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DfE's Alternatives Assessment Program helps industries choose safer chemicals for applications such as fire safety in
furniture. Alternatives assessments provide a basis for informed decision making by developing an in-depth comparison of potential human health and environmental impacts.
Alternatives Assessment Partnerships bring together environmental organizations, industry leaders, academia, and others to evaluate the environmental and health impacts of potential alternatives to problematic chemicals. The outcome of an Alternatives Assessments Partnership provides industry with the information they need to choose safer chemicals. This informed substitution enables the move to safer chemicals, while minimizing the likelihood of unintended consequences. Informed substitution analysis evaluates the hazards of alternative chemicals, during the relevant phases in the product life cycle, to ensure that substitutes are safer based on their health and environmental profiles.
Alternatives Assessment Methodology
Alternatives Assessments are used by the Office of Pollution Prevention and Toxics (OPPT) in EPA's Office of Chemical Safety and Pollution Prevention (OCSPP) to seek safer alternatives. DfE Alternatives Assessments are conducted as risk management actions when warranted for TSCA Work Plan Chemicals. They have also been conducted under Chemical Action Plans. By identifying and evaluating the safety of alternative chemicals, this approach can encourage industry to move to safer alternatives, it can complement regulatory action by showing that safer and higher functioning alternatives are available, or it can point out the limitations to chemical substitution for a particular use.
Alternatives assessments characterize chemical hazards based on a full range of human health and environmental information. Chemical choices made based on these assessments can minimize the potential for unintended consequences that might occur in moving from a potentially problematic chemical to a poorly understood alternative, which could be more hazardous.
DfE criteria for designating a concern for hazard can be found in the Alternatives Assessment Criteria for Hazard Evaluation (PDF) (35 pp, 405K). These criteria were updated August 2011 following stakeholder comment (PDF) (101 pp, 666K), and EPA's response to comments (PDF) (17 pp, 170K).
- Flame retardants in furniture
- Flame retardants in printed circuit boards
- Nonylphenol ethoxylate (NPE) surfactants
DfE is now applying this approach to:
- Bisphenol A alternatives in thermal paper
- Flame retardant decabromodiphenylether (decaBDE)
- Hexabromocyclododecane (HBCD) used in expandable polystyrene foam for insulation
- Alternatives to certain phthalates
What are the key steps to conducting an alternatives assessment?
STEP 1: DETERMINE FEASIBILITY OF AN ALTERNATIVES ASSESSMENT
To determine the need for and potential benefits of an alternatives assessment, DfE considers whether alternatives: are commercially available; have the potential for an improved health and environmental profile; and are likely to result in lasting change. Stakeholder interest is also a key consideration.
STEP 2: COLLECT INFORMATION ON CHEMICAL ALTERNATIVES
To develop a better understanding of the potentially problematic chemical and potential alternatives, DfE considers how well-characterized the possible alternatives are; the chemical manufacturing process; the range of functional uses that the chemical serves; and the feedstock or contaminants and residuals from the production process. DfE also considers the work of other organizations in exploring alternatives for the potentially problematic chemical, similar chemicals and functional uses. Based on analysis of this information and preliminary stakeholder consultation, DfE develops a proposed project scope and an approach for developing the alternatives assessment.
STEP 3: CONVENE STAKEHOLDERS
DfE uses input from a diversity of perspectives to inform the project scope, identify alternatives, and facilitate manufacturer and user adoption of safer chemicals. Stakeholders are drawn from the entire supply chain and all life-cycle stages of the potentially problematic chemical. Involvement throughout the project helps to ensure that stakeholders contribute to, understand and support the outcome, enhancing credibility and promoting adoption of the safer alternatives. Typical stakeholders include: chemical manufacturers; product manufacturers; non-governmental organizations; government agencies; academics; retailers; consumers; and waste and recycling companies. Chemical and technology innovators are critical members of the group.
STEP 4: IDENTIFY VIABLE ALTERNATIVES
Through literature review and discussion with stakeholders, DfE collects information about viability on a range of potential alternatives. The focus is on finding alternatives that are functional with minimum disruption to the manufacturing process. To identify the most likely alternatives, DfE may also include viability demonstrations by chemical and product manufacturers.
STEP 5: CONDUCT THE HAZARD ASSESSMENT
Central to the Alternatives Assessment is evaluation of a robust set of hazard endpoints. Based on the best data that are available from the literature or can be modeled, DfE assigns a descriptor of hazard concern level-high, moderate or low-for each alternative across a range of endpoints, including acute and repeated dose toxicity, carcinogenicity and mutagenicity, reproductive and developmental toxicity, neurotoxicity, sensitization and irritation, acute and chronic aquatic toxicity, and persistence and bioaccumulation. In addition, we provide a qualitative description of potential endocrine activity.
Sources of information for assessment of hazard include:
- Publicly available measured (experimental) data obtained from a literature review;
- Measured data contained in confidential business information received by EPA;
- Structure-Activity-Relationship (SAR)-based estimations from EPA's Pollution Prevention Framework and Sustainable Futures predictive methods;
- Professional judgment of EPA science experts with decades of chemical review experience; and
- Confidential data in experimental studies supplied by the chemical manufacturers.
