Download PDF
April 6, 2022

OSTP Publishes RFI Regarding Sustainable Chemistry

Bergeson & Campbell, P.C.

The Office of Science and Technology Policy (OSTP) published on April 4, 2022, a request for information (RFI) from interested parties on federal programs and activities in support of sustainable chemistry. 87 Fed. Reg. 19539. OSTP notes that “[t]he term “sustainable chemistry” does not have a consensus definition and most uses of the term indicate that it is synonymous with “green chemistry.”” OSTP requests information on the preferred definition for sustainable chemistry. OSTP also seeks comments on how the definition of sustainable chemistry could impact the role of technology, federal policies that may aid or hinder sustainable chemistry initiatives, future research to advance sustainable chemistry, financial and economic considerations, and federal agency efforts. OSTP states that it will use comments provided in response to the RFI to address Subtitle E of Title II of the National Defense Authorization Act (NDAA) (Subtitle E), which includes the text of the bipartisan Sustainable Chemistry Research and Development Act of 2019. Subtitle E directs OSTP “to identify research questions and priorities to promote transformational progress in improving the sustainability of the chemical sciences.” Comments are due by 5:00 p.m. (EDT) on June 3, 2022.

As reported in our January 19, 2021, memorandum, Subtitle E tasked OSTP with creating a consensus definition for the term “sustainable chemistry” to coordinate federal programs and activities in support of sustainable chemistry. According to OSTP, the definition will inform its development of a framework of attributes characterizing sustainable chemistry, as well as quantitative assessment metrics. Additionally, it will allow OSTP to assess the state of sustainable chemistry in the United States; coordinate and support federal research, development, demonstration, technology transfer, commercialization, education, and support for public-private partnerships; identify federal barriers and opportunities; identify scientific challenges; avoid duplication; and position federal funding for maximal impact, including through synergistic partnerships.

OSTP invites input from any interested stakeholders, including industry and industry association groups; civil society and advocacy groups; local organizers and community groups; state, local, and tribal governments; academic researchers; technical practitioners specializing in chemistry and chemical processes; and members of the public representing all backgrounds and perspectives. OSTP states that it “has great interest in receiving input from parties developing sustainable chemistry technologies, parties acquiring and using such technologies, and people from communities impacted by their use, including but not limited to environmental justice communities.”

According to the notice, OSTP has considered definitions for sustainable chemistry to include potentially incorporating technology, policy, finance/economics, energetics, national security, critical industries, and critical natural resources. OSTP encourages input on these and other considerations for a definition of sustainable chemistry. OSTP suggests that respondents provide information on the following topics:

  • Definition of sustainable chemistry: OSTP is mandated by Subtitle E to develop a consensus definition of sustainable chemistry. OSTP requests comments on what that definition should include. The definition will inform OSTP and federal agencies for prioritizing and implementing research and development (R&D) programs to advance sustainable chemistry practice in the United States. OSTP also requests comments on how the definition of “sustainable chemistry” relates to the common usage of “green chemistry” and whether these terms should be synonymous, exclusive, complementary, or if one should be incorporated into the other.
  • Technologies that would benefit from federal attention to move society toward more sustainable chemistry: What technologies/sectors stand to benefit most from progress in sustainable chemistry or require prioritized investment? Why? What mature technology areas, if any, should be lower priority?
  • Fundamental research areas: What fundamental and emerging research areas require increased attention, investment, and/or priority focus to support innovation toward sustainable chemistry (e.g., catalysis, separations, toxicity, biodegradation, thermodynamics, kinetics, life-cycle analysis, market forces, public awareness, tax credits). What federal research area might you regard as mature and/or robustly covered, or which federal programs would benefit from increased prioritization?
  • Potential outcome and output metrics based on the definition of sustainable chemistry: What outcomes and output metrics will provide OSTP the ability to prioritize initiatives and measure their success? How does one determine the effectiveness of the definition of sustainable chemistry? What are the quantitative features characteristic of sustainable chemistry?
  • Financial and economic considerations for advancing sustainable chemistry: How are financial and economic factors considered (e.g., competitiveness, externalized costs), assessed (e.g., economic models, full life cycle management tools), and implemented (e.g., economic infrastructure)?
  • Policy considerations for advancing sustainable chemistry: What changes in policy could the federal government make to improve and/or promote sustainable chemistry?
  • Investment considerations when prioritizing federal initiatives for study: What issues, consequences, and priorities are not necessarily covered under the definition of sustainable chemistry, but should be considered when investing in initiatives? Subtitle E includes the phrase: “support viable long-term solutions to a significant number of challenges.” OSTP states that it expects the final definition of sustainable chemistry to consider strongly resource conservation and other environmentally focused issues. For example, according to OSTP, national security, jobs, funding models, partnership models, critical industries, and environmental justice considerations may all incur consequences from implementation of sustainable chemistry initiatives such as dematerialization, or the reduction of quantities of materials needed to serve an economic function.


OSTP’s request for information does a good job of teeing up the issues Subtitle E of the NDAA compels OSTP to address, the most significant of which is creating a consensus definition for the term “sustainable chemistry.” Sustainable chemistry, however defined, should be a key focus of federal R&D efforts as the nation develops innovations to enable a more sustainable future — one with less reliance on extractive resources; one with a lower carbon footprint; one that manufactures, processes, and uses less hazardous substances; and one that is more circular. Defining sustainable chemistry is a key first step, and readers are encouraged to engage with OSTP to help ensure that the various government agencies are well aware of the scientific and commercial realities of developing more sustainable chemical technologies. As the notice elaborates, OSTP seeks information far beyond the definitional needs. For example, OSTP expressly seeks information on “policy considerations for advancing sustainable chemistry.” Specifically, OSTP seeks information on “[w]hat changes in policy could the Federal government make to improve and/or promote sustainable chemistry?” For those of us deeply concerned with the state of new chemical review under the Toxic Substances Control Act (TSCA), this initiative provides a critically important forum to educate and advocate.