Making the P2 Connection with the FOUNDATION Product Approval Module

Passage of the Pollution Prevention Act by Congress in 1990 was intended to focus industry as well as the U.S. public on efforts to reduce the amount of pollution being generated across the country.

The law gave the United States Environmental Protection Agency (U.S. EPA) the responsibility and the authority to develop and implement a source reduction strategy. As a result, EPA worked to integrate Pollution Prevention (P2) practices into general industry and reduce pollution “at the source” and not at the tailpipe, outfall, or landfill. The Act also required that EPA collect and disseminate information related to P2 to the public.

After passage of EPA’s mandate, each state then implemented its own P2 program which the federal law required to be as or more stringent than the program implemented by EPA. In the early 1990s, Indiana, for instance, adopted a very narrow definition whereby true Pollution Prevention could only be achieved through process change, in-process closed-loop recycling, or input substitution.

Using Indiana’s model as an example, the state’s goal was to reduce pollution through improved efficiency, recycling/reusing waste before it could be sent to a landfill, and by making changes to the raw materials used in the manufacturing process (input substitution). By focusing on the raw materials used in, or incidental to, production, a facility could identify less toxic materials to facilitate more environmentally safe production processes.

How can Cornerstone help your facility improve its P2 performance?

In the early 1990s, Cornerstone developed a chemical inventory system to analyze and track the chemical composition of materials used in production and manufacturing. Over time, Cornerstone’s chemical inventory system was further developed by adding SDS management to create the current FOUNDATION SDS Management and Chemical Inventory System. In addition, FOUNDATION determines the applicability of substances to the Emergency Planning and Community Right-to-Know Act (EPCRA), Clean Air Act, and OSHA regulations to help ensure continuous compliance.

While working with IDEM (the Indiana Department of Environmental Management) during the development of its P2 program, Cornerstone introduced me to the methodology of using a chemical inventory system to assist with Input Substitution. It seemed like the perfect tool to support P2 efforts through the identification of materials that could be substituted thereby protecting the environment (i.e., P2) and creating safer workplaces.

What can FOUNDATION’s Product Approval Module do?

The Product Approval Module in FOUNDATION enables users to fully evaluate and approve (or reject) materials to be used in their operation. The regulatory lists reviewed range from EPCRA, HAPs, Proposition 65 Chemicals, Carcinogens, Reach, ROHS, and can also incorporate customer-specific restrictions and chemicals of concern. Candidate lists are generated for each applicable regulation to which a chemical is subject. The Product Approval Module is also useful in compiling information for ESG (Environmental, Social and Governance) reporting related to customer requirements.

If a team of individuals is responsible for approving materials to be used in production, Cornerstone’s IT team works with the client to create a fully customized Product Approval system which enables mutual review, evaluation, and approval. A streamlined online approval process such as this eliminates delays in review and ensures a holistic approach product review.

Further Information

For more information or a webinar on our Product Approval system, please contact Cornerstone or your Sales Representative.


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