. Createalignment and agreement for change
2. Collaboration through consortium-based approaches can
a. Engagemany stakeholders simultaneously to unify industry acceptanceof green
chemistry solutions
b. Createprograms through which changecan occur faster
c. Provide a broad perspective from which priorities become more obvious
d. Initiateprojects involving specific chemistries
e. Leveragebroad knowledge base
f. Mitigaterisk of “go-alone” potential hazards
3. Collaboration can:
a. Bring new materialsand technology options to market faster
Intervieweesprovided anumber ofcurrentexamplesofcollaboration (continued):
TechnologySharing
As companiesdeveloptoolsor technology,they sharethemwith theindustryto help speed accessto and
adoption of green chemistry.
• Personal carecompany aboutto… “introducea testingand measuringproductthatwewill make
availableto industry.”
• A textilecompany… “sharingIP on anewproductand process”to help drivegrowth inthetechnology
and thus driveeconomiesof scalefor pricingand supply volumes.
• Thermal paper supplier,chemical supplier& retailer“planto sharesolution found forsaferalternative
to BPA,BPS”and other thermal developers.
Open innovation programs
• LAUNCH open innovationplatformfounded by NASA,NIKE,USAID & theUS Dept. of State
• InnocentiveCrowdsourcing:In aneffortto findgreen chemistry solutions,theGC3,Innocentiveand
Johnson & Johnson initiated a challengedriven innovationprogramsorcrowd-sourcingto findnew
green chemistry solutionsfor preservatives.
Supply ChainCommunication Forums
• GC3 was mentioned multipletimesasa uniqueforumto engageconversation alongthefull supply
chain: fromthematerial suppliersthroughto thebrand ownersand retailers.
• ACS Green Chemistry Round Tableswerecited asanother strongforumfor supply chain
communication:GCI ChemicalManufacturers,GCIFormulators, GCI Pharmaceutical
Consortiaasa meansto partner& collaborate
• ZDHC:major apparel andfootwearbrandsand retailersmadea shared commitmentto help lead the
industry towardsdischargeof hazardouschemicalsby 2020.Amongother things,thisgroup has
broughttogether members of thefull supply chain to engageand participatein collaborative
discussionsand innovationof saferchemicals
• Somecorporateculturesarenotopen to collaborationwith competitorsandconsortia.Thiswillbe a
hurdle to some industrycollaborativeefforts.
• Some otherNGO organizationshave beentalkingwith ZDHC on waysto worktogether tocross-
fertilize ideasand transferlearningsto other industriesbeyond footwearand apparel.

40
b. Get to larger scale faster
c. Bring the cost and risks down for all
D. Technology Forcing: Non-Regulatory
As previously discussed under “Government Regulation”, governmentalbodies have forced technology to
changeby the elimination of certainchemicals of concern, often in specific applications. In other cases
they have simply forced reductions to exposure from these chemicals.
There arestrong, non-regulatory forces also driving changes in industry. Marketplacedecision makers
with considerable “buyer power” force change. In effect, they createa de factoregulation. For instance,
it is well acceptedthat the “big box” stores in various markets (e.g., Walmart andTarget for consumer
goods, Home Depot and Lowes for building and home improvement products) and others with significant
shares of markets(e.g., CVS and Walgreens in pharmaceuticalsand personal careproducts) have
considerable market power. They have shown the propensity to demand cost reductions and even
require suppliers to change their practices under sustainability initiatives. Brandowners/manufacturers
have also effected a change. Thereare twoprimary approaches: “red list restrictions” and “incentives”.
Intervieweesprovided anumber ofcurrentexamplesoftechnologyforcing:
RetailersForceChange
• “BigBox and retail storesinfluence/selection of materialsdependingon theincentives/restrictions
they put in place.”
• Walmarthaslaunched a program- initially involving10 chemicals–thatrequiresdisclosureof the
presenceof thosechemicalswithinhousehold cleaningand personal careproductssold instores.
WalmartisalsotargetingDfE(SaferChoice) labelingby startingwith thisrequirementfor in-house
privatelabel brands.
Brand OwnersForceChange
• Tarkett,a global leaderin vinyl flooring,madesustainability a corporatepillarand leadtheindustry by
replacingtheir plasticizerswith non-phthalateoptions.
• P&Gannounced formaldehydeisbeingremoved fromPC productsfor children and iscommitted to
takethem outof adultproductsby 2015.
• Appleeliminated PVC and phthalatesfromall wire& cablejacketing.
• Adidas& Nikeandmany other Brand ownershaverestricted substanceslists.
Consortia/IndustryGroupsForcechange
• OIAOutdoor IndustryAssociationwith theSustainableApparel Coalitionhasachemicalsmanagement
workinggroup thatdoes assessmentand managementof chemicalsandtheirpotential impactson
humans and theenvironmentacrossproductlifecycle.
• BIFMA–providesincentivesfor beinglabeled greener.
• Healthy Hospital Coalition- providesbuyingincentives to eliminateCOC’s.
• TextilemanufacturersareusingBlueSign to eliminateCOC’satthebeginningof thedesign phase-
focused on a positivelistand incentives.
• Many others

