Updated April 2025.
For many organisations, the use of hazardous chemicals in production or research is unavoidable.
However, environmental, health and safety (EHS) teams can take an active role in reducing the risks associated with these chemicals by substituting them with less hazardous alternatives.
To be able to perform a chemical substitution in an effective manner – especially in the absence of software for chemical management – it is helpful to learn more about the topic.
By using a step-by-step method on how to substitute, it will become easier to begin the process of using less dangerous chemicals at your workplace. After testing this method, you will learn what works best for your company and how to establish a procedure that you and your colleagues can use.
What your safety team should know
Substituting is not as easy as replacing one chemical with another and the process might not be the same in all situations. Methods that work for one business or process, might not be suitable for another business or way of using the chemical.
One approach to use is to look at the production techniques and product design. For example, when designing a chair, one might use the process of wedging or snapping pieces together to assemble the chair, instead of using glue or screws.
Often you have to try different solutions and alternatives to find the best one.
Areas to consider are:
- Hazard and exposure to the chemicals
- Technical performance
- Economic aspects
- Energy and resource use
- Waste and recycling
5-step process for substituting chemicals
Substituting hazardous chemicals offers several important benefits to workplaces that handle them.
In addition to reducing the potential for accidents and injuries, chemical substitution can reduce costs associated with disposal, storage and PPE as well as improve employee morale by providing a safer work environment.
Plus, in some cases where toxic materials are used frequently, such as in paint shop operations or dry-cleaning businesses, physical surroundings may be improved through reduced emissions from substituted products.
Below we will share 5 steps you can follow. These steps are based on the European Chemicals Agency (ECHA) model “How to substitute?”
Note that in the UK, ‘UK REACH’ is in effect. The UK’s Health and Safety Authority (HSE) has a similar approach to chemical substitution.
Step 1: Identify the chemical you want to evaluate, substitute and/or phase out
Get an overview of all the substances/chemicals at your workplace. This can be achieved by creating a chemical register and conducting an inventory of all the chemicals present on site. You can choose to do this manually or to implement digital software for chemical management.
To know what substances the chemical contains and how hazardous it is, you can easily use the safety data sheet to find this information.
Prioritise the substances to see what chemical(s) candidates for substitution. You can look at the most hazardous chemicals that might not be necessary and chemicals with substances that are, or may be, subject to regulatory actions now or in the future.
You can use regulatory lists such as:
- SIN-list (Substitute It Now) consists of hazardous chemicals that should be removed as they are a threat to human health and the environment.
- List of substances subject to authorisation (Annex XIV of REACH/EU)
- Candidate List of substances of very high concern for authorisation (EU)
- REACH Annex XVII: REACH Restricted Substance List 2019
Ask yourself: What is the function of the chemical that is to be replaced?
Step 2: Identify potential alternatives
Now it is time to look for alternatives. Here are some questions to ask:
How would you have solved the problem if you didn’t have the chemical in the first place? For example, do you really need to provide your customers with a printed receipt that may contain hazardous ink developers, or would an electronic receipt be a suitable alternative?
This evaluation process should include careful consideration not only of toxicity but also flammability and other physical properties.
Step 3: Assess, compare and select alternatives
If you need to use a chemical, what other options can you choose from? There are services that you can add on to a digital chemical register to find options to use and evaluate other chemicals.
In what ways can humans or the environment be exposed to the alternative product or waste products during manufacturing, use, disposal of waste or in recycling?
How does the alternative method or substance affect quality and function? In the substitution process, prioritise which elements you assess first and how these are detailed. When looking at different chemicals, always evaluate the risks. How hazardous is the chemical? How will people and the environment be exposed?
You can use the SIN-list during this step also. Look at the lifecycle perspective both for new product designs without chemicals and the chemicals hazard compared to gas emissions, for example.
Step 4: Test, implement and improve
Choose what new chemical or problem-solving solution you are going to test first. Decide how the test will be performed and how long the test period should be. Look at the different costs of the different methods you will use to test the new solution.
When your pilot test has been successfully launched, you can start to implement the alternative. Make sure you have a detailed plan to implement the substitution.
Collect feedback from everyone who is directly affected by the substitution and make necessary improvements. Make it easier to evaluate and improve over a longer term by using a chemical management system.
Step 5: Inform your supply chain
Your customers and suppliers might need to be informed of your changes. Perhaps you also want to publicise the information on your website to gain an advantage over your competitors.
Keep in mind that your customers might need time to inform their customers about your changes.
Conclusion
After completing the above steps and finishing the substitution, you can report on the experience and create a standard operating procedure that can be used by yourself and your colleagues for future substitutions.
Don’t forget that these 5 steps will have to be exhaustively documented. There are various assessment tools and methodologies, but be aware that they differ by sector and some may require specialist training.
Chemical substitution software can drastically cut down on the amount of time spent on this process. Click the link below to find out more:
