This Archive of the IC2 Safer Alternatives Assessment Wiki contains a great deal of information that those new to alternatives assessment may find helpful in understanding many of the drivers and details of the AA process. Readers, however, should remember that the content in this archive is not being updated and may contain out-of-date information and bad links.
Introduction & Background
Why Assess Alternatives?
The use of toxic chemicals can result in worker and consumer exposure that leads to potential health effects, can result in the generation of emissions to air, water and land, and can adversely affect companies' bottom line as they devote resources to controlling the liabilities (including regulatory compliance, training, insurance, control and remediation costs) associated with the use of these chemicals. Many state and local environmental agencies want to minimize the negative effects associated with toxic chemical use while encouraging the viability and growth of the companies that employ their citizens and support the health of their economies. Finding safer alternatives that companies can adopt (i.e., that satisfy their functional needs and performance requirements and are cost effective) is a highly efficient way to achieve these goals.
The overall process of assessing alternatives involves identifying potential alternatives and then determining whether they are 1) safer, 2) functionally equivalent, and 3) economically feasible. Individual states and local agencies will likely have their own unique policy, regulatory, and/or technical assistance response to the information obtained from an alternatives assessment. However, the goal is to have a consistent process that allows programs to use each others' studies in order to minimize duplication and maximize dissemination of valuable information on safer alternatives to chemicals of concern.
What is the Goal of Your State?
Goal setting is an essential step in defining what a project is about and deciding what the scope needs to be to achieve the goal. The goal of a project is often determined by the questions that need to be answered. The types of questions that a state legislative or executive branch may want to answer can range from:
This first question was posed by the Massachusetts Legislature to the Toxics Use Reduction Institute in 2005. More recently, Maine and Washington have considered the third question as they seek to restrict the use of chemicals they have identified as being of significant concern to their economy and constituents. California is looking at the second question as part of its process to implement a green chemistry program. What is the Scope of Your Project?
What is the Scope of Your Project?
Once you understand the questions you need or want to answer, the next step is to determine the scope of your project.
Why Assess Whether an Alternative is Safer?
State and local programs conduct alternatives assessment for a variety of reasons, from determining whether or not it is reasonable to expect companies to find safer alternatives to chemicals of concern to identifying specific safer alternatives to chemicals of concern in order to mandate reductions in the risks posed by toxic chemicals in particular products. For example:
Once you've established your goals and scope, you can then decide which of the many elements of the Alternatives Assessment Protocol apply to your process, and to what depth you need to research and analyze in order to be able to answer your questions.
Defining the scope of your project is very important - and can be tricky. An example of the scope developed by the State of Maine Department of Environmental Protection to conduct a study on the availability of safer alternatives to the use of brominated flame retardants in shipping pallets is attached. In addition, an amendment to the original scope was created as the scope of the project became better understood.
When considering the question about how to define the term "safer", there are various degrees of "safe" that might apply. Some examples include:
Example definitions of "safer alternative"
Methods for Identifying Chemicals of High Concern
There is a common set of questions that is asked by state governments and advocacy groups when identifying chemicals of concern.
Other aspects to consider when determining what chemicals are of concern include the availability of data, and the potential for human and/or environmental exposure to the chemical.
An important tool in the process of identifying chemicals of high concern is defining what is meant by that term. The State of Washington defines high priority chemicals in its Children's Safe Products Act as follows:
"High priority chemical" means a chemical identified by a state agency, federal agency, or accredited research university, or other scientific evidence deemed authoritative by the department on the basis of credible scientific evidence as known to do one or more of the following:(a) Harm the normal development of a fetus or child or cause other developmental toxicity;
(b) Cause cancer, genetic damage, or reproductive harm;
(c) Disrupt the endocrine system;
(d) Damage the nervous system, immune system, or organs or cause other systemic toxicity;
(e) Be persistent, bioaccumulative, and toxic; or
(f) Be very persistent and very bioaccumulative.
PROCESS FOR IDENTIFYING CHEMICALS OF HIGH CONCERN
States like WA and ME are going through a process of:
There are a number of guidance and tools that could be used by states to identify chemicals of concern.
US FEDERAL AND STATE RESOURCES
With an increasingly global economy, states may choose to use or borrow from the EU lists such as the SIN list to simplify the process of identifying chemicals of concern. Alternatively, states may wish to go through a more state-specific process of identifying chemicals of concern. This may allow states to focus their limited resources on a smaller subset of chemicals to consider for alternatives assessment.
The Massachusetts Toxics Use Reduction Institute used the TUR Science Advisory Board’s list of More Hazardous Chemicals as a pre-screening list for its alternatives assessment process. In this list, “hazard” is interpreted to include inherent toxicity, potential for exposure through dispersal in the work place (based on the physico-chemical properties of the chemicals, such as vapor pressure) and indicators of safety of use (e.g., flammability).
Other tools include on-going government projects, such as the EPA Design for the Environment program, which has identified specific chemicals and applications for evaluation. Other legislative indicators, such as the EU Restriction on Hazardous Substances (RoHS) directive, could be used to identify a short list of chemicals of concern.
Lists provide a good starting point. The International Chemical Secretariat (ChemSec), a non-profit organization focused on moving toward a toxic-free environment, created a list of chemicals it determined were of particular concern and should be first in line for substitution. ChemSec collaborated with leading NGOs in the European Union and beyond to develop the Substitute It Now (SIN) List of chemicals of concern. For the most part these chemicals are either designated as PBT, vPvB or CMR. There are other chemicals included in this list that have been identified by ChemSec as being of particular concern. Currently there are 17 PBTs, 232 CMRs and 30 chemicals on the list for other reasons. While this is an important and useful list, it is necessarily dynamic, as more scientific research and data about other chemicals becomes available as part of the EU REACH legislation.
Many companies are also taking stock of their chemical inventories and identifying chemicals of concern within their supply chains. In 2008 the Green Chemistry and Commerce Council (GC3), a business network focused on green chemistry and design for environment coordinated by the Lowell Center for Sustainable Production, compiled a list of chemicals that firms have deemed restricted in some way, based on concerns about negative environmental or health impacts, or some other factor. The list includes some 860 entries from 19 corporate restricted substance lists representing retailers, electronics, textiles, apparel, building products, consumer products, automotive, flooring, commercial cleaning products, aerospace, and pharmaceuticals sectors. When provided, the list includes the type of restriction and driver behind it, as well as how the chemical is used. An analysis of the compiled restricted substances lists as well as the searchable list itself are available in the Chemical Database Resources section.
If a state or local program has identified more than one chemical of concern, it may be necessary to prioritize which chemicals will be assessed first. There are different goals associated with this kind of assessment. Prioritization may be linked to specific stakeholder concerns in the state. The priority for which chemical to assess, however, is more commonly based on the impact it poses to the environment or health and safety.
IC2 recommends that selecetion of which chemicals to assess be based not on state legislature choices only but on the recommendations and considerations of the various interested stakeholders. Stakeholders typically include the companies that manufacture the chemical, the product it is incorporated into, and/or the alternatives. Other stakeholders include organizations concerned about the impact on human and/or environmental health. These stakeholders may be interested in body burden data associated with the chemical or the presence of the chemical in products to which vulnerable populations are exposed. State programs have prioritized chemicals by a combination of both hazard endpoints (e.g., PBTs and CMRs) and proxies for exposure potential. For further details see Examples of Prioritization Methods below as well as the Profile Chemical Hazard and Exposure section.
