Alternatives Assessment Wiki Archive

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 Readers, however, should remember that the content in this archive is not being updated and may contain out-of-date information and bad links.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.

Safer Alternatives Assessment

Define Goals and Scope

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: 

  • Is it possible to identify safer alternatives to a specific chemical of concern used in a specific product?
  • What tools can we implement to facilitate shifting our economy towards the use of safer chemicals?
  • Do safer alternatives exist for a chemical of concern such that we can justify banning or significantly restricting the use of that chemical?

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. 

  • If you are looking to determine the existence of safer alternatives for a specific chemical used in a particular application, the scope of your work may be limited to identifying the unique performance and technical requirements that the chemical of concern possesses, and finding an alternative that can satisfy those requirements while demonstrating less serious environmental and/or human health impacts
  • If your goal is to eliminate or significantly restrict the use of a chemical of concern, your scope will be more comprehensive, including a more thorough investigation of the various uses of the chemical of concern, the associated characteristics of the chemical for each use, identification of potential alternatives that could satisfy the performance criteria for the various uses, and a thorough assessment of the relative safety of the identified alternatives.

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:

  • The Massachusetts Toxics Use Reduction Institute (TURI) conducted an assessment of five chemicals that were selected by the State Legislature from a larger set of chemicals of concern originally identified by a coalition of advocacy groups. The original list represented concerns from a variety of perspectives – from occupational hazards to environmental releases to agricultural releases of toxic chemicals. The Legislature chose to demonstrate the viability of assessing the availability of safer alternatives to a subset of the chemicals of concern rather than create a ban of any of the specific chemicals.

  • The Legislatures in the States of Washington and Maine were concerned about the growing body of evidence of potential harm to human and environmental health from specific toxics found in products manufactured and/or used in their jurisdictions. These States were particularly concerned about the presence of toxic chemicals in children’s products. Prior to creating a ban of these chemicals from specific products, the Legislatures tasked their environmental agencies with assessing whether viable safer alternatives are available.

What's Next?

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.

Defining "Safer"

When considering the question about how to define the term "safer", there are various degrees of "safe" that might apply. Some examples include:

  • safe
  • safer
  • plausibly safer
  • incrementally better than

Example definitions of "safer alternative"

  • In accordance with An Act to Clarify Maine's Phaseout of Polybrominated Diphenyl Ethers, Public Laws 2009, chapter 610, "safer alternative" means a substitute process, product, material, chemical, strategy or any combination of these that:
    (1) When compared to the chemical to be replaced would reduce the potential for harm to human health or the environment or has not been shown to pose the same or greater potential for harm to human health or the environment as the chemical to be replaced;
    (2) Serves a functionally equivalent purpose that enables applicable fire safety standards, approvals and tests and relevant performance standards to be met;
    (3) Is commercially available on a national basis; and
    (4) Is not cost-prohibitive.

  • "Alternative that, when compared to the chemical of concern, would reduce the potential for harm to human health or the environment and that has not been shown to pose the same or greater potential for persistence, bioaccumulation, toxicity, and long-range environmental transport" (POPs—not Annex F)

Identify Chemicals of High Concern

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.

  • What is the chemical used for?
  • Is there a group or class of chemicals that are of concern, or is the concern limited to an individual chemical?
  • Is there sufficient scientific evidence for concern?
  • Is the chemical used in significant amounts with respect to its potential to impact human or environmental health to be a concern?
  • Who are the key stakeholders in the use of the chemical and of any potential alternatives?
  • Would adoption of alternative safer chemicals lead to an observable improvement in the health of the people and environment in the state?

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.


States like WA and ME are going through a process of:

  • Create a list of chemicals of high concern based on criteria like PBT, CMRs, etc. Typically the list of chemicals of high concern is derived from a list of authoritative lists. For an example of a list of lists, see the Red List of Lists developed by Clean Production Action and Healthy Building Network in the Resources section.
  • Prioritize the list based on exposure proxies such as production volume, presence in consumer products, etc. The SIN list described below is an example of a prioritized list of chemicals from the list of lists.


There are a number of guidance and tools that could be used by states to identify chemicals of concern. 


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.

Prioritize Chemicals for Assessment

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.

Washington State

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;
(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.

In Washington it was determined that lower priority could be given to chemicals that are: 
  • Preempted by Federal legislation (the Federal Toxics Substances Control Act, for example)
  • Not intentionally added to materials or components of children’s products. (e.g.,pesticides, pharmaceuticals, and degradation products)
  • Emerging chemicals of concern (i.e., those chemicals where toxicity testing data is still emerging).

Higher priority consideration could be based on one or more of the following criteria: 
  • Toxicity
  • Demonstrated presence in children’s products
  • Availability of a suitable test protocol
  • Exposure potential and amount of exposure
  • Age of children potentially exposed
  • Availability of safer alternatives
  • Amount of the chemical in commerce
  • Prevalence of the chemical in materials commonly used in children’s products, such as plastics or additives to cosmetics

Profile Chemical Hazard & Exposure

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.


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

  • Corrosivity
  • Flammability
  • Greenhouse gas potential
  • Ozone-depletion potential
  • Reactivity

Human Health Hazards

  • Acute toxicity
  • Carcinogenicity
  • Chronic toxicity
  • Developmental toxicity
  • Endocrine disruption
  • Eye damage/irritation
  • Mutagenicity
  • Neurotoxicity
  • Reproductive toxicity
  • Sensitization
  • Skin irritation

Environmental Hazards

  • Acute aquatic toxicity
  • Bioaccumulation
  • Persistence

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 


The following is a suggested hierarchy of validity for sources of information:

  • Peer-reviewed studies
  • Government-generated studies
  • Industry or advocacy group studies subject to Good Laboratory Practice guidelines
  • Models based on structure-activity relationships (SAR)
  • Industry or advocacy group studies not subject to Good Laboratory Practice guidelines
  • Read-across analyses

Exposure Characteristics

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[1] 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:

  • Production volume
  • Biomonitoring studies: presence of the chemical in human blood, including umbilical cord blood, breast milk, urine, or other bodily tissues or fluids
  • Sampling and analysis showing presence in household dust, indoor air, drinking water, or elsewhere in the indoor environment
  • Environmental monitoring of  fish, wildlife, or the ecosystems
  • Presence in a consumer product used or present in the home
  • Presence in children's products
  • Used in products resulting in potentially high exposure to workers or  pregnant or lactating women
  • Used in dispersive product applications

Exposure Proxy

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)  





[1] EPA, 2008. Child-specific exposure factors handbook. Available at:

Identify Function, Use, & Class

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:

  • Reduce surface tension (i.e., surfactants)
  • Dissolve materials (i.e., solvents)
  • Reduce water hardness (i.e., chelating agents) 
  • Provide or mask a scent (i.e., fragrances)

Other categories of functional use for chemicals of concern include: 

  • Additives
  • Antioxidants
  • Buffering Agents
  • Colorants
  • Emulsion Stabilizers
  • Film-Formers
  • Oxidizing Agents
  • Preservatives
  • Reducing Agents
  • Viscosity Controlling Agents

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.

  • Major suppliers of the chemical
  • Major derivatives, components, and/or end products that incorporate the chemical or use the chemical as a feedstock, and their manufacturers
  • Major distributors, retailers, or customers of end product
  • Functionality requirements of chemical or component or end-product (i.e., why is it used and what is it used for?)
  • Concerns of relevant stakeholders, including businesses, industry associations, environmental, public health and labor organizations

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.

Prioritize Uses for Further Evaluation

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:

  • Importance to the state conducting the assessment:
    • 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. 
  • Potential availability of alternatives (conduct a quick scan of available alternatives – are they still in the developmental stage or readily available commercially?)
  • Exposure potential (environmental, occupational, and public health). For example, what is the mobility of the chemical for a particular use? If the chemical is used in a product, is the user likely to be exposed to it?
  • Potential value to state businesses and citizens of the alternatives assessment results. In this case the preferences of the relevant stakeholders should be given priority.
  • Other criteria as appropriate, based on the goals of the project

Identify and Prioritize Alternatives

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:

  • Drop-in chemical substitutes
  • Material substitutes 
  • Changes to manufacturing operations 
  • Changes to component/product design 
  • Other technological solutions

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.

Identifying Alternatives

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: 

  • Critical substance properties related to the desired equivalent function 
  • Quality criteria 
  • Process and performance constraints 
  • Customer requirements
  • Legal requirements for technical acceptability

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:

  • California’s Safe Drinking Water and Toxic Enforcement Act of 1986 (commonly referred to as Proposition 65) requires notification of chronic health effects. In addition, new legislation adopted in 2008 expands the ability of the State to manage and disseminate information about chemicals.
  • Legislation in Maine and Washington requires that they be notified of the presence of selected toxic substances in children's products.
  • Mercury products legislation in a number of US states requires manufacturers to submit detailed information to a centralized database on products to which they have intentionally added mercury.
  • The EU's Restriction on Hazardous Substances (RoHS) Directive prohibits the use of certain toxic substances in electrical and electronic equipment. The directive does not focus on information management; however, in order to comply with the directive, manufacturers and suppliers have had to develop complex information management systems to pass information along the supply chain.
  • The EU's chemicals regulation, REACH, requires registration of toxic substances in articles when certain criteria are met, as well as notification of toxic substances under another set of criteria. In some instances, REACH requires that information be provided to the recipient of the article as well as to consumers on request.
  • The Globally Harmonized System (GHS) for Classification and Labeling of Chemicals is a standardized system for communicating about chemical hazards. It applies only to chemicals and chemical products; it does not apply to articles. However, some elements of the GHS may be useful for accessing information on 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.

Pre-Screen Alternatives

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.

Persistence, Bioaccumulation and Toxicity

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 ToxicityAccording 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.

[1] Half-life is the length of time it takes for the concentration of a substance to be reduced by one-half relative to its initial level, assuming first-order decay kinetics.
[2] The bioconcentration factor (BCF) is a measure of the ability for a water-borne chemical substance to concentrate in fatty tissue of fish and aquatic organisms relative to its surroundings. EPA defines bioconcentration as the net accumulation of a substance by an aquatic organism as a result of uptake directly from the ambient water through gill membranes or other external body surfaces (60 FR 15366). In general, chemicals that have the potential to bioconcentrate also have the potential to bioaccumulate. Because BCF values are much easier to measure (and estimate), the BCF is frequently used to determine the potential for a chemical to bioaccumulate.
[3] ChV is the chronic (long-term) toxicity value to fish over the timeframe specified. This is the same as a chronic no-effect-concentration (NEC) and the geometric mean of the maximum allowable toxicant concentration (MATC). The MATC is the range of concentrations between the lowest-observed-effect concentration (LOEC) and the no-observed-effect concentration (NOEC).


A chemical can be screened out if it is classified under one of the following classifications:

  • US EPA Classifications:
    • Group A: Known Human Carcinogen
    • Group B1: Probable Human Carcinogen (Limited human evidence)
    • Group B2: Probable Human Carcinogen (Sufficient evidence in animals)

  • IARC Classifications:
    • Group 1: Known Human Carcinogen
    • Group 2A: Probable Human Carcinogen

More information about the various classifications of carcinogens is available on the Data Sources for Chemicals of Concern section in the Resources section.

Chemicals present on specific lists

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
Acrylamide 79-06-1
Acrylonitrile 107-13-1
Arsenic compounds NA
Arsenic 7440-38-2
Cadmium compounds NA
Cadmium 7440-43-9
Carbon tetrachloride 56-23-5
Chlorine 7782-50-5
Chloroform 67-66-3
Chromic acid 1333-82-0
Chromium compounds (+6) NA
Cyanide compounds NA
Dibromochloropropane 96-12-8
Dichloroethane 107-06-2
Diethylsulfate 64-67-5
Dimethyl formamide 68-12-2
Dioxane 123-91-1
Epichlorohydrin 106-89-8
Ethylene oxide 75-21-8
Formaldehyde 50-00-0
Hydrazine 302-01-2
Hydrogen cyanide 74-90-8
Hydrogen fluoride 7664-39-3
Lead 7439-92-1
Lead compounds NA
Methylene bisphenyl isocyanate 101-68-8
Nitrobenzene 98-95-3
Nickel compounds NA
Phosgene 75-44-5
Propyleneimine 75-55-8
Propylene oxide 75-56-9
Selenium and selenium compounds 7782-49-2 (elemental)
Silver chromate 7784-01-2
Sulfuric acid 7664-93-9
Sulfuric acid (fuming) 7664-93-9
Tetrachloroethylene 127-18-4
Toluene diisocyanate (mixed isomers) 26471-62-5
Trichloroethylene 79-01-6

Other lists may provide an appropriate basis for pre-screening. The SIN list previously mentioned is an example of one such list.

