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ORF Home > Environmental Protection > Criteria for Listing Substances of Concern

Criteria for Listing Substances of Concern

Groups of chemicals and specific substances must meet all of the following three criteria to be listed as Substances of Concern:
1.    Have Significant Use in Facilities or Mission Activities.  The substance must have a significant known or potential use or emission from products used in NIH facilities or mission activities.  Over 100,000 discrete substances are used or maintained in NIH research repositories.  Most of these are in very small quantities, present minimal potential for exposure and release, do not justify development of procurement controls and will not be listed as SOCs.  Exceptions may be made for extremely hazardous substances that present unacceptable risks even in small quantities.
2.    Pose Significant Risk.  The substance must pose a known hazard or risk in the supply chain, as used at the NIH or after use:
·        Human Health.    Substances that can result in sufficient levels of human exposure and intake as evidenced by biomonitoring or other data, to cause potential adverse health impacts.  These include but are not limited to asthmagens, allergens, carcinogens, endocrine disruptors, teratogens and substances causing other types of acute or chronic toxicity to humans.
·        Safety.  Substances with other hazardous properties such as flammability, corrosivity or reactivity.
·        Security.  Substances that are potentially explosive, extremely toxic or particularly subject to abuse or diversion for malicious use, or require special compliance with specific security requirements or precautions.
·        Environment.  Substances that are bioaccumulative, persistent or have other adverse impacts when released into the external environment.  Examples of such impacts include upsetting waste or wastewater treatment processes, toxicity to wildlife, reducing biodiversity and ecosystem services, increasing global warming, depleting stratospheric ozone, generating air pollutants, or preventing NIH from meeting goals established by its Environmental Management System.
·        Research Mission.  Substances with a potential to contaminate or interfere with research activities or results; affect laboratory animals, or are likely to be present as contaminants in facilities undergoing decommissioning and require remediation before beneficial reuse or demolition.
·        Regulatory Compliance.  Substances that may be banned, restricted, require special inventory controls, security precautions; are subject to regulation at very low concentrations; are associated with unusually high potential liability, or are likely to be regulated as hazardous waste when disposed of.
·        Sustainability.  Substances that require excessive amounts of energy or water or deplete scarce resources to produce or that make the final product less reusable, recyclable, recoverable or suitable for regeneration; or impede meeting other NIH sustainability and environmental justice goals. 
3.    Suitable Alternatives are Available.  Alternative products or services that do not contain or emit the substance(s) of concern, and pose a lower risk(s) must be developed, suitable and approved for the specific intended use and available at reasonable cost.  Substances in critical uses that do not meet this criterion will be listed as SOCs but may not be amenable to reduction by procurement controls.

This page was last updated on Mar 03, 2021