As part of its Children's Safe Products Act (CSPA), the State of Washington prioritizes chemicals of high concern to children (CHCCs) by comparing High Priority Chemicals (HPCs) with chemicals found from biomonitoring and anaylses of potential routes of exposure.
Washington identifies chemicals as CHCCs "after considering a child's or developing fetus's potential for exposure to each chemical". Washington considers the following criteria in its process to identify CHCCs:
(a) The chemical has been found through biomonitoring studies that demonstrate the presence of the chemical in human umbilical cord blood, human breast milk, human urine, or other bodily tissues or fluids;In Washington it was determined that lower priority could be given to chemicals that are:
(b) The chemical has been found through sampling and analysis to be present in household dust, indoor air, drinking water, or elsewhere in the home environment; or
(c) The chemical has been added to or is present in a consumer product used or present in the home.
The objective of profiling chemical hazardous and exposure is to provide background information on each chemical of concern, highlight associated environmental, health and safety issues; and provide a baseline against which the alternatives can be compared.
Chemical Hazard Characteristics
Characterizing a chemical based on its inherent hazards is an essential component of conducting an alternatives assessment, because it allows you to assess whether or not an alternative is indeed preferable from an environmental, health and safety perspective. The hazard properties are intrinsic to the chemical, which means that regardless of the way that it is used, these characteristics do not change. Given the difficulty in knowing or anticipating all of the different applications for a chemical, the hazard data and characterization are extremely useful to have in hand for current and potential users of the chemical.
The specific hazard characteristics examined will depend on your definition of "safer alternative." For some alternatives assessments, safer alternative has been defined by statute or regulation; in others, it has not. Alternatives assessments are more or less extensive, depending on the number of hazard characteristics evaluated.
HAZARD CHARACTERISTICS TO CONSIDER
State and local programs conducting alternatives assessments need to determine what chemical hazard and exposure criteria they are interested in including in the assessment. Hazard endpoints that could be considered include:Physical Hazards
Human Health Hazards
Note that no alternatives assessment done by the US EPA, Maine, Washington or the United Nations (UN) in implementing the Stockholm Convention, has examined a chemical for every one of the 19 characteristics listed above. The US EPA Design for the Environment (DfE) Program evaluated in it's Flame Retardant assessments, 11 endpoints. Green Screen evaluates chemicals on the basis of 17 endpoints. The hazard characteristics evaluated need to be consistent with the program's policy objectives; otherwise there is a danger of paralysis by analysis.
Information about potential human health and environmental impacts associated with the use or exposure to the chemicals of concern can be found in a number of sources: public databases, peer-reviewed scientific journals, reference materials, industry trade group resources, and advocacy group resources. See the Resources section for more information
SOURCES OF INFORMATION
The following is a suggested hierarchy of validity for sources of information:
Exposure potential is challenging to generalize, as it is affected by the specific use of a chemical. For instance, when considering a chemical that will be incorporated into a product with negligible potential for human or environmental exposure after production, the exposure concern is primarily associated with the production process and possible occupational and environmental exposures. If a chemical is incorporated into a product in such a way that it could be released during use, the AA analyst must consider the specific mechanisms that could lead to exposure by humans or in the environment. Finally, exposures that occur during the end-of-life management of the chemical and/or product into which it is incorporated depend on the state of the chemical or product and the management method to which it is subjected.
In a risk assessment model, exposure is estimated by examining chemicals in a specific end use for a particular population. For example, hypothetically one could perform a risk assessment for lead in a toy coated with lead-based paint and used by toddlers. Simplified, one could estimate exposure by knowing the concentration of lead in the toy, how often a child would interact with the toy, how often the child would put the toy in his or her mouth, how much of the lead would dissolve in the child's saliva, and how much would be taken up by the child's gastrointestinal tract. Much of this information does not exist.
Depending on how many chemicals are evaluated, the types of exposures of interest, and the accessibility of relevant information, risk assessments can be time-consuming, costly, and impractical. Many assumptions need to be made in risk assessments related to product use, and this uncertainty can make these evaluations contentious. A large area of uncertainty when estimating exposures from the use of consumer products is the lack of information about the types and amounts of chemicals in them. The US EPA provides guidance on conducting risk assessments related to children’s exposures that focuses on providing information related to children’s behaviors, but limited information exists around actual levels of chemicals in products.
Governments are using proxies for exposure potential as way of addressing the challenges associated with a full risk assessment. These proxies do quantitatively estimate exposure, but they provide a qualitative description of exposure potential that can be especially useful in prioritizing chemicals. Proxies can include:
State legislation defining proxies for exposure potential
Added to or present in a consumer product present in or used in the home
Contained in a children's product offered for sale in state
Identified as HPV chemical by US EPA
Found through biomonitoring studies: human umbilical cord blood, human breast milk, human urine, other bodily tissues or fluids
|Found through sampling and analysis to be present in household dust, indoor air, drinking water, elsewhere in the home environment||
Found through monitoring to be present in fish,wildlife, or the natural environment
|Criteria for "high priority chemical of high concern for children," include one or more (WA Children's Safe Products Act, Sec. 4)||
|Criteria for "priority chemical", include one or more (ME Act to Protect Children's Health and the Environment from Toxic Chemicals in Toys and Children's Products, Sec. 1694)||
|Criteria for "priority chemical", include one or more of shaded cells (MN HF250 Committee Engrossment, Sec. 3, 2009)||
 EPA, 2008. Child-specific exposure factors handbook. Available at: http://cfpub.epa.gov/ncea/cfm/recordisplay.cfm?deid=199243#Download
The function of a chemical in a specific application provides important information when considering alternatives. A chemical that is used to modify the properties of a material into which it is being incorporated must be substituted either with another chemical that accomplishes the same function or another material that does not require modification for that specific property.
Individual chemicals may be used for a multitude of purposes, including to:
Other categories of functional use for chemicals of concern include:
Therefore it is important to determine the full suite of functions for the chemical of concern. The scope of the alternatives assessment process may be limited (for example, due to agency resource restrictions or because the goal of the project is narrowly defined). In that case, the identification of the function of the chemical of concern can be focused on the priority use (see the next section for more).
The function of the chemical of concern is related to the technical/performance requirements of its use. Sources of information on these may include direct communication with current users of the chemical of concern, industry trade associations (most of which can be accessed on the internet), and scientific and trade/industry literature or journals. The Massachusetts Toxics Use Reduction Institute (TURI) maintains a technical research library of pollution prevention and chemical alternatives resources and is just one example of a powerful resource for supporting this part of the process.
Uses of chemicals range from manufacturing processes to services to consumer products. Alternatives assessors should identify the suite of uses for the chemical of concern. These may include use in manufacturing operations (e.g., chemical production) and non-manufacturing operations (e.g., services such as dry-cleaning), as well as incorporation in consumer and industrial products.
Several governmental sources on chemical uses are available. The National Library of Medicine (NLM) maintains use information on many chemicals in its Hazardous Substances Database (HSDB). Several European countries have also investigated chemicals in products. The Danish Environmental Protection Agency has pulled products from shelves and analyzed them for a wide range of chemicals as part of their Survey of Chemical Substances in Consumer Products Program.
