UEIL HSE Committee Working Group
The HSE Committee of UEIL has created a dedicated working group to discuss the issue of Safe and Sustainable by Design (SSbD). The working group is only starting its activities and is actively seeking new participants, so UEIL members are highly encourage to join.
Is SSbD just another acronym or a driver for innovation for lubricant manufacturers? The SSbD was introduced as a concept by the EU Commission’s Chemical Strategy for Sustainability in October 2020. It has recently been described as a ‘framework for sustainability frontrunners’ rather than a legislative requirement. You may be wondering why EU lubricant manufacturers are giving attention to SSbD given all the other challenges faced by this industry. The Environment Commissioner Virginijus Sinkevičius recently identified lubricants as a logical target and ‘low hanging fruit’ for a proposed new Regulation on Ecodesign for Sustainable Products (ESPR). Not addressing SSbD development now could be a costly mistake, as SSbD cannot be viewed in isolation.
What does SSbD actually mean?
Some understand safety as some form of assessment of risk by considering the inherent hazard of the product, as well as how that product is used and by whom. However, others still maintain that safe equates to ‘not hazardous’ where chemicals are concerned.
Similarly, the concept of a sustainable product is likely to mean many different things depending on an individual’s perspective. Does it mean biobased, biodegradable, low product carbon footprint or one of a range of other measures, or is it a combination of several of these properties? Is a sustainable lubricant, for example, one that readily biodegrades or is it a lubricant that is relatively less biodegradable but allows for improved fuel efficiency and has a lower carbon footprint? Both answers could be correct for different applications.
And what does the ‘by design’ part mean given that no lubricant manufacturer currently designs unsafe and/or unsustainable products for any market.
42 LUBE MAGAZINE NO.170 AUGUST 2022
Without a thorough understanding of SSbD, lubricant manufacturers might assume that it only concerns their raw materials such as virgin base oils, re-refined oils, and additives. However, the current framework proposal doesn’t allow such raw materials to be categorised as SSbD, only finished lubricants. Therefore, it will not be possible to describe a lubricant as SSbD without a clear, quantifiable understanding of the in-use and end-of-life phases. Life Cycle Assessment and Product Environmental Footprint are being considered as an integral part of SSbD and the ESPR, but such assessments are a very specialised, costly exercise. It is unlikely that every EU lubricant manufacturer will have the necessary in-house expertise, finances, or other resources to guide sustainable product development activities, especially SMEs.
Furthermore, current Ecolabel certified lubricants are not the answer to SSbD, as they will likely fall short of being categorised as SSbD. Indeed, Ecolabel criteria for lubricants do not currently consider product carbon footprint and/or other environmental markers including the contribution of the use phase or what happens at the end-of-life of the lubricant.
Why should my company get involved now? Like all new regulatory initiatives, the Commission seeks the views of stakeholders before finalising implementing legislation. The UEIL working group on SSbD will participate to the consultation with the goal of helping the Commission develop SSbD guidelines that are workable and do not generate additional barriers to competition, especially for SMEs. This will ensure that UEIL members’ views are heard by the Commission.
For more details contact:
secretariat@ueil.org
LINK
www.ueil.org
Page 1 |
Page 2 |
Page 3 |
Page 4 |
Page 5 |
Page 6 |
Page 7 |
Page 8 |
Page 9 |
Page 10 |
Page 11 |
Page 12 |
Page 13 |
Page 14 |
Page 15 |
Page 16 |
Page 17 |
Page 18 |
Page 19 |
Page 20 |
Page 21 |
Page 22 |
Page 23 |
Page 24 |
Page 25 |
Page 26 |
Page 27 |
Page 28 |
Page 29 |
Page 30 |
Page 31 |
Page 32 |
Page 33 |
Page 34 |
Page 35 |
Page 36 |
Page 37 |
Page 38 |
Page 39 |
Page 40 |
Page 41 |
Page 42 |
Page 43 |
Page 44 |
Page 45 |
Page 46 |
Page 47 |
Page 48 |
Page 49 |
Page 50 |
Page 51 |
Page 52 |
Page 53
