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Chemical Alternatives Assessment

The premise behind chemical alternatives assessment (CAA) is that because risk is a function of hazard and exposure, focusing on hazard reduction is an effective way to mitigate risk. By assessing chemicals of potential concern and their functional alternatives with respect to their effects on the environment and human health, CAA enables the substitution of safer chemicals.[139] Information gained through CAA can be used by decision-makers in combination with analyses of cost, performance, and other factors to select safer chemical and material alternatives.

CAA compares alternative chemicals within the same functional-use group across a consistent and comprehensive set of hazard endpoints. CAAs may also consider intrinsic properties of chemical substitutes that affect exposure potential, including absorption potential, persistence, and bioaccumulation. This approach to alternatives assessment orients chemical evaluations within a given product type and functionality. Factors related to exposure scenarios, such as physical form and route of exposure are generally constant within a given functional use group and would fall out of the comparison. Thus, the health and environmental profiles in the alternatives assessments become the key variable and source of distinguishing characteristics.

Chemical Alternatives Assessment

How can Chemical Alternatives Assessment contribute to Sustainability?

Industry, non-governmental organizations, and governments are working to identify safer and more sustainable chemical alternatives.[140, 141] CAA can guide the selection of safer alternatives. It also can be used in combination with other tools such as risk assessment or life-cycle assessment to better inform decisions about chemical substitutions.

The intent of CAA is to better inform decisions about chemical and material substances, avoiding unintended or undesired social, environmental, and economic impacts. EPA's DfE is a prominent example of how CAA can be used to promote sustainable decision-making.[142] DfE’s Furniture Flame Retardancy Partnership, a collaborative initiative among the furniture industry, chemical manufacturers, environmental groups and EPA, provides information that has supported the transition to safer alternatives for flame retardants.

What are the main steps in a Chemical Alternatives Assessment?

The methodology for CAA can be summarized in the following six broad steps:[139, 143]

  • Step 1—identify chemicals that warrant evaluation and possible replacement. These may be chemicals that are slated for regulation, that have attracted the attention of stakeholders, or that otherwise have been identified as needing replacement;
  • Step 2—gather information to identify and understand potential alternatives in the chemical’s functional use class. This step includes determining how well alternatives are characterized; how the alternatives compare on structural, functional, and physical properties; and, how the alternatives are manufactured;
  • Step 3—engage stakeholders to help define the scope of the CAA; monitor its implementation; and, implement the transition to safer chemicals. Involvement throughout the project helps to ensure that stakeholders understand and support the outcome; this both enhances the project’s credibility and utility and promotes further adoption of the safer alternatives. Stakeholders include organizations involved throughout the life-cycle of the chemical and alternatives in question: chemical manufacturers, product manufacturers throughout the supply chain, retailers, non-governmental organizations, government agencies, academics, end users, and waste management entities; [144]
  • Step 4—conduct comparative chemical hazard assessment using a robust list of hazard endpoints taken from the Organization for Economic Cooperation and Development (OECD) Screening Information Data Set, science-based thresholds based on criteria developed by the EPA’s New Chemicals Program and Office of Pesticide Programs, and from the United Nation’s Globally Harmonized System for Classification and Labeling of Chemicals;[145, 146]
  • Step 5—report information and data summary for each alternative so that decision-makers can make informed substitution decisions; and,
  • Step 6—apply information to aid stakeholders’ decisions about alternatives when combined with cost, performance, and other factors.

CAAs conducted through DfE combine information from five sources, generally in this order of preference: (1) publicly available empirical data; (2) confidential empirical data received by EPA under Toxic Substances Control Act regulations; (3) analogs and structure activity relationship based estimations; (4) expert judgment of EPA staff; and, (5) confidential empirical data on experimental studies supplied by the chemical manufacturers for the alternatives assessment. The information gathered assists in preparing the assessment report, which includes a detailed discussion of the relevant products, materials, and technologies for the functional use category; narrative and tabular summaries of the CAA; a discussion of general exposure and life-cycle considerations; and, a summary of the environmental, health, technical, economic, and social considerations to be taken into account during the decision-making process. The CAA report may also contain information on alternative technologies that might influence manufacturing practices.

In the context of DfE, CAAs are guided by seven principles to ensure their value and utility. First, alternatives must be commercially available or likely to become available; and, second, they must be technologically feasible. Under these first two principles, an alternative would satisfy the same functional use as the chemical it is replacing. DfE also recognizes that, in some cases, the best alternative may not be a chemical substitution. For example, an alternative such as an inherently flame retardant material or a barrier may present a preferable human health and environmental profile than an alternative flame retardant chemical. Third, an alternative should deliver comparable value in cost and performance as the material it is replacing. Fourth, alternatives should have an improved health and environmental profile, as demonstrated by the CAA, to demonstrate the benefits of substitution. Fifth, the analysis of the alternatives should consider relevant economic and social factors; and, sixth, stakeholders should participate in the CAA process. Finally, the alternatives should have the potential to result in lasting change. These principles are integrated into the six steps of CAA methodology outlined above.

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What are the strengths and limits of Chemical Alternatives Assessment in a sustainability context?