Links to a number of these European reports and the HSDB can be found in the Data Sources for Chemical Uses in Products section in the Resources section of this archive.
Furthermore, several companies provide information on chemicals reported in Material Data Safety Sheets (MSDSs) for a fee. Similar information is also provided by NLM's Household Products Database. Non-governmental organizations such as the Environmental Working Group have created databases based upon chemicals listed in product labels.
Caution should be used when referring to some of these sources since they are based upon information which has not been verified through chemical analysis. MSDSs and product labels can be inaccurate and/or incomplete. For example, the amount of chemicals listed in a product's MSDS may be higher than the actual concentration due to legal concerns. In addition, product labels may not list all of the chemical ingredients. Labels, however, are improving as consumers demand more information on the chemicals in the products they buy. Many of these sources provide an indication of where chemicals may be found but are not recommended as a sole source of data.
The following information should be gathered when identifying the various uses of a specific chemical.
Information may be gathered from the literature (both published and on-line sources) and experts. The sources of information should be clearly documented to maintain transparency within the process. As part of use identification, researchers may choose to contact and interview representatives from manufacturers, trade associations and customers who use the chemical or its derivatives.
Class of Chemical
Each ingredient in a product formulation has a specific function. The functional class is typically related to chemical and physical properties. By comparing the hazard profiles of chemicals within a functional class, the chemicals with lower hazard profiles can be preferentially selected. This is the basic approach taken by EPA's Design for the Environment Program (DfE), which works with companies to screen product ingredients, identify chemicals of concern and identify and promote use of safer substitutes.
EPA's DfE, however, requires full disclosure of all chemicals in products while maintaining confidential business information. Without this level of detail, the selection of viable safer alternatives is more difficult, and there is an increased risk in the selection of any alternative. Where possible, analysts should work with businesses to obtain as much information as possible on chemical use in products although it is likely that many may not be able to honor confidential business concerns.
Functional class should not be confused with chemical class. For example, within the solvent functional class, many different chemical classes may be represented, including: halogenated organics (e.g., perchloroethylene, trichloroethylene, and ether) , alcohols (e.g.,ethanol, methanol, and phenol), esters (e.g., ethyl acetate, and methyl acetate), ethylene glycol ethers (EGEs) and propylene glycol ethers (PGEs). While chemicals within a given class may have similar hazard properties, there will often be significant differences in potential toxicity to human health and the environment between the chemical classes that serve a particular function.
For some functional classes and some endpoints, however, there may be little difference in potential toxicity among members because of the function that they perform. For example, surfactants typically demonstrate aquatic toxicity because they are, by definition, surface-active. In such cases, the entire functional class - or the underlying functionality - could be the focus of research into the development of safer alternatives.
In some cases the uses are the defining element of a state's alternatives assessment activities (i.e., in the States of Washington and Maine the legislatures required that a process be developed to assess alternatives to high priority chemicals used in children's products). In other cases, such as in the Commonwealth of Massachusetts, the chemicals were prioritized prior to determining which uses were of high priority.
Each chemical has a variety of uses associated with it. These uses range from manufacturing process chemicals to services to consumer products. For each chemical of concern, the range of associated uses may be wide and varied. Therefore it is usually necessary to narrow the scope to evaluate uses that are a priority. Chemical uses can be prioritized using the following criteria:
Use in manufacturing and businesses: Total quantity of chemical used in manufacturing and business operations in the state
Use in consumer products: Total quantity of chemical used in products sold in the state.
This section provides guidance on methods for identifying potentially feasible and safer alternatives to the chemicals of concern. Existing and emerging alternatives for each of the high priority uses of a chemical of concern need to be identified. The alternatives may include:
Once a suite of alternatives has been identified, it is often necessary to prioritize which will be focused on for additional research in the assessment process. For state and local programs, limited resources are often the defining factor in determining how extensive an alternatives assessment can be, and focusing the analysis on the most promising alternatives is one of the most effective ways to make best use of those limited resources.
The first step in the identification of potentially feasible safer alternatives is to determine the appropriate industry or application specific performance requirements for each use. The European Chemicals Agency (ECHA) provides guidance on this step, referring to the functional requirements of the substance. As called out by ECHA: Examples of functional requirements may include:
Each alternative’s ability to satisfy the performance criteria needs to be then determined. Sources of information may include direct communication with current users of the chemical of concern, industry trade associations (most of which can be accessed on the internet), and scientific and trade/industry literature or journals. The Massachusetts Toxics Use Reduction Institute maintains a technical research library of pollution prevention and chemical alternatives resources, and is one example of a powerful source of research information for this part of the process.
Identifying Chemical Alternatives
When looking for chemical alternatives for a specific application/use, it is best to begin with industry literature about what is currently being used in the market. From there you can usually identify specific companies that are using alternatives. These companies are often good resources for identifying other alternatives that they may have tried or have heard of. From there, you can identify the types of chemicals that the list of alternatives represent and work with a chemist to identify analogues to that chemical (i.e., chemicals with similar molecular structures that may exhibit similar functionality).
A search of recent scientific literature may also lead to discoveries of chemicals that are being researched for the application, or for similar applications that have the same or similar performance requirements. There may be new formulations that are currently being studied. An alternative may not currently be a proven substitute for the chemical of concern, but may show promise for the near future. You may choose to list this as an emerging chemical alternative that could be reevaluated in subsequent updates of the alternatives assessment, if that is part of the scope of your project.
Information on chemicals used in articles (i.e., products for use by other industries or consumer products) can be difficult to find. This kind of information may be derived from legal requirements for information disclosure, information management systems that have been created by the private sector, or the Globally Harmonized System for Classification and Labeling of Chemicals (GHS), to name a few. In the absence of an internationally standardized approach to information on chemicals in articles, some jurisdictions have created information disclosure requirements. As presented in the report "Toxic Substances in Articles: The Need for Information" (Massey, et. al., 2008) prepared for the Nordic Council of Ministers, the following sources of information may provide the required data to assess the use of chemicals in articles:
Identifying Material Substitutes
A similar process should be followed for material substitutes (i.e., looking first to industry resources, followed by review of current scientific and trade literature). The major difference is that with material substitutions you should also be considering the availability of materials that eliminate the need for the functionality provided by the chemical of concern. For example, when looking for alternatives to phthalate plasticizers in resilient flooring applications, look for materials that do not need to be softened to provide the required characteristics (as is the case for rigid plastics like PVC).
Identifying Appropriate Process Changes
The opportunity to modify a process to eliminate the need for a chemical of concern is an option that is often overlooked. In Massachusetts, companies considerprocess changes as one of six defined methods for reducing their use of toxic chemicals. The first step these companies take is to ask themselves why they need the chemical in the first place. In the case of solvents, sometimes the chemical is used to clean parts between process steps. In those cases, changing process steps upstream can eliminate the need for that additional cleaning step. In fact, companies often discover that they are conducting a process step because it is a legacy of how they used to manufacture their products. Examining processes with a fresh set of eyes, and employing sound engineering judgment, can often lead to new opportunities to eliminate the use of toxic chemicals. In an alternatives assessment , these same questions and judgments can be employed to identify potential alternatives to chemicals of concern.
