Ask someone involved in manufacturing, particularly a person involved in critical cleaning, about regulatory trends. The responses are apt to be strong and impassioned. Regardless of the portion of the political or environmental spectrum we occupy, we all have strong feelings. Everyone thinks we could be doing a better job – whatever “better” means. And we all know that government isn’t doing it right – whatever that means.
We questioned a number of people in manufacturing and academia on what green, safe, and sustainable will look like in 2020. We asked how these issues are likely to impact chemical use and manufacturing processes. Some of these insights appear in articles in the October (1) and Nov/Dec (2) issues of Controlled Environments Magazine. In this companion article, explore additional thoughts, hopes, and fears.
Reshoring
Reshoring is relative. We can think in terms of the convenience and ease of oversight of buying local and also in terms of labor costs and environmental restrictions. We have seen some trends toward reshoring (3-4). Is it possible that near-term safety and environmental issues will redirect that trend? Anselm Kuhn, Manager at Finishing Publications, Stevenage, UK sees it as “an indisputable fact that year-on-year, environmental regulations, which also have an impact on cleaning processes, are remorselessly tightening. Therefore, one could ask oneself whether this process will plateau or whether regulations will continue to become fiercer and fiercer.” Kuhn points out a link between trends in worker safety and environmental regulations and trends in outsourcing and reshoring. With increasing regulations, “the inevitable outcome has to be an increase in manufacturing costs and/or a migration of manufacturing activity to regions (other states, other countries) where regulations are less Draconian.” While outsourcing and off shoring could both be seen as means (albeit not a very ethical means) of shedding any problems associated with cleaning. Kuhn adds that “judging from the Chinese technical literature which passes over my desk, the Chinese, at least in theory, are also trying to clean up their act.”
Higher Scrutiny
Many of us would predict scrutiny of more and more chemicals to occur. We periodically discuss the “witch hunt du jour.” However, interest in safety and environmental issues may also come from a greater diversity of agencies and private entities. Chris Jones, Director – International Operations at Brulin & Company Inc. Indianapolis, IN – expects that “the chemistry used in cleaning processes will be topics of interest to more groups than in the past; there will be more demand for improvement in the areas of environmental protection and worker safety.” Interested groups will include more local and state government and corporate entities, in addition to the well-known federal legislation and international efforts like REACH. Many of these groups will demand specific demonstration that products are green and sustainable in some way. This trend is likely to grow. This means that third-party certifications like Green Seal requirements are likely to increase.”
Globalism and Commonality
With international regulations and global corporate sustainability policies, one could speculate that the number of chemicals that are under regulatory scrutiny be consolidated in the hear future. “Global ethics drive commonality,” asserts John Burke, CMFS STLE Fellow and Global Director of Engineering Services at Houghton International in Valley Forge PA. Burke explains that many companies are adopting a global ethics program; and that sustainability is a subset of those programs. “Companies are beginning to say that it makes no sense that you can use boron in the United States but not in Europe. I am seeing companies in the United States banning boron.”
Ed and I are also seeing indications of enthusiastic corporate-wide policies. Some of these policies may be pro-active from the point of view of EH&S or corporate legal; but they may be (in our opinion) unrealistically comprehensive in outlawing the use of chemicals or even of entire classes of chemicals. We would be delighted to see companies look at the process, not at the chemical. One reason is that banning one “bad” chemical by no means guarantees that a green, safe, or sustainable process will be selected by us intrepid and imaginative process development people. We are also likely to see increased capital, training, and ongoing costs; and the process may not work as well as we would hope. Other than that Mrs. Lincoln …
Divergence
Safety and environmental regulations can be confusing; and in some places even contradict each other. In the United States, it seems as if each locale has a different approach to dealing with chemical usage. While frustrating, part of this is inevitable; you may recall from your history studies that we have something called “States Rights.” However, one might ask, could global corporate policy provide a pathway to consolidation?
Jones explains that EU legislation like REACH, with a long list of so-called “substances of very high concern”, impacts not only what we send to Europe but also what is required by manufacturers in the U.S. and Asia who supply product to Europe. He reasons that in the future, “international activities could have the impact of providing a consolidation of excluded chemicals.”