CAA focuses on finding highly-functional, safer, alternative chemicals that industry can use to solve environmental problems by replacing hazardous chemicals, rather than characterizing the magnitude of the problem associated with using such chemicals. In addition to identifying functional alternatives that are inherently safer, CAA considers associated trade-offs to minimize the potential for unintended impacts. The goals of CAA are to promote technological innovation and risk prevention, and to suggest feasible options to reduce risks that can be difficult to quantify. For example, rather than attempting to quantify the risks of certain solvents, CAA would examine the availability of safer solvents or solvent alternatives, or suggest alternative processing strategies to avoid the initial risk altogether.[147]

Obtaining comprehensive test data to conduct a CAA may be challenging as the data may not exist or may be unavailable for public use. While the EPA is compiling better test data on the most commonly used chemicals through the High Production Volume Challenge Program, robust test data on chemical hazards are still incomplete.[148]

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How are Chemical Alternatives Assessments used to support EPA decision-making?

Within the Agency, CAAs are conducted in the Design for the Environment partnership program. DfE applies this methodology to EPA priority chemicals, characterizing hazard based on a full range of human health and environmental information, including primary data sources and expert predictive models. Examples of CAAs completed by DfE include studies on flame retardants in furniture and printed circuit boards. DFE is currently performing CAAs for bisphenol A alternatives in thermal paper, the flame retardant chemical decabromodiphenylether, hexabromocyclododecane in expandable and extruded polystyrene foam for insulation, and nonylphenol ethoxylate surfactants.[41, 144, 149-151]

The outcome of a CAA provides industry and other stakeholders with information they need to choose safer chemicals and minimize the potential for unintended impacts, such as those that result from switching to a poorly understood (and potentially more hazardous) substitute. CAAs do not themselves specify a favored alternative. For some substitution challenges, the outcome of a CAA can provide a full basis for chemical selection. In other cases, CAAs are used in policymaking in conjunction with other economic and environmental assessments.

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Where can I find more about Chemical Alternatives Assessment?

  • EPA’s Design for the Environment Program website provides further information on CAA, including completed and ongoing analyses.
  • DfE staff, in collaboration with non-governmental organizations (NGOs) and industry, published a feature article in Environmental Science and Technology on DfE’s approach to CAA Exit EPA Disclaimer.
  • The Lowell Center for Sustainable Production’s “Alternatives Assessment Framework (PDF)(24 pp, 381K) Exit EPA Disclaimer describes the Center’s approach to CAA.
  • Clean Production Action’s GreenScreen™ Exit EPA Disclaimer for Safer Chemicals is a free, fully transparent and publicly accessible tool for identifying substances that are inherently less hazardous for humans and the environment.
  • The BizNGO Working Group for Safer Chemicals and Sustainable Materials is developing a Chemical Alternatives Assessment Protocol Exit EPA Disclaimer as a primer for businesses and other practitioners of CAAs.
  • Washington State Department of Ecology is developing guidance on alternatives assessments for businesses. For more information, please visit their website.
  • Washington State Department of Ecology’s Alternatives Assessment for decabromodiphenylether in Televisions and Computers and Residential Upholstered Furniture is available online.

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Illustrative Example of an Approach using Chemical Alternative Assessment

  • EPA Design for the Environment

    Source: EPA Office of Chemical Safety and Pollution Prevention [257]
    Suite of sustainability tools: chemical alternative assessment; green chemistry; collaborative problem-solving; life-cycle assessment; risk assessment
    EPA’s Design for the Environment (DfE) Partnership Program helps consumers, businesses, and institutional buyers identify products that perform well and are cost-effective, but are safer for human health and the environment. [257] This program promotes sustainability by working with small businesses and consumers to identify risks involved with chemicals used in products or manufacturing processes. Chemical Alternatives Assessment is a key analytic tool for the implementation of DfE. It is a tool for evaluating chemicals of potential concern by comparing alternative chemicals within the same functional-use group across a consistent and comprehensive set of hazard endpoints. Other analytic tools that are instrumental for the conduct of this program include risk assessment and life-cycle assessment. Through the DfE, EPA collaborates with industry, environmental groups and universities to decrease health and environmental risk by encouraging green design and reformulation of a wide range of products while maintaining their effectiveness. As more consumers seek sustainable products that are designed to have minimal impact on the environment and their health, an environmental “seal of approval” could help consumers select products that match their values.[258

    DfE offers that “seal of approval” by awarding use of the logo on products that meet environmental design criteria. The logo assures consumers that the DfE scientific review team has screened each ingredient for potential human health and environmental effects and that—based on currently available information, EPA predictive models, and expert judgment—the product contains only those ingredients that pose the least concern among chemicals in their class. Products are also expected to meet effectiveness criteria, i.e., glass cleaners must meet criteria for effective glass cleaning. To obtain the DfE recognition, ingredients in the formulation must be publically disclosed (with the exception of specific allowances for trade secret ingredients). EPA also offers the DfE label to partnering companies that design or reformulate high-performance and cost-effective products using the safest ingredients.[258]

    The screening process (PDF) (43 pp, 726K) for the DfE logo is detailed and comprehensive. DfE scrutinizes ingredients, starting with known toxicity information and performing an inherent property analysis when toxicity information is not available. With inherent property analysis, scientists estimate toxicity for a chemical ingredient without toxicity information using available toxicity information for a chemical with similar structure. Strong structural similarities to a chemical with high environmental or health toxicity would be a flag for concern.

    DfE sets specific standards for chemicals of known toxicity. For example, DfE will not recognize products that contain any pollutants on the Hazardous Air Pollutants list. Furthermore, DfE will not recognize products that contain chemicals on the EPA Toxics Release Inventory chemical list unless they meet stringent DfE criteria.

    This program fosters sustainability in a cost-effective way that benefits companies, consumers, and environmental and public health. Through such partnerships and education, EPA is helping businesses and consumers select safer chemicals and technologies, thereby reducing the number of potentially hazardous chemicals in use.

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