As noted above, beginning the exploration for process alternatives with a survey of industry practices and discussions with industry experts is important. A review of recent scientific and trade journals may also lead to the identification of emerging technology options that may represent viable alternatives to the use of the chemical of concern. In the case of emerging technologies, it may be appropriate to conduct further investigation into them depending upon the goals and timeline of the project.
The purpose of the initial screening effort is to eliminate from further study any chemical alternatives that would pose a high risk to the environment or human health. All identified chemical alternatives can be screened. If an alternative is persistent, bioaccumulative, and toxic, particularly carcinogenic, it can be eliminated from further consideration as an appropriate alternative. If there is no data available to address the criteria, the chemical should not be screened out based on that parameter. The goal is to identify a list of alternatives for further evaluation that is achievable in a reasonable amount of time.
The following sections present possible criteria to use for pre-screening alternatives.
You will find information sources to help conduct the alternatives pre-screening in the Resources section.
The US EPA in its Pollution Prevention Framework1 references it’s PBT Profiler software for levels of concern for chemicals that are persistent, bioaccumulative or toxic (PBT).The PBT Profiler can be run using the CAS number of each ingredient for each alternative. If a CAS number is not found by the PBT profiler, the chemical can be checked to see if it is inorganic or a mixture (PBT Profiler does not handle those substances); in some instances the chemical structure can be drawn and then run through the software. If a chemical alternative exceeds the criteria for any two of the PBT categories, it can
be screened out from further assessment.
a. Persistence: The US EPA PBT Profiler defines very persistent chemicals in terms of their half-life in specific media, as follows:
|Environmental Medium||Half-Life (1)|
|Water||> 180 days|
|Soil||> 180 days|
|Air||> 2 days|
|Sediment||> 180 days|
<p>b. Bioaccumulation: The PBT Profiler defines a chemical as very bioaccumulative if it has a bio-concentration factor (BCF) (2) greater than 5,000 (or log Kow greater than 5).
c. Aquatic Toxicity: According to the PBT Profiler, chronic aquatic toxicity values that are less than 0.1 mg/L indicate that a chemical is of high concern. The parameter used to evaluate for freshwater fish species toxicity is based on 30-day exposure duration, with the endpoint for evaluation expressed in ChV (mg/l) (3). Toxicity data for other aquatic species are not included in this initial screening criterion. In many cases data for aquatic toxicity is not available. In this case, the chemical cannot be screened out based on toxicity, and can only be screened out as a PBT if the criteria for P and B are exceeded.
If any one of the environmental media half lives is exceeded, the chemical can be considered to be persistent. The “persistent” classification for half-life in air is included since no “very persistent” criteria is established within the PBT Profiler.
A chemical can be screened out if it is classified under one of the following classifications:
The Massachusetts Toxics Use Reduction Institute uses the TUR Science Advisory Board’s list of More Hazardous Chemicals as an additional pre-screening list for its alternatives assessment process(below). In this list, “hazard” includes inherent toxicity, potential for exposure through dispersal in the work place (based on the physico-chemical properties of the chemicals, e.g., vapor pressure) and indicators of safety of use (e.g., flammability). Potential for exposure and indicators of safety do not include site-specific conditions.
The following table provides the list of Massachusetts More Hazardous Chemicals and their associated CAS numbers:
|Chemical Name||CAS Number|
|Chromium compounds (+6)||NA|
|Methylene bisphenyl isocyanate||101-68-8|
|Selenium and selenium compounds||7782-49-2 (elemental)|
|Sulfuric acid (fuming)||7664-93-9|
|Toluene diisocyanate (mixed isomers)||26471-62-5|
Other lists may provide an appropriate basis for pre-screening. The SIN list previously mentioned is an example of one such list.
The purpose of the prioritization effort is to focus assessments on the most feasible alternatives for a particular use. The following criteria can be considered:
Additionally, if the initial alternatives screening identifies a substance that exceeds the “median” level of concern for PBT as defined by the PBT Profiler, this can be noted and considered along with the above criteria.
Understanding and quantifying, to the extent possible, the functional and performance characteristics of the chemical of concern is a necessary first step in identifying technically feasible alternatives. These technical criteria must be specific to the use of the chemical/material, and may include items such as maintenance and durability as well as specific performance requirements for the process or product in which the chemical of concern is being used. The potential for future performance enhancements as a result of technical innovations should also be considered at this stage.
The best source of information on performance criteria for a chemical of concern in a specific application is technical experts from industries engaged in the manufacture or operation associated with that application. While there may be specific proprietary strategies used by a particular company to achieve the performance needs of their products, company experts are often quite willing to share their knowledge about the technical specifications that must be achieved for a product to be acceptable to their customers.
Other sources include academic researchers in the associated field, and scientific or trade literature that is often accessible on the internet.
This step in an alternatives assessment requires more knowledge of the engineering associated with the use of the chemical of concern.
The function of a chemical in a specific application provides important information when considering alternatives. A chemical that is used to modify the properties of a material into which it is being incorporated must be substituted either with another chemical that accomplishes the same function or another material that does not require modification for that specific property.
Individual chemicals may be used for a multitude of purposes, including to:
When evaluating the availability of viable safer alternatives to the use of phthalates (specifically DEHP) in resilient flooring applications the Massachusetts Toxics Use Reduction Institute considered the functional properties that DEHP exhibited and the identified specific performance considerations necessary to facilitate adoption of an alternatives plasticizer.
The following key performance criteria were determined to be important when substituting plasticizers in resilient flooring operations:
As state agencies, we are often tasked with considering the economic competitiveness of the companies we impact through our policies. Therefore, it is advisable to limit our investigations for safer alterantives to chemicals, materials or processes that are not just theoretical but commercially available.
Factors that states may consider relative to the availability of potentially viable and safer alternatives include:
Some safer alternatives may not be adopted by the industry using the chemical of concern because it is cost prohibitive - either from a chemical or capital equipment perspective. This is a situation that is best to be avoided, as the goal of the alternatives assessment is to identify feasible safer alternatives that can protect human and environmental health and safety while maintaining the economic viability of the manufacturing base in our states. The long-term costs of replacing or eliminating a toxic chemical can often yield a high return on investment (ROI) when the true and full costs of chemical use and management are considered. Indeed, in the case of drop-in replacements, the payback can be immediate .
Therefore it is important to clearly define the current costs associated with the alternative. Sources of information on costs associated with the chemicals include the chemical manufacturers themselves, and may also include industry users. The costs associated with required capital expenditures (i.e., process modifications required to allow processing of the new chemical in the application being evaluated) are more difficult to estimate, particularly if the alternative is not currently being used by industry for this or a similar application. In this case researchers must include process engineers in the conversation to more fully understand the cost implications, from a processing perspective, on the need for new or modified equipment if the alternative is adopted. Often, a less toxic chemical or product may have higher pound-for-pound purchase price, but will cost less over its lifetime. For example, a non-toxic alternative to a toxic product costs less to transport, store, handle, permit, and discard. It also often means less training for staff, and lower probability of an accident involving a toxic or hazardous material.
The potential for future cost reductions (e.g., economies of scale due to higher volume production) should be considered in this process as well. If available, other significant costs such as storage and handling costs, disposal costs, training costs etc should be determined in making this comparison.
