On June 9, 2010, the California Department of Toxic Substances Control (CDTSC) held a conference entitled “Alternatives Analysis Symposium I: Issues and Evolution, Capitalizing on Success.” CDTSC states that the alternatives analysis process for chemicals used in consumer products is a “core element” of California’s Green Chemistry Initiative, and that identifying alternatives is a complex process, involving an analysis of a chemical’s impact on human health and the environment. According to CDTSC, the goal is to find a science-based solution that provides consumers with assurance that the product is safe. CDTSC held the Symposium to obtain public and expert input on the issue. Presenters included:
- Clive Davies, Director, U.S. Environmental Protection Agency (EPA) Design for the Environment (DfE);
- Libby Sommer, Environmental Scientist, EPA DfE;
- Lauren Heine, Science Director/Partner, Clean Production Action (CPA);
- Alex Stone, Chief Chemist, Washington State Department of Ecology (WDE);
- Don Versteeg, Environmental Toxicologist and Risk Assessor, Procter & Gamble Co.; and
- Jay Bolus, Chief Scientist, McDonnough Braungart Design Chemistry (MBDC).
Links to the presentations are available online.
Davies provided an overview of DfE’s history and development, its approach to alternatives assessments, and DfE’s contribution to EPA’s Chemical Action Plans for bisphenol A (BPA), deca-brominated diphenyl ether (decaBDE), and phthalates. DfE’s alternatives assessment process consists of six steps: (1) determine need for alternatives assessment; (2) develop an approach; (3) consult with stakeholders; (4) conduct hazard assessment; (5) develop the report; and (6) apply the information in decision making. Davies also discussed EPA’s Safer Product Labeling Program (SPLP), which is currently available for cleaning products; holding tank treatments; bioremediation products; deicers; industrial coatings; inks; field paint; and tire balancing liquid. According to Davies, as of 2010, there are approximately 2,000 recognized products. Industry has shown so much interest in the SPLP that DfE uses third-parties to develop profiles, and DfE provides quality assurance of the third-party assessment, confirming that the products’ ingredients meet DfE criteria for human health and the environment. As part of EPA’s Chemical Action Plan for phthalates, DfE intends to hold a meeting on July 15, 2010, for stakeholders concerning BPA alternatives in thermal and carbonless paper. In Summer 2010, DfE intends to begin its review of decaBDE alternatives in flame retardants. In Fall 2010, DfE expects to begin exploring phthalate alternatives.
Sommer discussed differentiating chemicals in alternatives assessments and identifying the availability of safer alternatives for policy purposes. DfE’s criteria for safer ingredients includes authoritative lists (International Agency for Research on Cancer; National Toxicology Program; EPA carcinogens list; European Union (EU) carcinogenic, mutagenic, or reproductive list; and EU risk phrases), as well as the evaluation of experimental data (Globally Harmonized System of Classification and Labeling of Chemicals; EPA New Chemicals Program; and Section 8(e) reporting under the Toxic Substances Control Act). DfE also looks at human health toxicity and environmental fate and effects endpoints, and evaluates ingredients on specific human health, ecotoxicity, and environmental hazard concerns. Sommer reviewed CleanGredients®, which is sponsored by DfE as well as several companies. CleanGredients® identifies ingredients that meet DfE’s criteria for safer ingredients, and is intended to build on market demand for green products. More information regarding CleanGredients® is available online.
Heine discussed CPA’s Green Screen for Safer Chemicals, which is a publicly available screening tool intended to promote the design, manufacture, and use of safer chemicals. The Green Screen currently uses four benchmarks:
- Benchmark 1: Avoid — chemical of high concern;
- Benchmark 2: Use but search for safer substitutes;
- Benchmark 3: Use but still opportunity for improvement; and
- Benchmark 4: Prefer — Safer chemical.
The criteria for each benchmark become progressively more stringent for environmental and human health and safety, with the hazard criteria of Benchmark 4 representing the most preferred chemicals. CPA is in the process of updating the Green Screen, and the new version will include a fifth benchmark. Sommer noted that Hewlett-Packard began using the Green Screen to assess alternatives to chemicals being restricted in its products, and has used the results of assessments in its decision making on key replacement materials. Sommer suggested that manufacturers can use the Green Screen to identify chemicals of concern, and talk to their suppliers to find and evaluate possible alternatives. CPA is preparing for peer review of the second version of the Green Screen in June 2010, and requests volunteers. More information on the Green Screen is available online.
Stone reviewed WDE’s specific experience with alternatives assessments, with decaBDE as the example. Washington passed legislation that prohibited the sale of mattresses containing decaBDE beginning January 2008, and prohibited the sale of decaBDE contained in the electronic enclosure of televisions or computers and residential upholstered furniture, if fire safety was maintained and safer and technically feasible alternatives were identified. WDE completed its alternatives assessment report in January 2009, and the ban on decaBDE in electronics and upholstered furniture will take effect in January 2011.
Versteeg presented an industry perspective on the challenge of alternatives assessment, the integration of alternatives assessment into product development, and provided examples and issues. According to Versteeg, issues include replacing an “old” chemical, that is well understood, with a new chemical, that is less known, and substituting a chemical, only to discover later that the substitute is not as safe as initially thought. Bolus discussed MBDC’s Cradle to Cradle® Certification Program, which includes profiling chemicals based on their human and environmental health hazards. The hazard identification is based on ten human health criteria, and eight environmental health criteria. MBDC uses a “stoplight” approach, with red being assigned to high hazard chemicals.
The CDTSC Symposium is the first in a series of three that will focus on alternatives analysis. The symposiums are free and open to the public, and will be webcast. Information on the symposiums will be posted online as it becomes available.