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January 27, 2015

What Does 2015 Hold for Green Chemistry?


By Richard E. Engler, Ph.D.

In 2014, the U.S. Environmental Protection
Agency (EPA) and American Chemical Society Green Chemistry Institute® (ACS GCI)
renewed their Memorandum of Understanding (MOU), continuing the partnership
centered on the Presidential Green Chemistry Challenge Award. The award cycle
returned to its original schedule with the 2015 ceremony set to coincide with
the Green Chemistry & Engineering Conference, as it had until 2013. This
year the conference will be held on July 14-16, 2015, in North Bethesda,
Maryland. This recommitment between EPA and ACS GCI is an expression of the
continued dedication each has to creating opportunities for the growth and development
of green chemistry. 2015 is especially significant as it represents the 20th
year for the Presidential Green Chemistry Challenge Award. The award ceremony
and conference should highlight both the success of years past and the
potential of years to come.


There are other positive indicators about the
direction of green chemistry in the coming year as well. On January 5, 2015, Bergeson & Campbell, P.C. (B&C®)
published “Predictions
and Outlook for EPA’s Office of Chemical Safety and Pollution Prevention
(OCSPP) 2015
” (The Outlook). It covers the full range of OCSPP issues,
including green chemistry and Design for the Environment (DfE).


In 2014, Jim Jones, OCSPP’s Assistant
Administrator, continued his focus on green chemistry and DfE. Jones visited
award winners to gain a deeper understanding of their technologies and
businesses. Jones’s engagement in both programs should continue in 2015. DfE is
undergoing revitalization in 2015.


EPA is expected to reveal the new Safer Product Labeling logo. DfE
is also looking to expand its Safer Chemical Ingredients
List (SCIL)
and is providing new opportunities for DfE partners to be recognized for their efforts.


The New Year will also see more interactions
between green chemistry and the Toxic Substances Control Act (TSCA). As you may
know, manufacturers must submit “premanufacture notices” (PMN) to EPA prior to
manufacturing or importing any substance not listed on the TSCA Inventory or
otherwise exempt. TSCA allows EPA to review new substances for unreasonable
risk to human health or the environment.


Most green chemistry technologies are
classified as “new” under TSCA rules, so they must clear this hurdle. Some
green chemistry technologies have drawbacks in one phase of their lifecycle and
benefits in another. For example, a biobased substance may be less toxic to
humans, but more toxic to fish relative to the petroleum-based incumbent. The
challenge for EPA is how to consider these impacts, both positive and negative,
especially relative to existing chemicals in commerce.  Historically, EPA
has only focused on the substance itself, its hazard, releases, and exposures,
to determine “unreasonable risk.” Biobased chemicals, using waste as a feedstock,
and greener production methods present new challenges to EPA as these benefits
are upstream of the substance itself.  As discussed in The Outlook, some
green chemistry technologies have languished in the new chemicals review
process or have been subject to requirements different from those imposed on
nearly identical, existing chemicals. To avoid undue delays, some submitters
have taken advantage of voluntary pollution prevention (P2) statements in PMNs
to clarify the benefits of the novel technology to aid EPA in its
decision-making. Even with this additional information, it is not a trivial
task for EPA to compare and evaluate the relative risks and benefits at
different stages of a chemical’s lifecycle. Novel biobased feedstocks,
intermediates, and products will challenge both EPA and industry in 2015.


While some aspects of TSCA may be a barrier to
new green chemistry technologies, TSCA can also be a driver for change. EPA
regulatory action on existing chemicals will provide new drivers for companies
to develop and deploy green chemistry. Near the end of 2014, EPA published its
update on Work Plan and Action Plan chemicals. In particular, decisions on
trichloroethylene, dichloromethane, benzedine dyes, short-chain chlorinated
paraffins, phthalates, and long-chain perfluoroalkyl carbonates all present
increasingly important targets for green chemistry innovations. Similarly, the California
Department of Toxic Substances Control (DTSC) is moving ahead with its actions
on priority chemicals
and, of course, implementing the Safer Consumer
Products Regulations.


Information about chemical design may get a
boost from the maturation of EPA’s Computation Toxicology tools that allow
rapid screening for endocrine disruption. The coming year is likely to also see
progress on TSCA reform, which may include provisions relating to green


While EPA struggles with diminished funding and
diminished numbers of senior scientists (mostly through retirement), the
fundamental prospects for green chemistry remain sound: There are many problems
to solve and many scientists and engineers working to find sustainable ways to
solve them. EPA and ACS GCI will continue to be central to supporting and
nurturing green chemistry.

 Reprinted by permission from The
Nexus Blog
, a publication of the ACS Green Chemistry Institute