When evaluating the cost of substituting the use of a hazardous chemical in consumer products, the essential inquiry is the cost of the alternative to the consumer. Is the alternative affordable? This may be a level of economic evaluation that requires input from state economic and commerce experts. As a starting point, a comparison of purchase price of the product containing the hazardous chemical to the purchase price of the identified alternatives must be made.
State laws restricting the use of chemicals in products may require a demonstration that alternatives are available at comparable cost. For example, Maine's law on Toxic Chemicals in Consumer Products authorizes a ban the sale of a children's product containing a priority chemical if the Board of Environmental Protection finds that one or more safer alternatives are available at a comparable cost. See Maine Revised Statutes, Title 38, section 1696. This phraseology, if narrowly interpreted to restrict the inquiry to a straightforward comparison of relative purchase price, could frustrate the purpose of state chemical safety laws by precluding a shift to safer alternatives that, while costing substantially more on a per unit basis, lead to product costs that are still considered to be affordable to consumers.
The Maine Department of Environmental Protection, in draft rules implementing that state's law on Toxic Chemicals in Children's Products, proposes to consider the affordability of alternatives as demonstrated by their availability in the marketplace and sales volumes. The rule authorizes the department to presume that an alternative is available at comparable cost if the alternative is sold in and in wide use in the United States.
Tools can facilitate estimation of true costs, including direct labor and materials, manufacturing overhead, and administrative overhead, along with non-product output (waste, emissions, expired chemicals, etc.), water and energy inputs, air treatment and ventilation, waste management (testing, handling, handling, etc.), other regulatory compliance,and product takeback (for some companies).
Hazards associated with the alternatives are determined differently depending on if the alternative is a chemical or a material. Often we do not have full information about the inherent hazards associated with alternative chemicals. The potential life cycle impacts associated with alternatives might be even less fully available. Focusing on the key criteria established for the chemical of concern for the specific application being investigated can help in limiting the amount of uncertainty associated with the hazards of an alternative. However it is more common that there will be gaps in the available data for alternatives. Managing this situation is addressed at a later stage in the process, addressed in the Research Alternatives section.
For this stage of the process, use of known hazards of the alternative helps in determining which alternatives will be prioritized for further study.
In order to compare the potential chemical alternatives to the chemical of concern, one must go through a similar process to what is done when developing the chemical hazard and exposure profile of the chemical of concern itself.
When looking at a material alternative, it is more appropriate to look at the life cycle implications of the alternative materials. For instance, these may include the embedded energy associated with the material, the end of life possibilities for the material, or the sourcing of raw feedstocks required to manufacture the material. This can be a very detailed process, depending on the scope of the project. Rather than looking throughout the entire life cycle and conducting a comprehensive analysis, it is more common to identify the key criteria associated with the material for which alternatives are being sought, and focus on those.
As an example, for the resilient flooring assessment project conducted by the Massachusetts Toxics Use Reduction Institute, materials were assessed relative to their ability to be recycled at the end of life, and the use of renewable feedstocks in their manufacture. This focus on aspects of the life cycle of a material provides the opportunity for a more qualitative analysis, rather than quantitative. By using this approach, the process of comparing materials will be expedited.
Occasionally it is possible to identify an entirely different approach to the creation of the function or product associated with the chemical of concern. For instance, the use or perchloroethylene in dry cleaning can be replaced with a new process that does not utilize any solvent to accomplish the cleaning. This "wet cleaning" alternative requires the use of new and additional equipment to accomplish the performance required by customers of dry cleaning establishments, but it is able to do this will only aqueous-based chemicals and equipment, thereby virtually eliminating the environmental and human health hazards associated with the use of perc (or other solvents) in dry cleaning.
To identify process alternatives, it is best to review literature for the industry, and discuss alternatives with industry experts.
As our world becomes an increasingly global marketplace, taking into account the impact of international marketability on a product is essential to the sustained economic viability for most industry sectors. States may choose to consider the global market when developing policy and technical support for alternatives assessments. Information about pending or existing global restrictions that might materially affect the ability of an industry to market its products internationally are of particular import.
For example, in 2006 the European Union promulgated the Restriction on Hazardous Substances, or RoHS, Directive. RoHS precluded the use of six substance in electrical and electronic equipment sold or distributed in the EU (with some exceptions). The electronics industry had to adjust to these restrictions if it wanted to maintain market share in the European market. Those companies that had identified and adopted alternatives to the chemicals of concern identified by RoHS were at a competitive advantage. Because the six chemicals (lead, mercury, cadmium, hexavalent chromium, polybrominated ethers and prolybrominated diphenyl ethers) were identified as chemicals of concern, the likelihood was that at least some of the alternatives adopted would indeed be safer. However, without the specific mandate to identify safer alternatives, some of the alternatives adopted could indeed have been of greater concern from an EH&S perspective.
In some instances multiple similar alternatives exist for a particular use. In this case one alternative that is representative of that type may be chosen for further study in order to limit the resources necessary to conduct a complete safer alternatives assessment
The process of comparing alternatives includes conducting more in-depth research into the alternatives that were selected for evaluation in the previous stage, and comparing each of them to the chemical of concern from technical/performance, economic, and environmental and human health and safety perspectives.
For each of the high priority uses of the chemical of concern and for each identified priority alternative, researchers can compile and assess data for the following assessment categories.
Some of the assessment data will be specific for each use of the chemical and its alternatives, and some assessment data will be the same for various uses of the chemical and its alternatives.
When evaluating environmental and human health data as part of its assessment of alternatives to five chemicals, the Massachusetts Toxics Use Reduction Institute used the following protocol:
Other criteria may be more appropriate for your assessment process. For instance, it may be beneficial to create guidance for use of data derived from other sources (such as studies conducted by or for industry or NGOs). In addition, limiting modeling methods to those approved by the US EPA may be too inflexible and strict.
Industry-specific performance requirements that must be met for each feasible alternative are important data to obtain when conducting an alternatives assessment. A primary source of this information is industry/user experience with the chemicals and their substitutes. Contacting and interviewing representatives from manufacturers, trade associations, and customers who use the chemical or its derivatives is often the best way to obtain this information. The anecdotal nature of these kinds of conversations can be informative, if not scientific. It provides good insight with which to direct further research.
Additionally, readily available information on key life cycle considerations that may affect the feasibility of the alternative need to be considered. Key life cycle considerations that should be considered when comparing alternative materials might include such issues as waste disposal limitations, energy usage required during manufacture, and impact on product recyclability or reuse potential. Researchers and stakeholders may have suggestions on other life cycle implications associated with the use of the material or chemical being considered. Data on product use and disposal implications may also be informative.
The primary goal of assessing the alternatives is to determine if the alternative is not only feasible, but indeed safer than the chemical of concern.
The environmental, technical, financial and human health data obtained for each alternative must be organized and evaluated to assess its feasibility as a substitute for the chemical of concern for the specific use/application being considered. User experience and pertinent and reliable life cycle considerations can be included in this evaluation.
Key elements of the assessment process include questions about how adoption of the alternative might impact the overall system of chemical/product use. . These can include:
An Iterative Process
Another important element of this process is acknowledging that today's assessment outcome will likely not be valid indefinitely. New scientific data is developed all the time, providing new insight into just how "safe" a chemical or material is. In addition, the performance criteria for a specific application may change as the technology innovates and improves. And, economic indicators tend to be volatile. Therefore, any assessment should be considered to be valid only for a limited time period, depending on the state of the science and the likelihood of innovations in technology. States could consider developing a time limit on the applicability of the results of an assessment and call for feedback about and updating of assessments . For instance, an assessment of alternatives to brominated flame retardants used in computer casings conducted by the State of Maine in 2008 may not be valid or applicable to an assessment of alternatives to brominated flame retardants used in TV casings in the State of Oregon studied in 2011.