However, Jones points out that there is also a “potential for increasing divergence among what individual companies and municipalities have on their lists of restricted or excluded chemicals.” Jones explains that while, on the surface, the lists of excluded chemicals by an individual manufacturer might seem capricious, there can be sound reasons related to complex supply chains. For example, the small company that supplies several larger companies, each with distinct requirements, needs a single process and set of suppliers that will satisfy all of them. Jones concludes that the overall impact would be to shorten the list of allowed ingredients, and require suppliers to work around these limitations.
What’s next?
The future of environmental regulations remains uncertain. “That’s a challenging question,” muses Tony Revier, Past President of the National Association for Surface Finishing (NASF). “It’s hard to predict what government will do given the changing political arena, however, that is why the NASF (GAC, Government Affairs Committee) is so important today, to stay on top of these issues.” Revier points out that “change can be your best friend or your worst enemy.
Without going out on a limb, we might strongly suspect that continued governmental regulations are inevitable. Taoward Lee, Manager of Technology at Ecosystems Inc in Costa Mesa CA contends that there is a positive role for government. “Government can be instrumental in promoting technologies before they are cost-effective, as in the development of hybrid cars and renewable energy. They make a lot of mistakes—but we all make mistakes. We need mistakes so we can learn from them!”
Efficiency Goals
“What if the government set efficiency goals, like the goals we set to get to the moon?” Jason Marshall, Director of the Cleaning Laboratory at TURI, Toxics Use Reduction Institute (TURI), at University of Massachusetts Lowell asks the question, using automobiles as an example. “They could propose a goal of 300 mpg; and then give us 10 years to get there.” Marshall adds that “we can redesign automobiles so that they don’t use as much energy. But, you also have to consider safety.”
“In manufacturing, there is a tremendous waste of energy associated with inefficient design and use of pumps,” explains Lee. “Even now, pumps can be designed for higher efficiency.”
Power
Lee asserts that “the future will be in lowering energy consumption without compromising quality. Cost will be the driver. Because the infrastructure is set, power companies can extend its utility of it by penalize people peak usage.”
“In terms of solar energy, there are two types,” explains Lee. “Photovoltaic is 15 to 17% efficient. Solar heating, which is not as well-known, is 50 to 95% efficient, depending on the ambient temperatures and type of solar collector used. There are engineering issues yet to being addressed, but what if we could use solar energy to heat process tanks? We can get to 300 – 400 degrees F using evacuated heat pipe collectors.” Lee predicts that in the next 5 to 10 years, the trend toward solar energy for heating could grow faster than photovoltaic.
Materials of Construction
“The materials of construction we use in machining are changing, particularly in automotive applications,” explains Burke. “We are seeing increased use of aluminum and plastic, because lighter materials favor less fuel consumption. There is no shortage of aluminum; and it is said to be the most recycled metal on the planet. Aluminum melts at lower temperature; therefore it uses less energy during production.” Burke adds that changes in materials of construction will influence the lubricants, cleaning agents, and finishing processes that are used; “for example, cleaning agents used with aluminum cannot be highly alkaline, and there will be some head scratching in developing new painting processes.”
Better regulations
At the end of the day, we need regulations that protect the local environment, the global environment, that protect workers – and these regulations have to do so in a sustainable manner. That means rules have to be coordinated; they should be developed in a scientific, logical, and prompt manner. The rule development process should be transparent and understandable to the public. Somehow, “political chemistry,” the mud-slinging of a given technology by the competition should be eliminated, or at least minimized. Rules should not conflict with each other; and they should not be highly-variable from locale to locale. Rules should be practical and achievable. We will never control all chemicals; so we need to manage processes.
References
1. B. Kanegsberg & E. Kanegsberg, “2020 Vision: Green, Safe, Sustainable-Part 1,” Controlled Environments Magazine, October 2014,http://digital.cemag.us/controlledenvironments/october_2014#pg20
2. B. Kanegsberg & E. Kanegsberg, “2020 Vision: Green, Safe, Sustainable-Part 2,” Controlled Environments Magazine, November-December 2014, to be published by late November, 2014.
3. B. Kanegsberg and E. Kanegsberg, “Home Turf,” Process Cleaning Magazine, May/June 2011.
4. B. Kanegsberg and E. Kanegsberg , “20/20 Vision on Outsourcing,” Controlled Environments Magazine, October 2013; http://www.cemag.us/articles/2013/10/20/20-vision-outsourcing
