Clean Production Action 11/16/2017 Blog
Dear Friends of CPA, It is with great pleasure that I share the news that… Read More
The Survey includes 20 questions scored to 100 points that evaluate corporate chemical management performance in four key performance categories:
The CFP Survey evaluates overall corporate chemical management performance by considering four elements: 1) management strategy, 2) chemical inventory, 3) footprint measurement, and 4) public disclosure and verification.
For the 2016 reporting period, the CFP asks companies to measure CoHCs contained in the products they sell.
In future years the scope of chemical footprint measurement will expand to include manufacturing operations, supply chain, and packaging.
The CFP defines Chemical Footprint as the total mass of chemicals of high concern (CoHCs) in products sold by a company, used in its manufacturing operations and by its suppliers, and contained in packaging. For the 2015 reporting period, the CFP asks companies to measure CoHCs contained in the products they sell.
Chemical footprinting is the process of assessing progress toward the use of safer chemicals and away from chemicals of high concern to human health or the environment. A chemical footprint can be used as a benchmark to document the actions an organization takes to advance the use of safer chemicals in its products and manufacturing operations.
Signatories are investors, large-scale purchasers, retailers or NGOs that agree to:
A Responder is a brand or manufacturer that completes the Chemical Footprint Project Survey.
The Survey allocates a total of 100 points across 20 questions. Question-specific scores are added to give a company a total score. The response data from participants will be anonymized, collated, and analyzed in the CFP 2017 Annual Report.
Responders can choose whether to publicly share 1.) their participation in the CFP, 2.) their Survey responses (not including documentation), and 3.) their scores. Although third-party verification is not a required, additional points are awarded if responses are independently validated.
As a primary goal of the CFP is to recognize corporate leadership, the CFP will publically profile top performers in its annual report. The results will provide valuable data to investors, retailers and other organizations seeking to identify companies that use best practices in chemicals management. Participants can share their results with their customers and investors who wish to source products from companies that are leaders in using safer chemicals.
Any brand or manufacturer can use the Survey to benchmark its chemicals management program, understand its progress over time and its position relative to other firms. It is designed as a tool to measure continuous improvement in chemicals management.
You can apply to participate at: https://www.chemicalfootprint.org/assess/assessment-tool. Responders will answer the 20 questions that comprise the Survey to measure their company’s overall chemicals management performance.
The CFP Survey is designed to be completed by manufacturers and brands of final products or product components. While the Survey is applicable to any manufacturer or brand, it was developed using information on the chemicals management practices of the following sectors: automotive, building products, consumer packaged goods, medical devices, electronics, and apparel/footwear/outdoor.
There is no cost for being a Signatory in the Chemical Footprint Project.
There is no cost to be a Responder to the Chemical Footprint Project.
Many tools have been developed to help companies identify chemicals in products, assess the hazards and risks of those chemicals, and determine safer alternatives. Examples include the Health Product Declaration, GreenScreen® for Safer Chemicals, Pharos, the SIN List, and the SciVera Lens. The CFP does not specify or recommend any tool or database for use in implementing a robust corporate chemicals management program. Rather, tool and database selection are left to the discretion of each company. These tools can help prepare firms to participate in CFP.
The CFP 2016 Chemicals of High Concern List aligns with the approach used by GreenScreen® for Safer Chemicals to identify CoHCs, known as “List Translator-1” chemicals (LT-1’s) with one exception. CFP uses the European Union’s Candidate List of Substances of Very High Concern to identify CoHCs, while GreenScreen uses the European Union’s list of Substances of Very High Concern requiring authorization to identify LT-1 chemicals.
The Health Product Declaration (HPD) provides a standard format to report building product content and associated health information. The objective of HPD is to establish a standard format to support consumers’ informed decisions about the products they purchase and their impacts on human health, and to reduce the burden on product manufacturers who must complete multiple types of information requests and reporting formats. The Chemical Footprint Project differs from HPD in two ways. First, HPD is a program designed to collect chemical content information about individual building products, whereas the CFP assesses chemicals management at the corporate level. Second, HPD is designed for the building product sector, while CFP evaluates a wide range of products sectors.
The Higg Index was developed by a collaboration of brands, retailers, suppliers, and other stakeholders. It is currently being used as an internal self-assessment tool to measure the sustainability impacts of apparel and footwear products across the value chain at the brand, product, and facility levels, with a verification protocol under development to ultimately allow its use in consumer-facing communication. The Chemicals Management Module of the Higg Index was developed to specifically address chemicals use and impacts in the supply chain. The Higg Index is a business to business tool that does not publicly benchmark companies for their chemicals management system.
The purpose of the NSF/ANSI 336 Standard is to address the environmental, economic and social aspects of commercial furnishings fabric used in public occupancy settings such as office, hospitality, healthcare and institutional interiors. It is designed to evaluate the sustainability of contract textiles and includes a material safety component. It does not evaluate chemicals management systems at the corporate level.
Textile and fabric brands and manufacturers using the Higg Index and NSF/ANSI 336 should be able to use the data they have gathered for these tools in responding to the CFP Survey.
The Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH) is a European chemicals management regulation. It came into force in June 2007 and replaced a number of European Directives and Regulations with a single system. The European Union’s Restriction of Hazardous Substances in Electrical and Electronic Equipment (RoHS) Directive restricts (with exceptions) the use of six hazardous materials in the manufacture of various types of electronic and electrical equipment.