A chemical is any element, chemical compound or mixture of elements and/or compounds. Chemicals are the constituents of materials. A chemical “mixture,” also known as a chemical “preparation,” includes multiple chemicals.
A chemical alternative represents the simplest alternatives assessment case, where the chemical being studied can be directly substituted with another chemical that satisfies the functional requirements for the particular use. In this instance, the evaluation can be relatively straightforward, and information associated with the assessment criteria can be obtained, verified, and presented in a way that maximizes usefulness to those looking for tools to help in designing products using alternative chemicals.
Often the chemicals being evaluated are used in formulations of multiple chemicals. In this case, each of the chemical constituents of the mixture needs to be considered in the assessment in a manner similar to that used for individual chemicals. Environmental and human health information about each of the chemical constituents needs to be gathered, along with performance and cost information for the overall formulation. If information on the mixture is available from a manufacturer’s MSDS, that information may be used for available parameters.
In its study of five chemicals, the Massachusetts TURI focused on the primary constituents of each formulation being evaluated. Specifically, constituents present in amounts exceeding 1 percent were included in the review. When formulation breakdowns were presented on associated MSDSs with ranges, TURI assumed the average weight percentage of the range. As the environmenta, health, and safety (EH&S) factors associated with the constituents of a mixture were determined, their relative significance to the overall EH&S characteristic of the mixture were determined based on the weight percent within the mixture.
The actual approach to evaluating the EH&S impact of a mixture will differ depending on whether the chemicals in the mixture cause similar or different health effects. If the health effects are similar (e.g., two constituents are CNS depressants), their weight percentages could be added and the overall impacts of the combined chemicals assessed. If the health effects are different (e.g., one chemical is a CNS depressant while another is a respiratory irritant), the effects could be evaluated separately based on the weight percentages of each constituent*.
In the event that data is available for a chemical product (i.e., the mixture of chemicals) that information should be used directly. The assessor could develop a process and guidance on how to manage data associated with mixtures.
A material is defined as the basic matter (i.e., metal, wood, plastic, fiber) from which the whole or the greater part of something physical (such as a machine, tool, building, fabric) is made. Human-made materials like petroleum-based plastics are synthesized from chemicals.
In some cases the chemical being studied may be used to impart particular qualities in a material. For instance, DEHP is used in PVC to make this otherwise rigid plastic flexible. Rather than find other ways to make the material (PVC) less rigid, there may be opportunities to find alternative materials that are inherently more flexible, therefore, bypassing the need for the particular chemical additive.
When evaluating material alternatives, performance and cost considerations are important. However, the impact of a material on the environment or human health may not be as easily assessed as it can be for chemical substitutes. For materials, life cycle considerations may become more important. For its assessments, TURI examined both EH&S impacts when appropriate and at life cycle issues that, based on its research, appeared to be of most significance relative to the material being replaced.
Process alternatives are those that employ a different technology, process or approach to achieve the objective or function of the original product or process. For example, when considering alternatives to perchloroethylene in vapor degreasing, one approach might be to change the upstream process to use lubricants that either do not require cleaning, or are easier to remove using water-based surfactants. The feasibility of this type of alternative can be assessed, but it can be difficult to compare the EH&S impacts quantitatively.
The selection of preferred alternatives to the chemicals of concern is a process that is linked to the goals of your organization and your project.
For instance, state programs may wish to make a determination about whether or not the alternative is indeed safer than the chemical of concern. This was the approach taken by the State of Washington when it assessed alternatives to decabromodiphenyl ether for use in computer and television housings.
Alternatively, it may only be necessary to present the information obtained in a way that allows stakeholders to make their own determination. This was the approach of the Toxics Use Reduction Institute (TURI) when it conducted its assessment of five chemicals (i.e., lead, formaldehyde, hexavalent chromium, di (2-ethylhexyl) phthalate, and perchloroethylene) at the request of the Massachusetts legislature.
The German Federal Environmental Agency, in collaboration with Okopol, created the guidance document "Guide on sustainable chemicals: A decision tool for substance manufacturers, formulators and end users of chemicals", which can be accessed at http://www.umweltbundesamt.de/uba-info-medien-e/4169.html. This guidance takes a positive approach, looking for safer, sustainable chemicals rather than identifying the "bad actor" chemicals, and can be helpful as a model for selecting the preferred alternatives.
The relative weight your organization assigns to the evaluation criteria will also affect your selection. Companies looking to reformulate products consider impacts on performance and costs more heavily than government agencies looking to reduce the use of specific toxic chemicals.
The level of detail that a state program may choose to provide in its assessment results will likely depend upon the goal and scope of the assessment process. The sections below present examples of AA results presentations from various state programs.
Examples of Alternatives Assessment Results Presentation
Massachusetts Five Chemicals Alternatives Assessment Study
The Massachusetts Toxics Use Reduction Institute was asked to determine if there are safer alternatives to lead, formaldehyde, hexavalent chromium, di (2-ethylhexyl) phthalate (DEHP), and perchloroethylene (selected by the Massachusetts Legislature). The Institute was not asked to make a policy recommendation. Therefore, the Institute decided that the best way to make the results of the study readily accessible to legislators, while avoiding the suggestion of blanket recommendations with respect to the chemicals that might not be feasible for specific applications, would be to present the results in tabular form. The following is an example of one of the tables from the study - this one referring to plasticizer alternatives to DEHP used in medical devices.
The table lists the key criteria for comparison, categorized into technical/performance, cost, environmental and human health criteria. The values for specific criterion for the reference chemical (i.e., chemical of high concern) was listed, and the priority alternatives that were evaluated were compared qualitatively. If the data associated with a specific chemical indicated more favorable results than that of the reference chemical (in this case, DEHP), a + symbol was put in the appropriate cell. Similarly, if the data indicated less favorable results than DEHP a - symbol was used. If the results indicated no significant difference, either better or worse, a = symbol was used. Finally, if no data, or insufficient data to make a determination was available, a ? was used. For specific applications, or for specific criteria, there was occasionally a need to provide additional information. For instance, you will note that plasticizer loss was a critical performance criteria for medical device applications, but that it was also an issue if the loss occurred during manufacturing or during use. If the loss of an alternative plasticizer differed from that of DEHP, an M or U was used to indicate at what point that loss difference can occur.
Washington State’s Department of Ecology and Department of Health "Alternatives to Deca-BDE in Televisions and Computers and Residential Upholstered Furniture"
The conclusions of the assessment of safer alternatives to deca-BDE in television and computer enclosures was summarized as follows:
"RDP (resorcinol bis (diphenyl phosphate)) is a safer and technically feasible alternative to Deca-BDE. RDP’s low environmental persistence, moderate bioaccumulation potential and moderate toxicity make it a safer alternative than Deca-BDE for use in electronic enclosures.
RDP provides comparable fire safety (UL94 V-0) to Deca-BDE for plastics used in electronic enclosures. The use of RDP in electronic enclosures requires the use of a different plastic than what is typically used with Deca-BDE. However, this switch in plastic is anticipated to be feasible and cost effective.