41
At its extreme, technologyforcing is counter to collaboration. Strong arming does work, especially with
companies that have leverage. Yet, it canhinder a pathto future solutions, especially if unrealistic
expectations areset or if goals are set in a vacuum without appropriatevetting by those that canhelp
deliver the solutions. It createstheburden of discovery and changethat is forced sequentially and often
slowly all the way “up” thesupply chain. Therefore, exercising power should involve an appropriate level
of collaboration and compromise in order to ensure project goals are appropriately set and met. During
the course of interviewing, a number of materialsuppliers voiced concern over theconflicting messaging
from the sustainability and sourcing groups within consumer product and mass retailer organizations:
• “Mass retailer sustainability groups should work in tandem with their own sourcing groups and
suppliers so that realistic expectations areset for greenchemistry and economics.”
Key take-aways on technology forcing:
1. Marketplacedecision makers with considerable “buyer power” can force change. In effect,
they createa de facto regulation.
2. Technology Forcing can, like government regulations, drive changeto green chemistry.
a. Largeretailers, especially, have a great dealof market power to leverage.
3. This will work faster and more efficiently if done via a collaborative approach.
a. Collaboration canhelp ensure realistic goals areset
b. Feedback mechanisms need to be createdwithin the technology forcing companies, as
well as with those companies subject to force.
4. Internalcollaboration between thesourcing and sustainability groups at consumer products
and retailer organizationscan ensure green chemistry and price/performance needs are
examined in tandem.
5. Some level of compromise may be necessary.
6. Success is much more likely if stakeholders areeducated, including being provided with
answers to the following questions:
a. “Why arewe doing this?”
b. “What arethe benefits?”
c. “What arethe consequences of non-compliance?”
E. Compromise
Compromise is a subsidiary principle of any true collaboration (and mayalso be applied when technology-
forcing approaches areused). It involves theacceptanceof continuous improvement. Something “better
enough” is better than thestatus quo. It will not necessarily represent the ultimate goal, but provides a
step in theright direction.
Commercializationof new solutions requires passing many rigorous goals and hurdles. Invariably,
compromises areinvolved because a chemicalthat is “greener” thanexisting products is likely to have
tradeoffs to the incumbent material: price/performance, supply & demand, etc.
Compromise can help lift some of the barriersthat haveslowed the adoption and flow of greenchemistry.
For instance compromising in thefollowing manner addresses several key greenchemistry adoption
issues:

42
o Green Chemistry Definitions areestablished
guidelines). These areunderstood and agreedto before significant decisions aremade.
o Transparency expectationsandrequirements areestablished.
o Expectationsof Supply & Demand areagreedtoby some means. This can be managedvia a
Memorandum of Understanding (MOU) betweensupplier and customer(s). While generally
non-binding, MOUs do set expectationsand guideposts for relationships at functional levels
and can enhance support by those at the highest levels of corporations or investors who must
approve significant investments.
o This paves a pathfor New Technology Accessand Placement andallows for some measure of
Risk sharing to be agreedupon.
Compromise and non-regulatory technology forcing appear on thesurface to be two approaches at odds
with one another. They arenot if the companies forcing the changeand those impactedby the change
areable to compromise.
Intervieweesprovided anumber ofcurrentexamplesofcompromise:
“Industryneedsto bepatient:Romewasn’tbuiltin aday. Chemical industry has50 yearsof optimizinganditis
goingto taketimeto change.Do a phased approach. Compromise.”
“Commercialization involvingnewsolutionsmustpassa setof multiplegoals. Compromisesareinvolved.”
“Productinventory turnswerenotmeetingthemassretailer standards. Themassretailer eased thevelocity
rateto keep our sustainableproductin stores.”
“Wecouldn’tremoveall PVC,butweremoved itfrompackagingwhereitwasn’tnecessary. Thiswasan easy
solution.”
“Wedesigned a saferproductremovingphthalates,loweringVOC contentandmanaginga post-userecycling
chain. UsingPVC istherightchoicenowuntil anothereffectiveandsustainablealternativecanbewidely
availableon themarket.”