When measured data are not available or adequate for an endpoint, DfE assigns a hazard concern level based on SAR and expert judgment. The DfE criteria for level of concern for hazard can be found in the Alternatives Assessment Criteria for Hazard Evaluation (50 pp, 1.09MB). This practice ensures that all endpoints are considered in the assessment and that alternatives are evaluated based on as complete an understanding of their human health and environmental characteristics as possible. DfE also designates a level of confidence associated with hazard assignments and notes decisions based on little or conflicting evidence.
The most instructive endpoints are those that reveal differences in toxicity among alternatives; these endpoints make it possible to distinguish the inherently safer chemicals from the less safe.
STEP 6: APPLY ECONOMIC AND LIFE CYCLE CONTEXT
Once the hazard assessment has been completed, DfE prepares a report to inform stakeholders, the public and decision makers. The report provides contextual and supplemental information designed to aid in decision-making and may include descriptions of manufacturing processes, use patterns, and life-cycle stages that may pose special exposure concerns. The report may contain a description of the cost of use and the potential economic impacts associated with the selection of alternatives and may also contain information on alternative technologies that might result in safer chemicals, manufacturing processes and practices.
STEP 7: APPLY THE RESULTS IN DECISION MAKING FOR SAFER CHEMICAL SUBSTITUTES
The DfE alternatives assessment combines: functionality (step 4), hazard assessment (step 5), economic and life cycle considerations (step 6) to facilitate decision-making by industry and others (step 7). One organization has developed tools for choosing safer chemicals based on the alternatives assessment methodology (see "more information" below).
How can I get more information?
For more information about alternatives assessments and choosing safer chemical substitutes, DfE recommends the following resources:
- Chemical Alternatives Assessments: Enabling Substitution to Safer Chemicals. Lavoie et al. Environmental Science and Technology Article ASAP. Nov. 9, 2010.
This Feature article in the journal Environmental Science and Technology, explains DfE's approach to alternatives assessment, the steps in the process and examples of application of this assessment method.
- Alternatives Assessment Framework from the Lowell Center for Sustainable Production (PDF)
(24 pp, 381K)
The Lowell Center for Sustainable Production created this Framework in 2006 as a first step in defining the methodology for identifying and evaluating safer alternatives.
- Alternatives Assessments conducted by states from Massachusetts Toxics Use Reduction Institute
Massachusetts Toxics Use Reduction Institute created this database to enable the exchange of information and resources between state pollution prevention providers and regulatory agency representatives.
- DfE Criteria for Safer Chemical Ingredients and DfE Standard for Safer Cleaning Products
These documents define by component class the characteristics and toxicity thresholds for ingredients that are acceptable in DfE-labeled products.
This database of safer chemicals supports DfE's Safer Product Labeling Program by providing a list of chemicals, arranged by component class, that meet the DfE Criteria.
- Green Screen for Safer Chemicals
Developed by Clean Production Action, an environmental non-governmental organization, the Green Screen complements the DfE Alternatives Assessment methodology. The Green Screen is designed to aid in the selection of safer alternative chemicals.
- Current Landscape of Alternatives Assessment Practice
The OECD Ad Hoc Group on Substitution of Harmful Chemicals developed a “meta review” of current alternatives assessment practices, to support the evaluation of alternatives when safer substitutes to chemicals of concern are sought.
- OECD Substitution and Alternatives Assessment Toolbox
This toolbox is a compilation of resources relevant to chemical substitution and alternatives assessments. The toolbox includes a range of resources where you can learn more about chemical substitution and alternatives assessments and get practical guidance on conducting them.
BizNGO for Safer Chemicals and Sustainable Materials
BizNGO, a non-profit environmental organization spearheaded by Clean Production Action, has developed tools and principles to help inform businesses on how to replace toxic chemicals with safer alternatives.
BizNGO Chemical Alternatives Assessment Protocol
BizNGO has developed a decision framework for substituting problematic chemicals to human health or the environment with safer alternatives.
Top DfE Questions
What's New with DfE?
June 12, 2014 – EPA, through DfE, issued:
- Final DfE Alternatives Assessment for Hexabromocyclododecane (HBCD) (PDF) (230pp, 1.76MB) that evaluates and compares potential hazards associated with HBCD and three alternatives. Read more.
- Draft update of a previous alternative assessment on flame retardants used in flexible polyurethane foam (PDF) (840pp, 8.05MB), which will be available for public review and comment until August 11, 2014. Please submit comments to Docket No. EPA-HQ-2014-0389 via www.regulations.gov. Read more.
- Q. & A. Consumer Fact Sheet on Flame Retardants
January 29, 2014 -- EPA issued final DfE alternatives assessments for DecaBDE and BPA.
- The Flame Retardant Alternatives Assessment for Decabromodiphenyl Ether (DecaBDE) (PDF) (901pp, 10.84MB) evaluates and compares potential hazards associated with decaBDE and 29 alternatives. Read more.
- The Alternatives Assessment for Bisphenol A (BPA) in Thermal Paper (PDF) (519pp, 3.72MB) evaluates and compares potential hazards associated with BPA in thermal paper and 19 alternatives. Read more.
January 23, 2014 -- EPA updated DfE’s Safer Chemical Ingredients List (SCIL), adding 50 chemicals – bringing the number of safer fragrance chemicals to 150 and the total number of safer chemicals to nearly 650.