The Fire Safety Committee and the State Fire Marshal found that RDP will meet applicable fire safety standards for televisions and computers.
Two other phosphate flame retardants were considered by Ecology and DOH as potential safer alternatives to Deca-BDE. These alternatives are BAPP and TPP. BAPP was identified initially as a feasible alternative to Deca-BDE; however one of its breakdown products, bisphenol A, has been identified as an endocrine disruptor in animal studies. Therefore the agencies determined that BAPP may not be a safer alternative to Deca-BDE.. TPP was identified is a feasible alternative; however concerns about its aquatic toxicity preclude it from being considered as a safer alternative at this time."
Rather than present the results in one tabular format, the Washington Departments of Ecology and Public Health provided a wealth of data in appendices and a narrative conclusion based on their research.
Clean Production Action's Green Screen
At the foundation of the Green Screen method are the Principles of Green Chemistry and the work of the US Environmental Protection Agency’s (EPA’s) Design for Environment (DfE) program. The Green Screen addresses many of the principles of green chemistry through its focus on hazard reduction and does this by defining four benchmarks with each benchmark defining a progressively safer chemical. The figure to the right illustrates the various benchmarks associated with a Green Screen chemical comparison. When presenting results from this process, chemicals are identified by the color that relates to the appropriate benchmark.
US EPA's Design for Environment (DfE) Program
DfE's Alternatives Assessment Program is designed to help industries choose safer chemicals for specific applications. The DfE program brings together environmental organizations, industry leaders, academics, and others to evaluate the environmental and health impacts of potential alternatives to problematic chemicals. The outcome of a DfE Alternatives Assessments Partnership provides industry with the information they need to choose safer chemicals, as well as avoid unintended consequences of switching to a poorly understood substitute. DfE presents its results qualitatively, by endpoint. Below is an example of a DfE assessment of alternatives for a specific application.
State programs may have an obligation to find ways to work with stakeholders to promote the adoption of the safer alternatives.
This could be done through directives (i.e., mandating elimination of the chemical of concern for specific uses with a requirement for the user to demonstrate that their alternative is in fact safer). An example of this is the State of Maine's Act To Protect Children's Health and the Environment from Toxic Chemicals in Toys and Children's Products, which requires manufactures and distributors of children's products to provide an assessment of the availability, cost, feasibility and performance, including potential for harm to human health and the environment, of alternatives to the priority chemical and the reason the priority chemical is used in the manufacture of the children's product in lieu of identified alternatives. If there are several available safer alternatives to a priority chemical, the State may prohibit the sale of children's products that do not contain the safer alternative that is least toxic to human health or least harmful to the environment.
Other mechanisms to promote adoption of safer alternatives that states should consider include:
Quite often the use of the chemical of concern is associated with a long history of technical improvements in manufacturing and product design that revolve around its presence in the application or product in which it is used. A common barrier to adopting safer alternatives is the lack of long-term performance and product quality data associated with the use of the safer alternatives that have been identified. State programs can assist companies in overcoming this significant barrier by facilitating research into the performance and product quality implications of adopting the safer alternatives.
Mechanisms that states may want to consider include:
An element of the alternatives assessment process that the participants at the September 2008 meeting agreed should be considered throughout the assessment is the engagement of stakeholders. When working with stakeholders, regardless of where in the alternatives assessment process you are, you should consider:
- Who the essential stakeholders are;
- When they should be communicated and/or collaborated with;
- How frequently this should occur.
Stakeholder engagement should be an iterative process throughout the alternatives assessment process.
Three phases of the stakeholder engagement process are:
Things to consider:
The following summarizes key elements of preparing for the initial phase of stakeholder engagement.
1. Who is leading the stakeholder effort? A leader should be able to:
2. The team responsible for stakeholder engagement should include staff expert/s in content, policy, and communications and outreach. The team should discuss about how decisions will be made. Also, the team needs to be skillful about communicating, presenting material, and handling conflicts and challenges. Training and coaching may be a good idea before actually engaging stakeholders and the public.
3. Objectives and measuring success should be the focus of a team discussion early on to get clear about internal goals. Stakeholders will contribute their perspectives.
4. Controlling expectations
What will be accomplished and what will not be accomplished, who can make decisions and who is advising, mid-course corrections may be needed, damage control plans? These are important questions for the team to consider in their planning.
The stakeholder engagement team should prepare a list of stakeholders by addressing the following questions. Who has information that can help make the assessment more comprehensive and accurate? Who should be consulted about priority chemicals of concern? Who should be consulted about priority uses of chemicals of concern? What stakeholder representatives should be included (e.g., government, trade association, NGO, company, supply chain, consultant, and academic)
To refine To refine the team’s understanding of the stakeholder community, they should address these questions:
The team can begin to design its program by thinking about these questions:
Plan the Project
The stakeholder engagement team should address who, what, when, where, and how of what they propose to do as outlined below. This is how you will control the time and outcomes. With proposed actions, you can selectively adjust as you go to respond to on the ground realities without losing sight of the plan and goals.
Planning for meetings with stakeholders should address the unique needs of the situation. The following are some questions to consider:
To prepare the documents for stakeholders to reference consider:
To measure progress and correct the direction or participation or the process, consider:
The following pages provide various resources to use in developing and updating alternatives assessments and chemicals use policies.
General Guidance - additional resources providing guidance on the alternatives assessment process
Chemical Hazard Comparison Methods
Hazard Display Methods
Chemical CharacteristicsGeneral Toxicity Databases
Undesirable Materials and Products
Guidance on appropriate sources of data - Tracey J. Woodruff, Patrice Sutton and The Navigation Guide Work Group, An Evidence-Based Medicine Methodology To Bridge The Gap Between Clinical And Environmental Health Sciences, Health Affairs, 30, no.5 (2011):931-937, doi: 10.1377/hlthaff.2010.1219. Available at: http://content.healthaffairs.org/content/30/5/931.full.html
United States: Federal
States in the United States:
The EC also provides an Access database which contains all of the chemicals reviewed and enables one to separate out the chemicals into the categories identified above.
 Information on VCCEP can be found at: http://www.epa.gov/oppt/vccep/index.htm, accessed 11/17/2008.