43
Key take-aways on compromise:
1. When compromising, companies can acceleratetheadoption of greenchemistry by
embracing the principle of reasonable trade-offs.
2. Accepting continuous improvement will acceleratetheadoption of greener chemistry.
Something “better enough” is better thanthe status quo. It will not represent the ultimate
goal, but provides a step in theright direction.
3. Reducing risks and exposures from COCs, as opposed to their outright replacement, may be an
acceptablecompromise.
4. The cost of a green chemicalis likely to be higher initially than that of thestatus quo.
a. Timetables for step changeeconomic improvements can be established.
b. Suppliers and customers can negotiatea short term plan for absorbing or passing along
the increase in cost.
5. The performance of a greenproduct may not be identicalto that of the status quo.
i. Key performance parametersand expectationscan be defined to satisfy all parties
and avoid consumer push-back.
Intervieweesprovided anumber ofcurrentexamplesofcompromise(continued):
“Our customerfocused on a trade-off analysisvsa red listsincetherewerenoteffectivereplacementsfor full
formaldehydereplacement.”
“Wecompromisedwith lowformaldehyde-emittinglaminates. They don’talwayseliminatetheformaldehyde,
butyieldsproductsthataresaferfor consumersinall cases.”
“The biopolymerisn’tGMO free. Thiswilltaketime. Wecanstartwith a GMObiopolymer nowandlook
toward GMO freeproductsin thefuture.”
“Wewantbiomaterialsthatarenotusingfood-sourcerawmaterials. As longasthereisa plan to gettherewe
can work with thefirstgeneration product.”
“Weconsider practicesaswell assubstitutes. Wherewecan’tchangeto a “safer solvent”wefocused on
installingaclosed loop systemto keep restricted chemicalsfrombeingreleased.”
“Wehad to look attheways in whicha COCcan bediffused notjustreplaced. Wetargeted layersand multiple
solutionsregardingBPAinthermal receipts.
Evaluatesustainablenewsolutionsandprocesses
Limitpaper waste- don’tprintwhen notneeded
Educatenotto recycle
Promotee-receipts
TSCA influencein minimizingreceiptsdiscarded
OSHAto addressworker contactand handling”

44
6. Easing of other business standards is a compromise to fuel thegrowth of the greenchemistry
products: inventory turns, supply terms, etc.
F. Enhanced Education
Enhanced education is thefourth accelerator. Twoelementsof education wereraised during interviews:
- Consumer Education
- Industry Education
1. ConsumerEducation
Being green is not enough of a driver. Consumers and customers have demonstratedthat even though
they say they want green, theywill not always (or generally) pay for it. Adoption rateshave been
successful when consumers and customers are educatedand awareof theperceived risk of existing
chemicals or materials. At this point they canand do drive change. Empowering consumers with
information about chemicals in products they purchase for themselves, friends and family canhelp drive
this change.
Intervieweesprovided anumber ofcurrentexamplesofconsumer education:
“Consumershavea simplisticunderstandingof chemicalsand have“chemophobia”thinkingchemicalsmeans
bad.Education iskey.”
“Consumerscareaboutsustainability andgreen insomeareasmorethanothers:Highinterestin cleaning,
food,personal careandcosmetic,baby/children;Lower interestinfashion,homegoodsand transportation. A
bigeducation effortisneeded.”
“Consumersaren’teducated enough. Thisisahugeroadblock. Mustbea pull;can’tbea push.”
“There is limited consumer awarenessaboutBPAin thermal receipts.”
“Consumersonlyseemto generally beinterested in knowingthatthemanufacturer isdoingtherightthing.
They seem disinterested inknowingwhatthecompany isdoinginsustainability or corporatesocial
responsibility.“
“Consumersarenotawareof green chemistry,butthey do see‘sustainability’”
“Consumerscontinueto ask abouttheirexposureto COC’sincludingphthalates,formaldehydeandBPAin their
furniture.”
“Brandingasan integral partof thebrand imageishelpful with productslike7th Generation,Method,Aveda,
butthere is still somuchgreenwashing,thatthisisnotalwaysa reliablesourceof education.”
“Consumersfearsor perceptionsarereality. Education isneeded to help preventconsumerpanic. For
example,carbon black ishazardouswhen airborne,notwhen itisbound in a resinsystem.“