Prioritize Alternatives for Further Evaluation

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:

  • Performance: Known performance of alternatives. Performance criteria should be specific to the use of the chemical/material and may include such items as maintenance and durability as well as specific performance requirements. Consider the potential for future performance enhancements.
  • Availability: Number of suppliers/manufacturers that commercially provide the alternative. In addition, information about the volume of the alternative produced may be important (i.e., is the alternative available only in very small quantities?).
  • Manufacturing Location: Is the product manufactured in the state or outside of the state conducting the assessment? Products or materials manufactured in the state or a local community would receive a higher prioritization for evaluation as this may have a greater impact on the economy of the area.
  • Cost: Current costs associated with the alternative compared to that of the hazardous chemical. Consider the potential for future cost reductions (e.g., economies of scale due to higher volume production). If available, consider other significant costs such as raw material , storage and handling, and disposal costs.
  • Environmental, Health, and Safety: Known environmental, health, and safety risks or benefits compared to that of the hazardous chemical.
  • Global Market Effect: Information about pending or existing global restrictions that might materially affect the ability of an industry to market its products internationally. Since the world has become an increasingly global marketplace, taking into account the impact of international marketability on a product is essential for sustained economic viability for most industry sectors.
  • OtherOther use specific criteria as appropriate. For example, in some instances multiple similar alternatives exist for a particular use. In this case one alternative that is representative of that type can be chosen for further study.

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.

Technical Feasibility

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. 

Performance Criteria by Function of Chemical

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:

  • reduce surface tension (i.e., surfactants), 
  • dissolve materials (i.e., solvents), 
  • reduce water hardness (i.e., chelating agents) or 
  • provide or mask a scent (i.e., fragrances).

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:

  • Lower plasticizer volatility, measured by plasticizer’s vapor pressure, increases a product’s expected lifetime. Ideally, the volatility of a substitute plasticizer should be equal to or lower than DEHP to assure comparable processibility to that of DEHP.
  • Compatibility measures how well a plasticizer is suited to PVC. Plasticizers with inadequate compatibility are known to migrate out of plastic over the life of a product.
  • Molecular weight is a good indication of tensile elongation. Higher molecular weight plasticizers tend to result in longer product life
  • Compounding and calendaring processability compared to DEHP. These processes are most common when manufacturing flexible PVC. Alternatives should ideally process as well as or better than DEHP.

Availability of Alternatives

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: 

  • Number of suppliers/manufacturers that commercially provide the alternative.
  • Volume of the alternative produced (i.e., is the alternative available in quantities sufficient to satisfy the need).
  • Location of the alternative manufacturing operation. States might choose to prioritize alternatives that are manufactured in the state as this may have a greater impact on the state’s economy.

Cost of Alternatives

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. 

Environmental Management Accounting Tools

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). 

  • The EPA Environmental Accounting webpage provides a synopsis of environmental accounting concepts and case studies.
  • Tools that have been developed to assist in estimating costs associated with alternatives include
    • the New England Waste Management Official's Association (NEWMOA) created a tool, Energy and Materials Flow and Cost Tracker (EMFACT) and 
    • Texas Natural Resource Conservation Commission's Total Cost Accounting Software

Known Hazards of Alternative

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.

Chemical Alternatives
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. 

Material Alternatives
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. 

Process Alternatives
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.

Global Market Considerations

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.

Other Considerations

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

Compare Alternatives

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.

Research Alternatives

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.

  • Technical/Performance (including key performance requirements, key physical characteristics, key quality parameters, and key life cycle considerations)
  • Financial (including purchase price, availability of the alternatives, and associated capital costs)
  • Environmental (including PBT characteristics, environmental mobility and other environmental hazards)
  • Human Health/Safety (including acute and chronic human effects, other hazards such as flammability and corrosivity and exposure potential)

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:

  • All data must represent current science and be derived from peer reviewed and publicly available (i.e., published) sources. The primary source of these data were those articles available from the National Library of Medicine’s Toxicology Data Network (ToxNet).
  • For human health, data based on human epidemiological studies were used preferentially. Data based on tests of non-human sources were used if human epidemiological data was not available. If neither human epidemiological data nor data based on non-human sources was available, data derived from models were used
  • If modeled data was to be used, the Institute used models approved by the US EPA.

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. 

User Experience with Alternatives

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. 

Assess Alternatives

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.

Systems Impacts
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:

  • (e.g., Could the adoption of an alternative lead to a shift in manufacturing that might alter employment opportunities or protections in a certain geographic region?
  • Would adoption of the alternative create new and unfamiliar regulatory restrictions on the company that might be challenging to comply with?

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.

Evaluate chemical alternatives

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.

Evaluate mixtures

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.

Evaluate material alternatives

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.

Evaluate process alternatives

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.

Select an Alternative

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 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.

Presenting Results

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.

DEHP Alternatives Assessment Summary - Plasticizers in Medical Devices

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.

DfE Assessment results table

Promote the Adoption of Safer Alternatives

Once a chemical of concern and its safer alternatives have been studied, states need to consider ways that they will promote the use of the safer alternatives. 

Things that states should consider include:
  • Getting companies to adopt the use of the safer alternative/s
  • Deciding what to do if no safer alternatives are available
  • Developing an implementation policy
  • Conducting research and development (R&D) (different stakeholder process might be needed if R&D needed)
  • Providing money/resources to support further analysis  

Implementation Policy

There are a number of possible implementation policy actions that may be considered, including:

Require additional information
  • In cases where an alternative to a chemical of high concern is in use, it would not be unusual for the agencies to have little or no information about it. Authority to ask for such information could help the agencies determine if the alternative is safer. Additional information could be sought on a chemical’s use and toxicitity and accessibility by a target population (e.g., children)
  • States could request an additional alternatives assessment to be done by the manufacturers to determine whether a safer, effective alternative is available. 

