Making proactive safer chemistry a standard operating procedure

By David Bourne, Sustainability Strategy Lead, Consumer Hardware

Driving positive change to safeguard the health of humans, plants, animals, and earth’s planetary systems necessitates work on multiple sustainability focus areas. While climate change is the best known among these, the planetary boundaries framework illustrates others that are also important. In this framework, “novel entities” consist of chemicals and materials created by humans that never existed on earth before. The critical level of this boundary reflects the risk presented by the hundreds of thousands of synthetic chemicals currently produced without fully understanding their potential effects. While this planetary boundary was only recently quantified, safer chemistry has been a focus of Google’s sustainability work for many years in the built environment and food service as well as electronics. Its importance is clear, now more than ever.

Last year, we shared a new approach to our internal engineering process for inks and coatings incorporating a proactive hazard-based evaluation of the specific chemicals used in those formulations. That approach has resulted in safer choices where Google engineers have directly designed parts and processes. Most products however contain material choices made by other companies at various levels of the supply chain that also design and engineer parts and subcomponents. Because electronics products require some of the most complex supply chains on the planet, driving adoption of this proactive approach in supply chains is essential to achieving systemic change making safer materials more accessible to many product companies.

Our Restricted Substances Specification (RSS) is a key policy document that communicates our requirements to suppliers for chemicals and materials used in our products as well as those used during the manufacturing processes that produce them. Our specification has followed a common model shared by many companies which is that it contains lists of individual chemicals or groups of chemicals with restrictions and prescribed limits, often more conservative than regulatory requirements. However, we’ve recognized that chemicals are often only added to restricted lists after many years of use in manufacturing and typically when detrimental effects have become apparent to environmental protection stakeholders and regulators. This approach is slow to address newly introduced chemicals or ones whose use has significantly increased over time.

This past November, we opted to implement a more proactive strategy in our Restricted Substances Specification - Revision E. Our updated specification still contains many traditional list-based restrictions but also introduces new hazard-based requirements for the first time.

Mandatory Hazard Ratings

The first of these requires any solvent, flame retardant, or Per- and Polyfluoroalkyl Substance (PFAS) at or above specified concentration levels used in our products to have a hazard rating, regardless of whether the chemical is regulated or not. These three categories cover thousands of individual chemicals that could potentially be used in manufacturing. This means that Google suppliers will need to obtain a chemical hazard assessment (CHA) if the chemical in question does not already have a hazard rating. Google has already made significant investments to jump start this process having commissioned over 110 CHAs on the nonprofit ChemFORWARD platform since 2020, including many commonly used solvents and flame retardants. Suppliers have several options to commission a CHA, however those that utilize ChemFORWARD will benefit from the assessments previously commissioned by Google and all other subscribers on the platform. Suppliers can review existing hazard ratings against their chemical inventory and request new hazard assessments as needed. Google is also sponsoring access to ChemFORWARD’s platform for select suppliers during calendar year 2024 to assist in their transition to this proactive assessment approach.

Restricting Highest Hazard Offenders

The second requirement restricts the use of any solvent or flame retardant with a ChemFORWARD Hazard Band rating of “F” (or equivalent rating from other hazard assessment frameworks) as well as any PFAS chemical without explicit preauthorization from Google. Suppliers seeking preauthorization for a specific chemical will need to submit a technical justification as well as a roadmap and timeline for implementing a verified safer alternative. This approach incentivizes our suppliers to proactively research and engineer safer alternatives into their operations and avoid this restriction. It also provides Google an opportunity to assist suppliers that submit preauthorization requests and share alternative material options or design solutions that could avoid using high hazard chemicals. In some cases, alternative solutions may not yet exist, but this approach is still critical in creating transparency for use cases where further research and innovation is needed to bring verified safer alternatives to market.

Our new hazard-based requirements represent a strategic progression of our safer chemistry work. The challenges we face are shared across our industry and many others; however, our goal is to enable industry transformation and to catalyze the broader investments needed to drive systemic change. That’s why we have decided to become a Founding Partner in the Safer Chemistry Impact Fund. The fund is a project of Windward Fund and seeks to work across industry sectors to advance science-based, data-driven solutions to systematically eliminate hazardous chemicals and replace them with verified safer alternatives. Through the deployment of high impact capital, the fund aims to positively disrupt entrenched systems of hazardous chemical use.

The fund was created with leaders from Google, Apple, and Nike to mobilize global investment from committed corporate and philanthropic entities. The collaboration seeks to identify, fund, scale, and measure verified impact solutions to embed safer chemistry across supply chains and establish safer chemistry as the standard operating procedure in commerce.

We are excited to have taken these steps, but we know much more is needed to accelerate progress. Brands and suppliers alike need tools to evaluate chemical hazard properties alongside functional ones that enable product performance. The pace of chemical hazard assessment needs to increase and the adoption of proactive policies needs to grow. We are confident these are all possible and are passionate about working together with others to bring about transformative change.

Image: Transparent chemistry glass tubes filled with substances by Horia Varlan is licensed under CC BY 2.0.