Memorandum by Chemistry Innovation and
the Chemical Industries Association
INTRODUCTION
1. Chemistry Innovation is a publicly funded
Knowledge Transfer Network (KTN) set up in 2006 to drive innovation
performance across the UK chemistry-using industries. We facilitate
innovation and knowledge transfer by providing unique networking
opportunities that help to connect companies, universities, funding
bodies, national, regional and devolved administrations and enable
them to focus on a common agenda. The thrust of our activity is
to provide the focus and stimulus to support product and process
innovation that will deliver growth and sustainability through
a coherent national strategy.
2. Chemistry Innovation is currently engaged
in a portfolio of collaborative projects valued at over £40
million, representing a mix of industrial projects, CASE awards,
TSB/EPSRC and EU funded projects, involving 150 organisations
We have formed strategic relationships with other national/European
organisations involved in the delivery of innovation services
to ensure a coherent approach with industry/academia in defining
and funding the delivery of innovation projects. Evidence here
is limited to our relevant experience and is focused on the chemistry-using
industries which, with chemistry an underpinning science, covers
sectors as diverse as pharmaceuticals, food and drink, materials
and transport. One of Chemistry Innovation's core activities is
to promote Sustainable Technologies and help UK industry become
more innovative in their approach. It is imperative to describe
the benefits of sustainability thinking to business. One of the
best ways to accomplish this is with powerful examples and demonstrator
projects.
3. The UK Chemical Industries Association
(CIA) is the premier trade/employers' organisation in the UK chemical
industry. It has a membership of 150 companies, many of which
are international, operating from over 200 sites in the UK.
4. The chemical industry in the UK contributes
over £5 billion annually to the country's balance of payments
from a gross output of £50 billion. It accounts for 1.5%
of UK GDP, 11% of manufacturing's gross value added, and employs
nearly 200,000 highly skilled people directly as well as supporting
several hundred thousand related jobs throughout the economy nationwide.
The industry is global both in terms of markets and ownership,
with over 65% of CIA's membership being foreign "headquartered".
Any significant imbalance in business operating environment between
the UK and other locations can lead to the loss of UK output,
trade and investment opportunities.
5. Responsible Care® is a self-imposed
commitment by chemical companies worldwide under the auspices
of the International Council of Chemical Associations (ICCA).
It is designed to help companies continuously improve the health,
safety and environmental performance of their operations and products.
In the UK, where the Responsible Care® initiative has been
in operation since 1989, compliance with the Guiding Principles
of Responsible Care® and self-assessment of responsible care
management systems, is mandatory for all CIA members. The CIA
publishes information concerning the environmental, health and
safety performance of its member companies on an annual basis
in the Responsible Care® Indicators of Performance. In its
new guiding principles and goals for sustainable development,[5]
launched on 6 July 2004, the Association has committed, by 2010,
to achieve a 25% overall reduction in hazardous waste, a 20% reduction
in water use, and 11% improvement in energy efficiency; together
with a significant reduction in our environmental burden.
BETTER DESIGN
AND THE
USE OF
MATERIALS
6. It is important that products are designed
for disassembly and ease of recycling as we seek to protect our
rapidly diminishing resources. Much is known of the impact of
oil scarcity however many other vital materials are in dwindling
supply. Many elemental metals are being exhausted by new technologies
and will vanish forever without efficient recycling.[6]
For example, indium metal is being used in increasing amounts
in LCD flatscreen televisions, pushing up the price of the metal
which is utilised for solar cell manufacture. The earth's supply
of indium predicted to run out as quickly as 15 years time. Natural
resources such as rubber and clean water are also increasingly
stretched.
Innovations in chemistry have a huge part to
play in reducing waste in downstream sectors. The construction
industry is an example of a sector where increased use of sustainable
materials and design for ease of dismantling and separation could
have a huge impact in reducing waste. New chemical technologies
will be needed to achieve this such as new adhesives and high-performance
insulating materials from sustainable sources.
7. Product developers are increasingly seeking
to incorporate renewable materials into their goods but more research
is needed into how the same product benefits can be delivered
without a loss of competitiveness. For example personal care products
may require substantial changes to base formulations to incorporate
new materials. This is distinct from the increasing use of "natural"
products, of which little is sometimes known of their health effects.