Increase public awareness
  • Agencies might develop and publish a web site that provides consumers with information on the chemicals used in various products, the reason the chemical has been identified as a high priority , and any safer alternatives.
  • Require product labeling. Labeling is possibly the most direct method of communicating hazard to consumers. However, labeling is expensive and can lead to “warning fatigue” in that if warning labels become too common that they are overlooked and do little to prevent exposure

Restrict chemical use
  • Restrict the use of the chemical. Use could be restricted in specific types of products or by amounts permitted for specific uses.
  • Prohibit the use of the chemical. Use could be banned in specific types of products.
  • Control access to limit exposure to the chemical. Chemicals could be required to be contained in some way or prohibited in products where the chemical’s presence would pose particular risk to the intended user.

Product stewardship
  • Require the manufacturer to be responsible for the product throughout the product life from design to reuse/recycling to disposal. This approach should result in significant reductions in use of toxic chemicals in products in order to increase recyclability and reuse. 

Extended producer responsibility
  • Require the manufacturer to manage the product at the end of its useful life. This approach may also provide an incentive to the manufacturers to design the products with fewer hazardous substances in a way that allows the product to be more easily recycled.

Green design
  • Providing green chemistry fundings. Agencies could make grants to universities, private firms or others to develop alternative chemical formulations for specific products that greatly reduce or eliminate hazards to human and environmental health.
  • Require the manufacturer to fund green chemistry or redesign efforts for products to reduce or eliminate hazards to human and environmental health.

Promoting Adoption of Safer Alternatives

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:

  • Providing incentive programs, such as regulatory relief, fee reductions or technical assistance to help manufacturers make the switch to safer alternatives
  • Conducting market analysis of innovations in the specific applications in which the chemical of concern is being used

Developing New Solutions

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:

  • Promoting research and development of innovations. For example, the Toxics Use Reduction Institute provides academic research grants for university researchers to develop and test alternatives to priority toxic chemicals, in collaboration with industry experts. Examples of these research products can be found at the Institute's website.

  • Promote Green Chemistry. Green Chemistry is the process of synthesizing chemicals in a manner that minimizes the use of toxic chemicals and associated generation of hazardous by-products, in accordance with principles originally articulated by John Warner and Paul Anastas in their seminal book "Green Chemistry: Theory and Practice" (2000). An example of a state programs that promotes the development of safer alternatives is the Michigan Department of Environmental Quality Green Chemistry ProgramThe Green Chemistry Program has responsibility for promoting and coordinating state green chemistry activities, including research, development, and demonstration, education, and technology transfer activities in Michigan. The objective has been to foster use and development of new chemicals and chemical products that reduce or eliminate the use or generation of hazardous substances while producing high quality products through safe and efficient manufacturing products.

Working with Stakeholders

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:

  • Internal preparation (i.e., leadership, the team, controlling expectations, and training);
  • Mapping and planning (i.e., inventory of stakeholders, roles, goals, setting the scope and agenda, and documenting); and
  • Engagement (i.e., meetings, messages, mid-course correction, and measuring outcomes).

Things to consider:

  • Who has information that can help make the assessment more comprehensive and correct? This may include chemists, toxicologist, engineers, and other experts in the specific applications associated with the use of the chemical of concern?
  • Who should be consulted about priority chemicals of concern? Often the choice of the priority chemicals of concern is a policy and/or regulatory decision and stakeholders related to these areas should be included? Companies who manufacture, process or use these chemicals have a wealth of information that should be accessed. In addition, manufacturers or users of alternatives to the chemical of concern for specific applications can provide valuable insight into the challenges and benefits of using the alternatives.
  • Who should be consulted about priority uses of chemicals of concern? Stakeholders may include labor groups, environmental and public health advocates, and commerce experts?
  • What kind of outreach can be used throughout the assessment process? State programs need to consider how they will engage stakeholders throughout the process.
  • How should the information obtained about the alternatives be presented? This is a critical consideration that is dictated by the goal of the project. Methods may include fully transparent matrices of decision data designed to inform chemical users of their choices, graphic depictions of aggregated data on key criteria for the alternatives, or directive restrictions on the use of chemicals of concern.

Internal Preparation

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:

  • Communicate clearly
  • Earn respect and have credibility
  • Speak honestly about consequences
  • Make hard decisions, deliver bad news or bold recommendations
  • Elicit  hard decisions from the team
  • Know how to resolve conflicts
  • It is important to know who the leader reports to and what their interests in the AA are.

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.

Mapping and 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:

  • What are the various stakeholders’ roles and relationships in the sector and economic or policy system?
  • What can you say about their goals? (You should ask them at the meetings, but empathy is valuable early in planning)
  • Where do stakeholders get their information, and how can you reach them through outreach throughout the assessment process?

The team can begin to design its program by thinking about these questions:

  • How should the information obtained about the alternatives be presented? 
  • What is the level of understanding, or values affecting the ability to understand what you are presenting?

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.

  • Who should come to meetings (short list)?
  • When should you meet, how many times can you meet and how often? (consider the meeting costs)
  • What is the agenda, at least in draft for each meeting?
  • What is the outreach plan (what, when, and who is going to do it?)
  • What documentation should be available at meetings?
  • What will be the record of meeting discussions?

Stakeholder project planning : setting the scope and agenda, calendar, outreach, documentation

Engagement Strategies

Planning for meetings with stakeholders should address the unique needs of the situation. The following are some questions to consider: 

  • What is your desired outcome for the first meetings?
  • Who will present what content? 
  • Timing and schedule - How much time will each topic take? How many meetings should there be, and how much will you cover in each meeting? When should the meetings be held?
  • What are pitfalls -- technical, political and personal? How will you control the discussions while supporting contributions? 
  • How will you record and distribute the important discussions and decisions?