CFP does not assess companies on regulatory compliance, but rather their performance beyond regulatory requirements. Specifically, the Survey includes questions in four areas: Management Strategy, Chemical Inventory, Footprint Measurement, and Public Disclosure and Verification
Alternatives assessment is a process for identifying, comparing, and selecting safer alternatives to chemicals of concern (including those in materials, processes, or technologies) on the basis of their hazards, performance, and economic viability. A number of tools and methods have been developed for assessing alternatives to chemicals of concern (see: http://www.oecdsaatoolbox.org/).
Responders to the CFP Survey may find these methods and tools useful to identify and select safer chemicals for use in manufacturing, products, and packaging.
Companies completing the Survey receive scores from 0 to 100 based on responses and supporting documentation. A company can decide whether to make its participation public, as well as its responses to the Survey questions and its score. Responses of companies that agreed to make them public for the 2015 reporting year are available here .
Responses of all participating companies are evaluated and reported anonymously in an Annual Report.
The Chemical Footprint Project will review answers based on: consistency with documentation provided, comparisons with similar companies, and a review of publicly available data. Although third party verification is not a requirement for participation, Responders receive additional points if their answers are independently validated.
Acceptable supporting documentation depends on the specific question. The CFP Guidance Document provides information about supporting documentation for specific questions. Some examples of supporting documentation include:
If CFP needs additional documentation to verify specific answers, we will contact you directly.
We recognize that not all questions are relevant to every organization. Our scoring algorithm does not penalize companies for a response of “N/A.”
The time to answer the questions will depend on the systems a company has in place to manage chemicals in products and supply chains beyond regulatory compliance. Companies with comprehensive data collection systems will be able to more rapidly answer the questions than those that have data located in many different parts of the organization. In the first year of participation companies may not have the data in hand to answer all 20 questions. The Survey is designed as a continuous improvement tool. Year one data will provide a base level of performance for a company.
Once a responder has been approved to participate in the Chemical Footprint Project, he/she will be provided with a log-in name and password. You can log in and answer a subset or all of the questions. As long as you save your answers, you can return to the questionnaire and complete it at a later date.
CFP will review responses and documentation, then assign each responding company a score from 1 – 100. Each responding company will receive a report with its score.
CFP will compile and analyze data from all responders anonymously in an annual report, to be released in April 2017. With their permission, leading companies will be highlighted in the report by name. All companies that agree to make their participation public will be listed in the annual report. Responses and scores of companies that agree to make these public will be posted on the CFP website.
Although third party verification is not a requirement for participation, companies receive additional points if responses are independently validated.
The CFP defines a Chemical of High Concern (CoHC) as a chemical that meets any of the following criteria: 1) carcinogenic, mutagenic, or toxic to reproduction (CMR); 2) persistent, bioaccumulative and toxic substance (PBT); 3) any other chemical for which there is scientific evidence of probable serious effects to human health or the environment that give rise to an equivalent level of concern (for example, an endocrine disruptor or neurotoxicant); or 4) a chemical whose breakdown products result in a CoHC that meets any of the above criteria.
Using this definition, the Chemical Footprint Project compiled its 2016 CoHC List from 14 lists of hazardous chemicals developed by governments and other authoritative bodies. The CFP 2016 CoHC List includes any chemical or chemical group that meets any combination of the CFP criteria for a CoHC on any of the 14 lists. Substances on these lists that could not plausibly be an intentionally added ingredient of a product were excluded from the CFP 2016 CoHC List (e.g., viruses, alcoholic beverages). The source lists and links to their websites can be found in Appendix D of the Guidance Document.
While each source list is dynamic, to simplify reporting the CFP 2016 CoHC List is static. It was compiled using July 1, 2016, versions of the source lists.
The CFP 2016 CoHC list aligns with the approach used by GreenScreen® for Safer Chemicals to identify CoHCs, known as “List Translator-1” chemicals (LT-1’s) with two exceptions. First, CFP uses the European Union’s Candidate List of Substances of Very High Concern to identify CoHCs, while GreenScreen uses the European Union’s list of Substances of Very High Concern requiring authorization to identify LT-1 chemicals. Second, CFP does not include EU-Reach Annex XVII CMRs.
Responders can decide whether to make their company’s participation, responses (excluding documentation), and/or score public. Responders will be awarded points for making their responses and/or score public.
Responders that agree to make their participation public will be listed in the 2017 CFP Annual Report. Responses and scores of companies agreeing to make those public will be posted on the CFP website.
Responses from all companies will be anonymized, compiled and analyzed in the 2017 CFP Annual Report.
Hazardous chemicals “present reputational, regulatory, and reformulation risks across a broad range of industry sectors. Investors need to understand how companies are meaningfully managing these risks.”
Corporate performance in chemicals management varies widely, from barely being in compliance with regulations to capturing new markets through innovative products based on safer chemicals. We look forward to using a tool that rewards innovators for using safer substitutes.
We need metrics for reporting and benchmarking overall corporate performance on chemicals management. CFP is a publicly developed standard which could allow us to benchmark, track and report our overall corporate chemical management performance going forward. We look forward to its launch in 2015.
The Chemical Footprint Project provides an independent, third party assessment tool that will help companies to think about how to fully integrate their policies into procedures and vice-versa.
We see the Chemical Footprint Project enabling us to quickly recognize and reward suppliers for doing what matters most to us in health care, which is implementing systems to ensure their products and supply chains use safe and healthy chemical ingredients