Design and engineering graduates could have a profound effect
on waste reduction and management in industry. This requires both
adequate training, and commitment from industry. Resources such
as the Ecodesign Pilot, developed by the Technical University
of Vienna, provide both a framework for sustainable design, and
many examples of its application in practice.[7]
Another example is the BASF ecohouse.[8]
8. Chemistry Innovation is working closely
with Bioscience for Business KTN on use of renewable feedstocks
and with Resource Efficiency KTN on issues such as new catalysts
for water treatment and methods to convert "waste" to
feedstocks. Chemistry is a vital underpinning technology with
huge scope for new innovations that address resource and sustainability
issues. Chemistry Innovation launched an online Sustainable Technologies
Roadmap in 2007 which provides a look into the future of the chemical
and chemistry-using industries.[9]
It asks what industry needs to do to produce solutions that will
help customers and society to be more sustainable, and what technologies
can help. It will provide key decision makers in industry, academia
and the UK Government with a clear picture of the challenges,
opportunities, gaps and actions that need to be taken. Importantly
it contains a wide variety of case studies exemplifying innovative
solutions to sustainability issues.[10]
Cross sector communication of success stories provides stimulus
for innovation in tackling such problems.
9. Recycling waste, or "cradle to cradle"
thinking, can turn waste streams into important feedstocks for
industry. This can be done in two ways; taking a waste stream
from one process or industry and making it a feedstock for another,
or by reusing materials within a single process or industry. An
example of the first would be the development of integrated biorefineries
producing fuel and platform chemicals based on agricultural, commercial
and domestic organic waste. An example of the second would be
the recycling of tertiary packaging materials within the retail
sector. In the big supermarkets, virtually all of the plastic
over wrap used when palletising product for delivery to the supermarkets
is recycled and reused. The barrier to the wider adoption of both
processes is the variability of the waste streams, and the risk
of contamination. We have yet to devise processes that can reliably
produce raw materials of the required quality from the general
waste streams. This is made more complicated by the tendency to
increase the complexity of materials used in industry in order
to gain other benefits in performance and environmental impact.
For example, modern window glass is frequently coated to give
additional benefits such as self-cleaning properties or control
of solar gain. From the point of view of recycling this is a contaminated
material which is extremely difficult and costly to clean up.
10. In the chemical industry itself there
is both a long tradition of designing out waste through novel
processing, and great potential for further development. The concepts
of "atom efficiency" and "E-Factor", measures
of how much of all the raw materials that are used in a manufacturing
process end up in the final product, has been very influential.[11]
In-process waste minimisation has been practised in the chemical
and related industries for more than two decades and a lot has
been achieved already so that at least in the chemical sector
most processes are optimised with respect to waste generation.
The main driver for this was economicsit made business
sense to do so.
11. Methods such as Lean Manufacturing,
Six Sigma and similar approaches (such as Design for Manufacture"easy
to make" and Poke Yoke"inadvertent mistake proof")
have had a powerful influence in recent years. However, they are
largely concerned with optimising an existing product and/or process.
The larger opportunity is in redesigning a product and process
completely to provide the user requirements in a different way.
This "deep innovation" can reduce environmental impact
by a much bigger factor. Lean manufacturing and six sigma have
a proven track record in reducing waste, but they are not sufficient
in their own right. It is more important to ensure that companies
continue to strive to achieve the objectives rather than to seek
to prescribe the perfect tool for achieving them.
12. Some sub-sectors have been better at
process optimisation than others so there is still significant
potential for improvement. However, it is not clear where and
how the improvements can be made (ie are there any "low hanging
fruit"?). The best way to reduce waste from a chemical process
is to consider the amount that will be produced at the earliest
possible stage in the design and development of the process. Unfortunately,
the timescale for developing and proving novel processing techniques
demands a lot of resources in time and personnel. In addition
this period of rapid legislation changes and review make it a
difficult area for manufacturers to commit to with any confidence.
13. The pharmaceutical industry is particularly
active at the moment in reducing waste in the manufacture of pharmaceutical
preparations because of increasing costs of raw materials, waste
disposal, and protection for workers. They are particularly keen
to increase the atom efficiency, and also to design out toxic
and hazardous materials, whose management adds so much to their
cost base. A strong interest in industrial biotechnology in the
pharmaceutical, consumer chemical and specialty chemical sectors
comes from the potential to reduce waste and improve efficiency
as much as from the opportunity to produce novel materials. Chemistry
Innovation is supporting BERR's Industrial Biotechnology Innovation
Growth Team which is seeking to address issues surrounding adoption
of biotechnology by the chemical industry.
14. For much of fine chemicals manufacture
reducing solvent use is where big gains can be made. Use of ionic
liquids (which aren't volatile), supercritical fluids (highly
compressed gases that can be recycled), process intensification
(use of flow chemistry over batch) and solvent free processes
all have the potential to greatly reduce waste. The sustainable
chemical technologies roadmap developed by Chemistry Innovation
has many examples of recently emerged and emerging technologies
that have the potential to substantially reduce waste in a wide
variety of sectors.