45
Many discussions withindustry, governmentaland NGO personnel during the study identified creating a
better educatedconsumer base as key to successfully increasing the flow of successful greenchemicals.
In effect, the messagewas: Consumers need to know that safer and/or more environmentally friendly
chemicals createbenefits that may be hidden to them.
2. Industry Education
There is a growing movement toward greenchemistry education, but it is pocketed and slow. High
schools have limited modules involving greenchemistry. The focus is more on environmental studies.
Universities tend to offer individual classes in greenchemistry. Industry players interested in promoting
greenchemistry adoption and design have a limited offering of training workshops and tools for design.
Much of thetraining is how to look for and measure COCs vs. green chemistry design.
Key take-aways on enhancededucation:
1. Educated, informed and impassioned consumers can fuel the growth of greenchemistry.
a. Consumer facing companies can help drive growthby educating their customers.
2. Educatedand informed customers all along the supply chain can fuel the growthof green
chemistry.
3. The easiest way toacceleratetheavailability and adoption of green chemistry is to start witha
greenchemistry design by way of an educatedwork-force.
IntervieweeFeedbackon Green ChemistryIndustryEducation
“Green Chemistry educationisanadd-on.“
“Green Chemistry needsto beintegrated into thechemistry and engineeringprogramsfor thefull four year
undergraduateprogram”
“Chemical educational programsin schoolsdon’tteachtoxicology or green chemistry.”
Industry challengesthatpromote“Designingwith Green Chemistry”arechangingthinkingpatterns.
• “LivingBuildingChallenge:launched by CascadiaGreen BuildingCouncil. Itisthemostadvanced
measurementof sustainability.Every creditisrequired isrequired forcertification.”
• “BlueSign isa design and manufacturingsoftwaresystemfor sustainabletextileproduction that
eliminates harmful substances rightfromthebeginningof themanufacturingprocess”.

46
V. CONCLUSIONS
adoption of safer alternatives, and scaling of supply in response to demands from regulatorsand
customers. Despite efforts from many stakeholders to accelerategreenchemistryuse, adoption rates
remain low and overall progress is slow, measured in decades.
The TFA analysis identified nine key deterrents that have affectedthe slow growthand availability of
greenchemistry. These have been strong impediments to growthof greenchemistry, weighing down the
supply chain and slowing green chemistry adoption.
ES Figure I: Nine Deterrents That Can Misalign Green Chemistry Supply Chains
Nine Deterrents to Green Chemistry Supply
1. Green Chemistry Definitions
Most industries have not established a unified set of “greenchemistry” definitions. It isn’t
criticalto pick a “right” definition. It is Critical to be on the same pagewhen initiating and
advancing discussions and collaborative efforts involving GreenChemistry.
2. Supply Chain Complexity
Supply chain complexity poses enormous barriers to greenchemical adoption. Eachposition
in the chain has its own vantagepoint, a different viewpoint from others positions. This
createsfragmentationof demand by application, volume, customer expectation, geography,
etc.
3. Incumbency
The existing infrastructureof theestablished chemical industry is so efficient that it is hard for
new entrants, greenor not, to competewith the established supply chain.

47
4. Confusion
Conflicting information from studies and research, policy uncertainties and conflicting
lobbying efforts continue to confuse the industry. Stakeholders areat times grid-locked, not
making a change due to uncertainty about theacceptabilityof status quo products.
5. Switching Risk
There is concern that switching to green chemistry alternativescould leadto market failures
such as market loss due to a product’s poor performance, brand tarnishing and other hidden
costs such as process or equipment or process changes, materialincompatibility, workforce
training, customer education and others. Thereis also the risk of switching to a “better bad”.
This makes stakeholders cautious and slow to makechemical management decisions.
6. Price / Performance
Price/performance was themost citedreason for the slow adoption of greenchemistry.
Entrenched chemicals of concern (COC’s) have set the standard for price/performance. Often
thereare savings in a total cost analysis such as reduced hazardouswaste handling and
disposal. This canbe hardto quantify for customers focused on $/lb. pricing.
7. Supply & Demand
There is often not enough realor perceived demand to make increased production worth the
investment. Stakeholders are cautious to move forward to commit to demand or to commit
to supply. Supply infrastructure growthwill be slow without compromise, partnership and
collaboration to increase demand and supply in tandem.
8. Transparency
More transparencyis occurring, much by force. Suppliers arelooking for ways to satisfy
customer demands while protecting IP and tradesecrets. Customers have the criticalneed to
mitigatetherisk in handling or selling products with unknown ingredients that could be COCs.
9. New Technology: Access andPlacement
Finding and vetting green chemistry technologies remains a weaklink. Suppliers struggleto
identify earlyadopters. Customers struggleon where to go beyond the traditionalsupply
chain for new technology.
Current Drivers to Green Chemistry Growth
Much of theprogress to datein advancing greenchemistry canbe attributedto two main drivers:
Government Regulationand Consumer Awareness. However, theslow adoption of greenchemistry to
datesuggests that future efforts need to better address the impediments to growth.
1. Government Regulation
Regulatorybans and restrictions have been and will continue to be a big driver for green
chemistry. However, thedifficult and costly regulatoryprocess for new product registrations
and secondary approvals can act as a hindrance to product availability, demand and adoption.
For a new chemistry, particularlyfrom a small company with limited toxicology or regulatory
support, this canbe challenging.

2015 TFA Green Chemistry Barriers & Accelerators

2015 TFA Green Chemistry Barriers & Accelerators

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