MACRAMÉ Experts used the opportunity to provide feedback in the commenting phase of the revision of the Safe and Sustainable by Design Chemicals and Materials Framework. MACRAMÉ Experts appreciated the larger flexibility and the stronger focus on innovation of the revised version. On the other side, the experts pointed out that the draft is still falling short of providing a holistic approach integrating functionality with safety and sustainability along the innovation process and value chain. The draft with its 125 pages is considered quite overwhelming for (small) companies, especially if they have no experience in SSbD. MACRAMÉ Experts suggested to add a first run-through of all the different steps (scoping, safety, sustainability,…) and their goals. Since MACRAMÉ is not a SSbD project but its scope is the development and pre-validation of test methods usable for advanced materials in complex systems representing later lifecycle stages, the MACRAMÉ comments were focused on safety aspects and the relationship between SSbD and regulations. The specific comments addressed the following topics:
Scoping analysis and intrinsic physico-chemical properties:
MACRAMÉ experts highlighted that intentional and unintentional transformations of the chemicals/materials during the production process and the use and end-of-life phase need more attention. Transformations of the material need to be addressed both in the physico-chemical characterization as well as in the hazard assessment. The framework could highlight the concept of use maps since the transformations will depend on the specific use case (product) of the material.
Safety assessment:
The flexibility resulting from the removal of the strict separation of hazard and exposure into Step 1-3 of the original Framework was highlighted by MACRAMÉ Experts. However, they saw during discussions within the project and collaborating projects that the revised draft framework is not clear enough on which information is required before a decision can be made and whether hazard or exposure (or both) should be mitigated in a SSbD approach.
Environmental sustainability:
MACRAMÉ Experts highlighted that how to define a benchmark is not addressed appropriately. Is the own product enough or is a market average for the same type of product needed?
Evaluation:
Furthermore, MACRAMÉ mentioned that recommendations are missing on which trade-off method is best to use when. Trade-offs might also include selections of hazard vs. exposure mitigation measures. Additionally, only examples are provided but not a clear methodology on how to aggregate results.
MACRAMÉ Experts are following closely the revision of the SSbD Framework and look forward to reading the final version and to contributing to make advanced materials safe and sustainable.