 VCCEP chemicals are identified at: http://www.epa.gov/oppt/vccep/pubs/basic.htm#basic3, accessed 11/17/2008
 More information on EPA’s PBT program can be found at: http://www.epa.gov/pbt/index.htm, accessed 11/18/2008
 More information on EPA’s Priority PBTs can be found at: http://www.epa.gov/pbt/pubs/cheminfo.htm, accessed 11/18/2008
 More information on EPA’s EPCRA Program and TRI can be found at: http://www.epa.gov/triinter/triprogram/tri_program_fact_sheet.htm, accessed 11/18/2008
 Federal Register notice at: http://www.epa.gov/EPA-WASTE/1999/October/Day-29/f28169.htm, accessed 11/17/2008
 More information on EPA’s IRIS can be found at: http://cfpub.epa.gov/ncea/iris/index.cfm, accessed 11/18/2008
 The search criteria and chemicals can be found on the IRIS site at: http://www.epa.gov/ncea/iris/search_human.htm, accessed 11/18/2008
 More information on EPA’s Waste Minimization Program can be found at: http://www.epa.gov/osw/hazard/wastemin/index.htm, accessed 11/18/2008
 More information on these chemicals can be found at: http://www.epa.gov/osw/hazard/wastemin/priority.htm, accessed 11/18/2008
 More information on the NTP and its work can be found at: http://ntp.niehs.nih.gov/?objectid=720163C9-BDB7-CEBA-FE4B970B9E72BF54, accessed 11/18/2008
 NTP CERHR found at: http://cerhr.niehs.nih.gov/aboutCERHR/index.html, accessed 11/17/2008
 Information on the CEHR list can be found at: http://cerhr.niehs.nih.gov/chemicals/index.html, access 11/18/2008
 NTP RoC found at: http://ntp.niehs.nih.gov/?objectid=72016262-BDB7-CEBA-FA60E922B18C2540, accessed 11/17/2008
 More information on Prop 65 can be found at: http://www.oehha.org/prop65.html, accessed 11/17/2008
 The Prop 65 List can be found at: http://www.oehha.org/prop65/prop65_list/files/P65single091208.pdf, access 11/18/2008
 Ecology’s PBT program found at: http://www.ecy.wa.gov/programs/swfa/pbt/, accessed 11/17/2008
 The Multiyear CAP Schedule can be found at: http://www.ecy.wa.gov/biblio/0707016.html, accessed 11/18/2008
 More information on IARC can be found at: http://www.iarc.fr/, accessed 11/17/2008
 IARC Monographs found at: http://monographs.iarc.fr/ENG/Classification/Listagentsalphorder.pdf, accessed 11/17/2008
 More information on SVHCs can be found at: http://echa.europa.eu/consultations/authorisation/svhc/svhc_cons_en.asp, accessed 11/17/2008
 Governing Statement of the European Commission at: http://ec.europa.eu/atwork/synthesis/doc/governance_statement_en.pdf, accessed 11/20.2008
 More information on the EU Endocrine disruptors program can be found at: http://ec.europa.eu/environment/endocrine/documents/sec_2007_1635_en.htm, accessed 11/17/2008
 The database containing these endocrine disruptors can be found at: http://ec.europa.eu/environment/endocrine/strategy/substances_en.htm#priority_list, accessed 11/18,2008
 More information on EC PBTs can be found at: http://ecb.jrc.ec.europa.eu/esis/index.php?PGM=pbt, accessed 11/17/2008
 More information on ORATS can be found at: http://ecb.jrc.ec.europa.eu/esis/index.php?PGM=ora, accessed 11/18/2008
 More information on OSPAR can be found at: http://www.ospar.org/content/content.asp?menu=00010100000000_000000_000000, accessed 11/18/2008
 More information on the OSPAR Chemicals of Possible Concern can be found at: http://www.ospar.org/content/content.asp?menu=00950304450000_000000_000000, accessed 11/18/2008
 More information on OSPAR Chemicals for Priority Action can be found at: http://www.ospar.org/content/content.asp?menu=00940304440000_000000_000000, accessed 11/18.2008
 For more information on CEPA see: http://www.ec.gc.ca/CEPARegistry/gene_info/, accessed 11/18/2008
 CEPA found at: http://www.ec.gc.ca/CEPARegistry/subs_list/dsl/dslsearch.cfm, accessed 11/17/2008
 Grandjean, P & PJ Landrigan, Developmental neurotoxicity of industrial chemicals, The Lancet, 2006, available at: http://reach-compliance.eu/english/documents/studies/neurotoxity/PGrandjean-PjLandrigan.pdf, accessed 11/20/2008
 The Lancet at: http://www.thelancet.com/lancet-about, accessed 11/20/2008
Ingredients in Products or Product Categories
Chemicals of high concern and their alternatives may be found in a variety of applications. Information about chemical use in specific applications can be gleaned from a variety of sources.
Some information on chemicals found in products can be found on US Government websites. The information available in some of these resources is limited and out-of-date and care should be taken with their use. Specific concerns, which should be considered prior to their use, are identified in the description of each source.
The US EPA provides data on chemicals in products as part of their Inventory Update Reporting (IUR) regulatory requirements. Due to claims of confidential business information, the database only contains information on those products whose contents are not restricted, which limits it's completeness.
The US National Library of Medicine, part of the National Institute of Health, maintains several databases with information of interest to individuals conducting safer chemical alternative assessments. For the purposes of products, two sources in particular contain information
In 1989, the State of Massachusetts passed a law, the Toxics Use Reduction Act to encourage reduction in the amount of toxics used in products with the state. As part of this legislation, the Toxics Use Reduction Institute (TURI) was created to provide support to business to reduce toxics use. TURI provides information about toxics used in products collected during its activities in the Toxics Use Reduction data. The information can be viewed in various ways including 16 chemicals groups but is limited to the information collected.
With the increasing development of electronic message, companies have been formed which provide information on chemical content in products.
Chemicals Used in Occupational Settings/Processes
The U.S. EPA Drinking Water Program identified contaminants of concern in drinking water and established regulations to limit the concentrations of these chemicals.
State Government Activities
States are increasingly interested in utilizing alternatives assessment tools in their decision-making efforts as well as their technical assistance to industries using chemicals of concern.
The Toxics Use Reduction Program has created a decision-making document that explains the process used by the Science Advisory Board to determine if a chemical should be listed under the TURA law or if it should be designated as a high hazard substance.
April 2007 PBDE Chemical Action Plan
Washington State Alternatives to Deca-BDE in Televisions and Computers and Residential Upholstered Furniture
Federal Government Activities
The U.S. EPA's Design for the Environment program (DfE) has been conducting detailed alternatives assessments of chemicals in specific applications. Alternatives assessments have been done for the following chemicals:
Intergovernmental Forum on Chemical Safety - Substitution and Alternatives Case Studies, Examples and Tools developed by the Lowell Center for Sustainable Product Chemicals Policy and Science Initiative
Alternatives Assessment 103: Case Examples and Lessons Learned
There are numerous government agency efforts to assess alternatives to chemicals of concern. While some look broadly at comparing alternatives on the basis of their hazard traits, others look more closely at performance and application. This webinar will present three case studies of conducting alternatives assessments involving perchloroethylene in dry cleaning; bisphenol-a in thermal register tape; and deca-brominated diphenyl ether in electronics and textiles. They will discuss the challenges faced in conducting alternatives assessment and how these challenges were addressed by the agency.
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Alternatives Assessment 102: How Alternatives Assessment concepts are being and can be integrated into agency initiatives.
Several state and federal agencies are incorporating regulatory or non-regulatory efforts on alternatives assessment for informed substitution into their work. Yet most agencies have not been able to do so in a systematic way. The goal of this webinar is to better understand how alternatives assessment has and can be applied across agencies and what types of collaborations, tools, and support would be useful is supporting greater application of and cooperation around alternatives assessment.
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Alternatives Assessment 101: An Introduction to Alternatives Assessment for Informed Substitution
On January 31, 2012, Joel Tickner of the Lowell Center for Sustainable Production and Pam Eliason of the Massachusetts Toxics Use Reduction Institute presented a one-hour webinar that was an overview of the history of the movement towards use of the alternatives assessment process as a policy tool to promote informed substitution activities and the general overview of the alternatives assessment process itself.
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