To prepare the documents for stakeholders to reference consider:

  • Tone and language of messages
  • Continuity
  • Layout and design
  • Collateral materials
  • Outreach and distribution
  • Web presence
  • Internal review
  • See examples at the "Presenting Results" section

To measure progress and correct the direction or participation or the process, consider:

  • Participative measurement of outcomes at each meeting and the take away message. Attenders should be able to report to their constituents each meeting about the value in taking part in the process.
  • Mid-course correction or intervention - who decides and how and when?


The following pages provide various resources to use in developing and updating alternatives assessments and chemicals use policies.

Tools for Assessing Alternatives

General Guidance - additional resources providing guidance on the alternatives assessment process

  • The European Chemicals Agency (ECHA) published "Guidance on the preparation of an application for authorisation", January 2011. The website includes a link for an assessment of alternatives template, which provides some guidance on data elements and information that should be considered in applying for authorization of a chemical under REACH. This website also provides some guidance on substitution planning and socio-economic analysis.

  • The EPA Design for Environment (DfE) program released "Alternatives Assessment Criteria for Hazard Evaluation", November 2010. This guidance goes through the step-by-step process that DfE uses in conducting alternatives assessments for chemicals as part of the EPA's Chemical Action Plans.


  • ISTAS RISCTOX Database (in Spanish) - A database containing information about uses of substances, hazardous properties, and alternatives.

  • TURI Laboratory CleanerSolutions database of cleaning products and solvents commonly used in industrial applications.

  • TOXNET - Databases on toxicology, hazardous chemicals, environmental health, and toxic releases.

  • NREL U.S. Life Cycle Inventory Database provides individual gate-to-gate, cradle-to-gate, and cradle-to-grave accounting of the energy and material flows into and out of the environment that are associated with producing a material, component, or assembly in the U.S.

  • The Substitution Support Portal Database contains 29 lists of substances that are legally or voluntarily restricted or are recommended for restriction due to their hazards. Lists are grouped in five categories: international agreements, EU regulatory lists, governmental lists, NGO, and trade union lists as well as company lists.

  • The Domestic Substances List (DSL) is a list of substances that were manufactured, used, sold in or imported into Canada in 1984-1986, in a quantity of 100 kg or more in any calendar year.

  • The International Chemical Secretariat's Substitute It Now List (SIN List) contains substances that are identified as Substances of Very High Concern according to REACH.

  • REACH XVIII: Restrictions on the manufacture, placing on the market, and use of certain dangerous substances, preparations, and articles.

    • State of California Proposition 65 list consists of chemicals known to the state of California to cause cancer or reproductive toxicity.

Chemical Hazard Comparison Methods

Hazard Display Methods

  • EPA's Design for the Environment process. The DfE program released "Alternatives Assessment Criteria for Hazard Evaluation" in November 2010. This guidance goes through the step-by-step process that DfE is using in conducting alternatives assessments for chemicals as part of the EPA's Chemical Action Plans.

  • Healthy Building Network Pharos Project - a tool to evaluate building materials

  • P2OASys - Pollution Prevention and Options Assessment System created and maintained by TURI

Screening Methods

  • Swedish KemI PRIO model - The criteria for the “PRIO substances” have been selected based on the Swedish Environmental Quality Objective for a Non-Toxic Environment (Government Bill 2000/01:652), and in consideration of the EU chemicals legislation REACH (Registration, Evaluation and Authorisation of Chemicals). 

  • German Institute for Occupational Safety Column Model - The Institute (IFA) has developed the Column Model to provide industry with a practical aid for the identification of possible substitutes. Only little information on the products is needed to carry out the assessment by means of this table. The figure below displays the model, which uses Risk-Phrases to quickly characterize the "employee risk" associated with a chemical being assessed

Chemical Databases

Chemical Characteristics

General Toxicity Databases
  • Toxicology, hazardous chemicals, environmental health, and toxic releases on ToxNet.
  • ToxSeek is a database from the US National Library of Medicine that allows users to conduct simultaneous searches.
  • US OSHA and EPA developed the Occupational Chemical Database, which compiles information from several government agencies.
  • US EPA's National Center for Computational Toxicology created the ACToR (Aggregated Computational Toxicology Resource) database for publicly available chemical toxicity data.
  • eChemPortal allows simultaneous searching of reports and datasets by chemical name and number and by chemical property. Data are organized and displayed by endpoint.
  • The European chemical Substance Information System (ESIS) provides data on specific chemical groups (i.e., PBT), and regulatory information.
  • PLuM (Public Library of Materials) was created by the Univ. of California Berkeley as a resource for finding authoritative information about known hazards of chemicals.

Specific Toxicity Databases

Preferred Products

Undesirable Materials and Products

Other Databases

Data Sources for Chemicals of Concern

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:


United States: Federal

  • EPA PBT Program - EPA identified 12 high priority PBTs that require immediate action. EPA established a chemical profile fact sheet and action plan for each of these PBTs.
  • EPA TRI Program - EPA is charge with implement the Emergency Planning and Community Right to Know Act (EPCRA) legislation which requires businesses and other organizations to report chemical release to the environment. As part of this regulation, EPA maintains the Toxics Release Inventory, a database which summarizes releases reported to EPA under this regulation. On October 29, 1999, EPA announced in the Federal Register that it was establishing TRI reporting requirements for a list of Persistent, Bioaccumulative and Toxic (PBT) chemicals.