15. It is probably of greatest importance
to re-think manufacturing processes on a life cycle basis and
not looking just at processes themselves but feedstocks and products
(ie can we start from different feedstocks, including using waste;
can products be re-designed; do we need these particular products,
etc etc). Shared responsibilities up and down supply chains should
be encouraged (programmes such as the Chemical Industries Association's
Responsible Care for example) and supported with simple to use
tools for identifying "hot-spots" in a supply chain
where shared action should be targeted with all members of the
supply chain sharing the benefits of the improvements.
16. The key problem is that the ISO approved
methods for life cycle analysis are too slow, too complex and
too costly for practical use in industry. As a result, a large
number of "cutdown" methods have been developed but
not standardised. For an organisation wanting to set out to use
sustainable design to reduce environmental impact, it is an extremely
confusing world. We urgently need internationally agreed methods
for simple life cycle analysis suitable for use in the early stages
of design and product development when multiple concepts are being
evaluated. Similarly, we need more data in the public domain on
the environmental impact of different materials. This is particularly
true for new materials designed to improve sustainability. Defra
has funded some work to enable high quality data on bio-derived
materials to be made available to designers and manufacturers.
Chemistry Innovation is involved in two projects, one European
and one UK-based supported by EPSRC and the Carbon Trust, addressing
life cycle analysis issues.
BUSINESS FRAMEWORK
17. If a waste reduction strategy made commercial
sense, we can assume that the smart company would want to follow
it. The barriers to them so doing include:
(a) Awarenessthe benefits of resource
efficiency are still not known to many companies, particularly
the large number of SMEs. The stories, backed up by evidence,
need to be told and retold;
(b) Cost of analysisfor many companies
the cost of finding out whether there are financial gains for
using resource efficiency is a substantial barrier, particularly
if you have no previous successful experiences. Again this is
particularly true for SMEs;
(c) Lack of resourcesmany companies
are so thinly staffed that they lack the resources to undertake
resource efficiency projects;
(d) Lack of skillseven with external
support, many companies lack the skills to undertake resource
efficiency studies, or to implement their findings;
(e) Lack of fit with the capital investment
cyclein many industry sectors capital investment follows
a natural cycle. Ideas for resource efficiency need to either
offer immediate and substantial benefits with low capital investment,
or need to fit into a plan to refurbish, replace or extend capital
equipment. With very long investment cycles in many industries,
resource efficiency opportunities often occur when there is no
real prospect of making the capital investment required.
If the company has carried out a proper analysis
and the strategy does not make commercial sense, then they cannot
be expected to follow it. Government has a role to shift the balance
if it wishes companies to follow waste reduction strategies in
areas which are not commercially viable. They can do this by regulation,
or by fiscal policy which charges companies for their environmental
impact. The chemical industry is global, and has to compete with
lower cost producers in the Far East and Eastern Europe. Generally,
capital projects which implement waste reduction technologies
do not meet the investment criteria applied to capacity expansion
and new products, and in many cases are implemented for CSR reasons
rather than economics.
18. There are examples where UK industry
is at the leading edge of waste reduction, and examples where
it lags significantly. Different countries have different regulatory
environments, and this has a profound effect on the type of waste
that industry focuses on. Regulatory environment, sector size
and strength, relative costs of waste management, sector history,
and whether the leading players are national or international
all have an effect on waste management strategy in the sector.
19. Customers, regulations and standards
can also be barriers to following a waste reduction strategy,
particularly with respect to recycling. Customers may have specifications
which explicitly or implicitly block the use of recycled material
in a product. For example, it has been reported that the specification
for vinyl flooring for government buildings means that recycled
PVC cannot be used in these products. Such specifications may
not have any scientific logic behind them, but can be incredibly
difficult to change. International or national standards and regulation
can have the same effect. The UK's wide interpretation of the
definition of waste is posing a barrier to sustainable waste and
resource management. The result of the interpretation in the UK
is resulting in sites, whose by-product reuse or management has
until recently (~2005) been regulated as part of their general
Pollution Prevention and Control permit, and subject to Best Available
Techniques (BAT) and Best Practicable Environmental Option (BPEO)
considerations, being drawn into additional waste-specific regulation
and its associated regulatory impact.
20. It is directing sites towards discontinuing
previously agreed strategies to manage their process by-products
sustainably (for example by burning in combined heat and power
plant in place of virgin fossil fuel) towards sending such by-products,
often over long distances, to the limited commercial incinerators
available or to landfill (if technically feasible) and buying
in commercial (mainly fossil based) fuels in their place to power
their boilers.
In the following example, the UK Competent Authorities
concluded that the material is waste:
"An installation produces an intermediate
(which is used to make products) and methanol as part of a chemical
process. The installation was designed with the specific intention
to use the entirety of the methanol produced from this process
as a fuel on site. The methanol stream does not require further
processing prior to its use as a fuel. The process of manufacture
and fuel combustion is regulated under, and complies with IPPC
requirements (all necessary measures are taken to achieve a high
level of protection for the environment as a whole). The methanol
is an output of production and, although it is not the primary
motivation for the design of the manufacturing process, it is
an output which is intended and which has an identified and certain
end-use. In this case, the end-use is on-site use as a fuel."