  • NTP Center for the Evaluation of Risks to Human Reproduction - CERHR publishes monographs that assess evidence that environmental chemicals, physical substances, or mixtures (collectively referred to as “substances”) cause adverse effects on reproduction and development and provide opinion on whether these substances are hazardous for humans.Through this process, the CEHR has identified 40 chemicals of concern.
  • NTP Report on Carcinogens - The NTP also publishes a list of agents, substances, mixtures, or exposure circumstances that may pose a hazard to human health by virtue of their carcinogenicity. The RoC includes two categories of carcinogenic compounds: 1. Chemicals ‘known to be human carcinogens’. 2. Chemicals ‘reasonably anticipated to be human carcinogens’ The 12th Report on Carcinogens identifies 56 Category A and 185 Category B carcinogens.
  • The Endocrine Disruption Exchange (TEDX) provides a database of chemicals with the potential to affect the endocrine system.
  • The web-based search system provided by the National Library of Medicine has created the Superlist (, which is a list of regulatory and related lists

States in the United States:

  • Massachusetts Toxics Use Reduction Act - More and Less Hazardous Chemicals List
  • California’s Proposition 65 Program - (Prop 65), also called the Safe Drinking Water and Toxic Enforcement Act of 1986, was enacted as a Californian ballot initiative in November of that year. Prop 65 was intended by its authors to protect California citizens and the State's drinking water sources from chemicals known to cause cancer, birth defects or other reproductive harm, and to inform citizens about exposures to such chemicals.[15] Each year, the Office of Environment Health Hazard Assessment section of the California EPA publishes an updated list of chemicals of concern. The list currently contains 721 unique chemicals which have been placed on the list due to their carcinogenic and/or reproductive toxicity.[16]
  • WA State PBT Program - In 2006, the WA Dept. of Ecology as directed by the Governor adopted regulations specific to PBTs (WAC 173-333). 27 PBTs are identified including 25 organic chemicals/chemical groups and two ‘metals of concern.’ The legislation also requires Ecology and the Department of Occupational Health (DOH) to issue one Chemical Action Plan each year until all of the PBTs are assessed. Ecology and DOH are also required to prioritize the PBTs and to address first those that pose the greatest threat to human health and the environment. [17] As part of this process, Ecology and DOH issued a Multiyear CAP Schedule in 2007.[18] Ecology and DOH evaluated all of the chemical compounds included in the 27 PBTs and established a list of 75 chemicals with specific CAS numbers for evaluation.
  • Maine’s law on Toxic Chemicals in Children’s Products directed the Maine Department of Environmental Protection (DEP) in concurrence with the Department of Health and Human Services, Maine Center for Disease Control and Prevention (CDC) to publish a list of Chemicals of High Concern by January 1, 2010.1739 chemicals are included in Maine's list of chemicals of high concern. A chemical may be included on the list if it has been identified by an authoritative governmental entity on the basis of credible scientific evidence as being known as: A. a carcinogen, a reproductive or developmental toxicant or an endocrine disruptor; B. Persistent, bioaccumulative and toxic; or C. Very persistent and very bioaccumulative


  • International Agency for Research on Cancer - (IARC) is part of the World Health Organization. IARC's mission is to coordinate and conduct research on the causes of human cancer, the mechanisms of carcinogenesis, and to develop scientific strategies for cancer control. The Agency is involved in both epidemiological and laboratory research and disseminates scientific information through publications, meetings, courses, and fellowships.[19] In addition, IARC publishes monographs which identify carcinogenic chemicals and separates them into four main groups:[20] 
    • Group 1: Carcinogenic to humans. (47 chemicals/chemical groups out of 105) 
    • Group 2A: Probably carcinogenic to humans. (51 chemicals/chemical groups out of 66) 
    • Group 2B: Possibly carcinogenic to humans. (221 chemicals/chemical groups out of 248) 
    • Group 3: Not classifiable as to its carcinogenicity to humans. (515 chemicals) 
    • Group 4: Probably not carcinogenic to humans. (1 chemical) For the purposes of this evaluation, Ecology did remove some entries from consideration

International: Europe

  • European Union (EU) Substances of Very High Concern (SVHC) Program[21] - ECHA has only begun the process of identifying SVHCs and currently sources 16 on its website. These 16 were included in the HPC list.
  • Danish EPA Advisory List for Self-Classification of Dangerous Substances - includes over 20,500 substances that have been identified by Quantitative Structure-Activity Relationship (QSAR) models.
  • Endocrine Disruptor Program- On 20 December 1999, the European Commission (EC) adopted a Communication on a Community Strategy for Endocrine Disrupters – a range of substances suspected of interfering with the hormone systems of humans and wild life. The strategy focuses on man-made substances, including chemicals and synthetic hormones, which may harm health and cause cancer, behavioral changes and reproductive abnormalities.[23] Endocrine disruptors have been grouped into four major categories which are: 
    • Category 1: Evidence of endocrine disruption activity (194 chemicals) 
    • Category 2: Some evidence of biological activity related to endocrine disruption (125 chemicals) 
    • Category 3: No scientific evidence of endocrine disrupting activity 
      • 3A: No data available on wildlife relevant and/or mammal relevant endocrine effects (23 chemicals) 
      • 3B: Some data available but evidence is insufficient for identification (85 chemicals) 
      • 3C: Data available indicating no scientific basis for inclusion in list (0 chemicals-details not provided)

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.[24]

  • Oslo-Paris Convention (OSPAR) - The OSPAR Commission, originally formed in 1972 to control dumping into the North Sea, is a consortium of 15 European Countries and the European Community whose mission is to protect the marine environment of the North-East Atlantic. OSPAR has expanded over the years to include land-based and production sources of potential pollution to the North-East Atlantic. The 1992 OSPAR Convention is the current instrument guiding international cooperation to meet these objectives.[27] OSPAR had conducted considerable work to identify chemicals of concern to the North-East Atlantic. The first of these is a list of chemicals or chemical groups of possible concern which consists mainly of PBT chemicals with a few endocrine disruptors included.[28] OSPAR further identified a shorter list of chemicals or chemical groups which require priority action.[29]

International: Canada

  • Canadian Environmental Protection Act - The Canadian Environmental Protection Act, 1999 (CEPA 1999) is Canada's federal environmental legislation aimed at preventing pollution and protecting the environment and human health.[30] As part of this effort, the Canadian government evaluated all compounds imported or produced in Canada and prioritized them for various criteria. The results of these efforts are available on the web.[31]

Non-Governmental Organizations


  • Grandjean & Landrigan Identification of Neurotoxins[32] - The European Chemicals Agency (ECHA) prepares Annex XV dossiers for the identification of substances of very high concern, which are carcinogenic, mutagenic, or reproductive toxins (CMRs), PBTs, or cause serious effects to human health or the environment of an equivalent level of concern as those above (e.g., endocrine disrupters). Two well-known toxicological researchers conducted detail evaluation of potential neurotoxins particularly on the young. Their work, which identified 201 potential neurotoxins, was published in The Lancet, one of the leading medical journals in the world.[33] Their identification of industrial chemicals that have caused neurotoxic effects in humans was based upon data from the Hazardous Substances Database of the US National Library of Medicine, supplemented by fact sheets by the US Agency for Toxic Substances and Disease Registry, and the Integrated Risk Information System (IRIS) of the US EPA

Primary sources of modeled data include:
  • ACToR is one of many EPA tools available for those interested in chemical toxicity to find data about potential chemical risks to human health and the environment.
  • ToxCAST – EPA's Toxicity Forecaster database, launched in 2007 to develop ways to predict potential toxicity and streamline the prioritization of chemicals that need toxicity testing.

  • EPA's database of chemical exposure studies (ExpoCast) used to estimate real-life risks to health and to identify the most effective ways to reduce these risks.
  • EPI Suite™ estimates physical / chemical properties (i.e., melting point, water solubility) and environmental fate properties (i.e., breakdown in water or air), which can indicate where a chemical will go in the environment and how long it will stay there.
  • ECOSAR predicts toxicity of chemicals released into water to aquatic life (fish, algae, and invertebrates).
  • PBT Profiler screens chemicals for potential to persist, bioaccumulate, and be toxic (model is an online tool and cannot be downloaded).
  • OncoLogic™, Version 7.0, is a computer software program designed to predict the potential cancer-causing effects of a chemical by applying the rules of structure activity relationship (SAR) analysis and incorporating knowledge of how chemicals cause cancer in animals and humans.
  • Analog Identification Methodology (AIM), available on EPA's web site, identifies close structural analogs that have measured data and points to sources where those data can be found. (AIM is an online tool and cannot be downloaded).
  • NonCancer Screening Protocol is a stepwise process (not a computerized method) useful for screening untested chemicals for non-cancer health effects and is described in the P2 Framework Manual, June 2005.
  • E-FAST estimates chemical releases and dose rates to humans from these releases.
  • ChemSTEER estimates environmental releases and worker exposures resulting from chemical manufacture, processing, and/or use in industrial and commercial workplaces.
  • The USEtox model is an environmental model for characterization of human and ecotoxic impacts in Life Cycle Impact Assessment and for comparative assessment and ranking of chemicals according to their inherent hazard characteristics.

Scientific Literature

  • ChemIDplus Advanced, is a web-based search system provided by the National Library of Medicine. In addition to ToxNet, and HSDB, ChemIDplus links to numerous other databases, including PubMed and the Superlist (, which is a list of regulatory and related lists. It also allows users to identify and evaluate structurally similar chemicals.

  • Toxnet - maintained by the National Library of Medicine

  • Integrated Risk Information System - IRIS (Integrated Risk Information System) is a compilation of electronic reports on specific substances found in the environment and their potential to cause human health effects. The information in IRIS is intended for those without extensive training in toxicology, but with some knowledge of health sciences. IRIS can be searched to determine chemicals of concern due to specific toxicity criteria.

  • National Toxicology Program - The NTP is an interagency program managed by the US Department of Health and Human Services (DHHS) whose mission is to evaluate agents of public health concern by developing and applying tools of modern toxicology and molecular biology.


  • OECD eChemPortal - The global portal to information on chemical substances developed by the Organization for Economic Cooperation and Development in 2008


[1] Information on VCCEP can be found at:, accessed 11/17/2008.
[2] VCCEP chemicals are identified at:, accessed 11/17/2008
[3] More information on EPA’s PBT program can be found at:, accessed 11/18/2008
[4] More information on EPA’s Priority PBTs can be found at:, accessed 11/18/2008
[5] More information on EPA’s EPCRA Program and TRI can be found at:, accessed 11/18/2008
[6] Federal Register notice at:, accessed 11/17/2008
[7] More information on EPA’s IRIS can be found at:, accessed 11/18/2008
[8] The search criteria and chemicals can be found on the IRIS site at:, accessed 11/18/2008
[9] More information on EPA’s Waste Minimization Program can be found at:, accessed 11/18/2008
[10] More information on these chemicals can be found at:, accessed 11/18/2008
[11] More information on the NTP and its work can be found at:, accessed 11/18/2008
[12] NTP CERHR found at:, accessed 11/17/2008
[13] Information on the CEHR list can be found at:, access 11/18/2008
[14] NTP RoC found at:, accessed 11/17/2008
[15] More information on Prop 65 can be found at:, accessed 11/17/2008
[16] The Prop 65 List can be found at:, access 11/18/2008
[17] Ecology’s PBT program found at:, accessed 11/17/2008
[18] The Multiyear CAP Schedule can be found at:, accessed 11/18/2008
[19]  More information on IARC can be found at:, accessed 11/17/2008
[20] IARC Monographs found at:, accessed 11/17/2008
[21] More information on SVHCs can be found at:, accessed 11/17/2008
[22]  Governing Statement of the European Commission at:, accessed 11/20.2008
[23]  More information on the EU Endocrine disruptors program can be found at:, accessed 11/17/2008
[24]  The database containing these endocrine disruptors can be found at:, accessed 11/18,2008
[25]  More information on EC PBTs can be found at:, accessed 11/17/2008
[26]  More information on ORATS can be found at:, accessed 11/18/2008
[27]  More information on OSPAR can be found at:, accessed 11/18/2008
[28]  More information on the OSPAR Chemicals of Possible Concern can be found at:, accessed 11/18/2008
[29]  More information on OSPAR Chemicals for Priority Action can be found at:, accessed 11/18.2008
[30]  For more information on CEPA see:, accessed 11/18/2008
[31]  CEPA found at:, accessed 11/17/2008
[32]  Grandjean, P & PJ Landrigan, Developmental neurotoxicity of industrial chemicals, The Lancet, 2006, available at:, accessed 11/20/2008
[33]  The Lancet at:, accessed 11/20/2008

Data Sources for Chemical Uses in Products and Processes

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.
US Federal:
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 