Materials produced as by-products of one industrial
process that can be used by other industrial processes as raw
materials may still be classified as waste for many years to come.
This will mean that the twin goals of efficient use of resources
and improved industrial competitiveness will remain unrealised.
The chemical industry, along with a number of
other sectors, has consistently lobbied for a more pragmatic interpretation
of the definition of waste. The Chemical Industries Association
are currently following closely the revision of the Waste Framework
Directive and support the proposed Common Position text, which
introduces a definition of by-product. We hope that his will help
clarify the distinction between waste and product and therefore
maximise efficient use of resources.
21. The use of weight targets to encourage
recycling and waste minimisation do not always make sense, as
for some waste it is volume that matters more than the weight
(eg low density materials). It should also be noted that it is
volume that matters in landfills, not weight. Also, some of the
weight targets (eg in the WEEE Directive) are set at a ridiculously
low level that they may have more of a negative than positive
environmental impact, when transportation and processing are taken
into account (ie economies of scale matter).
22. Weight targets do not take into account
the full life cycle, and can have perverse or unintended consequences.
For example, there has been a drive to reduce the weight of packaging,
particularly for consumer goods. One solution to this problem
has been to increase the sophistication and complexity of packaging
materials, so that the same degree of protection can be afforded
to the product, but at a much lower weight. This clearly reduces
the amount of material which has to be manufactured and transported,
but also makes it significantly more complicated to recycle materials.
It is much easier to recycle a thick single polymer packaging
film than it is to recycle a thin and light weight foil which
may have used separate layers of polymers to achieve the same
level of protection and performance. For the best decision making
there is no substitute for considering the full life cycle, but
this remains difficult and costly to do in practice. In summary,
targets should be set depending on the material and product, maybe
using a combination of measures (weight, volume, toxicity etc)
rather than introducing a blanket approach for all.
23. Suppliers can influence manufacturers
by demonstrating that using more sustainable materials, or using
materials more sustainably, will improve their business. This
might be through cutting their costs, being able to improve product
functionality and performance, helping them meet regulatory obligations
at minimum effort or minimum cost, or by enhancing customer profile.
This requires very active interaction between customer and supplier.
In some sectors, such as automotive with its Tier 1 and Tier 2
suppliers, supply chains are very closely linked together. In
other sectors where materials may be used in a very wide range
of applications, the supply chains have been less closely linked
and there has been less involvement by suppliers in innovations
of the customer. At the moment, for sectors like chemicals, it
mostly happens when a customer has a driver to be more sustainable.
For example, recently Ford in Europe wanted to reduce the waste
generated by metal cutting machinery in the production of engines.
Part of the problem were the lubricants and cutting oil used in
the process, and by working closely with their lubricant supplier
the supplier was able to develop a vegetable oil based lubricant
which had both superior performance and superior environmental
impact. As a result, Ford was able to realise significant savings
in their engine plants. It is generally easier for a manufacturer
to influence their suppliers than the other way round. REACH may
encourage much closer interactions and exchange of information
along supply chains, and could lead to opportunities for more
sustainable use of chemicals. The application of mutual responsibility
influences both parties to act in a more sustainable way such
as shared responsibility for waste collection and recovery. Producers
also have a large part to play educating consumers. The Chemical
Industries Association's Responsible Care product stewardship
is a voluntary industry programme that works on this aspect, trying
to understand how customers use products and work with them to
develop new products, which help them. For example: the development
of a fabric treatment system to allow a downstream customer to
complete several fabric finishing operations in one step, leading
to significant water savings. Another successful example is the
Voluntary Emissions Control Action programme (VECAP) established
by the brominated flame retardant sector. Through VECAP, manufacturers
and users of brominated flame retardants are working together
to establish and share best practices on their handling to minimise
emissions to the environment. In carpets manufacture for example,
it resulted in a significant reduction in emissions along with
substantial cost savings.
5 More details of this programme, including guiding
principles and a goals brochure, can be downloaded from http://www.cia.org.uk/newsite/downloads/Sustainable_Development_Brochure.pdf Back
6
Earth's natural wealth: an audit New Scientist 23 May 2007,
issue 2605, pp 34-41. Back
7
www.ecodesign.at Back
8
http://www.basf.co.uk/en/uk/house/?id=0._jjBny.bw24Sd Back
9
http://www.chemistryinnovation.co.uk/roadmap/sustainable/roadmap.asp Back
10
http://www.chemistryinnovation.co.uk/roadmap/sustainable/casestudies.asp?id=64 Back
11
Roger A Sheldon, Green Chem, 2007, 9, 1273-1283. Back
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