  • The Hazardous Substances Data Bank (HSDB) provides information on the major uses of specific chemicals among a vast array of other information of interest. No information is provided on chemicals in specific products, only major uses of specific chemicals stored in the data bank. Data on major uses is taken from public sources and may not be current or detailed enough to meet individual needs.
  • The Household Products Database (HPD) provides information on chemicals found in over 8,000 chemical brands. The information contained in the HPD is obtained from Material Data Safety Sheets (MSDSs), which are required to communicate to workers risks associated with chemicals used during the manufacture of or in products. MSDSs, however, are limited as they generally include only information on chemicals that potentially pose a hazard and are not a true indication of all of the chemicals used in a product. Chemicals are also listed in general ranges, which can vary considerably based upon the product formulation. Toxicity information is included for those chemicals listed although the data is often incomplete and does not reflect a full history of the risks posed by the chemicals.As the content information found in MSDSs is often dated, inaccurate and without peer-review, care should be taken when using this source.

US State:

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.


Non-Governmental Organizations:

  • maintains a limited database on toxic chemicals in specific toys ( Parents may access the information and determine which toys contain the lowest levels of screened toxics. The data, however, is limited and has not undergone extensive technical review.
  • The Environmental Working Group (EWG) provides a database, Skin Deep, which lists chemicals found in personal care products. The contents of the database are based upon input provided by manufacturers of cosmetic products that have volunteered the information and, to a lesser extent, from product labels. EWG has developed a method to rate the safety of cosmetic products based upon this information. The chemical data has not been verified through analysis and care should be taken in its use.


  • CleanGredients, which also provides information for formulators on general product and regulatory information, physical-chemical properties and human and environmental health data.

With the increasing development of electronic message, companies have been formed which provide information on chemical content in products. 

  • One example is Good Guide which was formed to evaluate products and to provide recommendations to assist in the purchasing of safer, healthier, and greener products.

Chemicals Used in Occupational Settings/Processes

  • The National Oceanic and Atmospheric Administration Office of Response and Restoration has created a website for first responders to get general information on chemicals used in various products and processes. The "My Chemicals" portion of the site provides good information on the various ways that hazardous chemicals may be used in production processes. For instance, halogenated organic compounds as a reactive group in a chemical are described here.
  • NIOSH Blue Book: Guide on Occupational Diseases:
  • California Pesticide Use Reporting - can search using the Pesticide Action Network website:
  • Canadian Centre for Occupational Health and Safety:

Data Sources for Exposure


  • Part D of the REACH Guidance on Information Requirements and Chemical Safety Assessments provides in-depth guidance on exposure assessment, in particular how to describe uses, how to collect information on operational conditions and risk management measures, and how to carry out exposure estimates. This includes:
    • Brief general description of identified uses and how to give exposure scenarios a short title (Chapter R.12).
    • Risk management measures and operational conditions for building of exposure scenarios, including guidance on how to determine the effectiveness of risk management measures and how to make use of the risk management library initially set up during the development of the current guidance (Chapter R.13).
    • Occupational exposure estimation (Chapter R.14).
    • Exposure estimation related to consumers (Chapter R.15).
    • Exposure estimation related to the environment (Chapter R.16).
    • Chapter R.17 and Chapter R.18 provide guidance on exposure estimates related to life cycle stages subsequent to identified uses (releases from articles and releases from waste life stage).


  • The Association of Occupational and Environmental Clinics (AOEC) developed an Exposure Code List was first developed in 1994, for use by AOEC members in order to help systematically identify both existing and emerging occupational and environmental health concerns (Hunting and McDonald, “Development of a Hierarchical Exposure Coding System for Clinic-Based Surveillance of Occupational Disease and Injury”, Appl. Occup. Environ. Hyg. 10(4), April, 1995). This source includes specific designation for chemicals known or suspected of causing or exacerbating asthma.

  • A project group under the Nordic Chemical Group (NKG) has developed a toolbox on the SPIN web site, SPIN Exposure Toolbox. The first tool is called Use Index. The tool makes it possible to search for a general indicative exposure of human beings and environment from different chemical uses. It is based on the extensive information stored in the Nordic product registers. Since the tool uses confidential data, which cannot be published on the SPIN web site, this leads to increased availability of chemical information.

Other Tools

  • The Stoffenmanager, created by the Safe and Healthy Work Department of the Ministry of Social Affairs and Employment of Netherlands, is a tool for prioritizing worker health risks to dangerous substances. The Stoffenmanager was developed as a tool allowing small and medium-sized enterprises (SMEs) to prioritize health risks to dangerous substances and to determine effective control measures. The tool combines hazard information of a substance or product with an inhalation and/or dermal worker exposure assessment to calculate a risk score. When risks are presumed, effects of control measures can be examined. An action plan shows an overview of the risk assessments with control measures. Stoffenmanager can also be used as a quantitative inhalation exposure tool and as a REACH Tier one quantitative inhalation exposure tool.
  • EPA's database of chemical exposure studies (ExpoCast) used to estimate real-life risks to health and to identify the most effective ways to reduce these risks.

Biomonitoring Data
  • The Danish Birth Cohort is a program initiated in the Nordic Countries to determine the impact of numerous external stimuli upon the development of the children. Between 1997 and 2000, mother and child pairs were recruited into a long-term study to evaluate the impacts of early exposures upon long-term development. 

Indoor Air and Dust Data

Authoritative sources of information on chemicals found in indoor air and dust include:

  • The California Air Resources Board (CARB) conducted research into a number of air pollution areas, as described in their 2005 indoor air report
  • The German Environmental Survey (GerES) is a nation-wide survey conducted to evaluate the exposure of the German population to environmental contaminants.

Drinking Water Data

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 and Federal Activities

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.

• Green Chemistry Initiative
• Summary of regulations associated with AB1879 (analysis by a law firm in California)

Safer Chemicals in Children's Products

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:

Examples of Alternatives Assessments

  • Quinn MM, Fuller TP, Bello A, Galligan C, Pollution Prevention-Occupational Health and Safety in Hospitals: Alternatives and Interventions, Journal of Occupational and Environmental Hygiene 3:182-193, 2006.

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

Logistics and Communications

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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