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From Reaction to Prevention: Ensuring that TSCA Reform and Other
Chemicals Policies Stimulate the Transition Towards Safer and More
Sustainable Chemicals
From Reaction to Prevention: Ensuring that TSCA Reform and Other
Chemicals Policies Stimulate the Transition Towards Safer and More
Sustainable Chemicals
Joel A. Tickner, ScD
University of Massachusetts Lowell
www.chemicalspolicy.org
www.greenchemistryandcommerce.org
ABA Spring Conference on the Environment, June, 11, 2010
Joel A. Tickner, ScD
University of Massachusetts Lowell
www.chemicalspolicy.org
www.greenchemistryandcommerce.org
ABA Spring Conference on the Environment, June, 11, 2010
OverviewOverview
Green Chemistry and safer alternatives in TSCA reform
Current EPA actions Barriers to green chemistry and safer alternatives
programs Precursors to advancing green chemistry and
safer products Policy options to advance this area
Green Chemistry and safer alternatives in TSCA reform
Current EPA actions Barriers to green chemistry and safer alternatives
programs Precursors to advancing green chemistry and
safer products Policy options to advance this area
Goals of TSCA reformGoals of TSCA reform
POLICY.—It is the policy of the United States—
‘‘(1) to protect the health of children, workers, consumers, and the public, and to protect the environment from harmful exposures to chemical substances and mixtures;
‘‘(2) to promote the use of safer alternatives and other actions that reduce use of and exposure to hazardous chemical substances and reward innovation toward safer chemicals, processes, and products;
POLICY.—It is the policy of the United States—
‘‘(1) to protect the health of children, workers, consumers, and the public, and to protect the environment from harmful exposures to chemical substances and mixtures;
‘‘(2) to promote the use of safer alternatives and other actions that reduce use of and exposure to hazardous chemical substances and reward innovation toward safer chemicals, processes, and products;
Green Chemistry and Safer Alternatives in TSCA reformGreen Chemistry and Safer Alternatives in TSCA reform
Section 32 Safer Alternatives and Green Chemistry• Safer Alternatives Program
• Create program to establish market incentives– Expedited review for new safer chemcials
– Recognition programs
– Other Incentives
• Green Chemistry Research Network (4 centers to explore alternatives to priority substances)
• Green Chemistry Research Grants
• Green Chemistry Workforce Development
Section 32 Safer Alternatives and Green Chemistry• Safer Alternatives Program
• Create program to establish market incentives– Expedited review for new safer chemcials
– Recognition programs
– Other Incentives
• Green Chemistry Research Network (4 centers to explore alternatives to priority substances)
• Green Chemistry Research Grants
• Green Chemistry Workforce Development
Why focus on Green Chemistry and Safer Alternatives and green chemistry in chemicals policy reforms?
Why focus on Green Chemistry and Safer Alternatives and green chemistry in chemicals policy reforms?
New understandings chemical uses, hazards, and prevention
Focus on innovation and economic development to solve problems rather than “stopping bads”
Focus on entire chemical lifecycle and “history” of chemicals – manufacture, use, and disposal
Helps to avoid trade-offs along lifecycles Detailed chemical by chemical assessment is
costly, does not prevent impacts on its own and is not innovation generating
New understandings chemical uses, hazards, and prevention
Focus on innovation and economic development to solve problems rather than “stopping bads”
Focus on entire chemical lifecycle and “history” of chemicals – manufacture, use, and disposal
Helps to avoid trade-offs along lifecycles Detailed chemical by chemical assessment is
costly, does not prevent impacts on its own and is not innovation generating
Evolving Chemicals KnowledgeEvolving Chemicals Knowledge
From Large Industrial Emissions…• Point sources, facility specific, media specific
(air, water, waste)• Few identified chemicals of concern• Policy tools: End-of-pipe controls, permitting,
monitoring, risk-based standards
To a Broad Range of Product-Based Emissions.
• Smaller, disperse, non-point, difficult to control, different toxicological mechanisms
• Many identified chemicals of concern and impacts throughout lifecycles “embedded hazards”
• Policy tools: Redesign, green chemistry, substitution, safer alternatives
From Large Industrial Emissions…• Point sources, facility specific, media specific
(air, water, waste)• Few identified chemicals of concern• Policy tools: End-of-pipe controls, permitting,
monitoring, risk-based standards
To a Broad Range of Product-Based Emissions.
• Smaller, disperse, non-point, difficult to control, different toxicological mechanisms
• Many identified chemicals of concern and impacts throughout lifecycles “embedded hazards”
• Policy tools: Redesign, green chemistry, substitution, safer alternatives
Current EPA initiatives on green chemistry and safer alternativesCurrent EPA initiatives on green chemistry and safer alternatives
Green chemistry• Presidential Green Chemistry Awards
• Green Chemistry support in new chemical design• Sustainable Futures and other design tools
Pollution prevention• Hospitals for a Healthy Environment
• Green Suppliers
Design for Environment• Formulators initiative
• Alternatives assessment – informed substitution
• Partnership programs
Green chemistry• Presidential Green Chemistry Awards
• Green Chemistry support in new chemical design• Sustainable Futures and other design tools
Pollution prevention• Hospitals for a Healthy Environment
• Green Suppliers
Design for Environment• Formulators initiative
• Alternatives assessment – informed substitution
• Partnership programs
Past EPA initiatives on Green Chemistry and Safer AlternativesPast EPA initiatives on Green Chemistry and Safer Alternatives
Cleaner Technologies Substitute Assessments Use Cluster Scoring System Product Side of Pollution Prevention/Sector
Notebooks ORD Green chemistry research grants
Cleaner Technologies Substitute Assessments Use Cluster Scoring System Product Side of Pollution Prevention/Sector
Notebooks ORD Green chemistry research grants
Actions not consistent with goals: Why are safer alternatives and prevention not prioritized in government programs?
Actions not consistent with goals: Why are safer alternatives and prevention not prioritized in government programs? Limited funding Lack of regulatory requirements Knowledge first culture
• Preoccupation with “problem-sphere” research
• Large commitment to detailed mechanistic knowledge on each chemical - eg. BPA
Institutional barriers• Lack of infrastructure
• Lack of commitment (does prevention “sell”?)
Doesn’t neatly fit a particular jurisdictional or departmental boundary• Chemical issues cross agency boundaries
Limited funding Lack of regulatory requirements Knowledge first culture
• Preoccupation with “problem-sphere” research
• Large commitment to detailed mechanistic knowledge on each chemical - eg. BPA
Institutional barriers• Lack of infrastructure
• Lack of commitment (does prevention “sell”?)
Doesn’t neatly fit a particular jurisdictional or departmental boundary• Chemical issues cross agency boundaries
Barriers to Green Chemistry and safer alternatives at numerous levelsBarriers to Green Chemistry and safer alternatives at numerous levels Data
• Lack of data on chemical toxicity, uses, product ingredients
• Lack of good supply chain information flows• How is safer defined? • Prioritization of 1000s of chemicals and hundreds of
uses
Implementation• Technical barriers that can compromise performance• Lack of cost-effective or viable alternatives• Lack of good incentives/disincentives• Poorly designed regulatory structures can work against
implementation
Data• Lack of data on chemical toxicity, uses, product
ingredients• Lack of good supply chain information flows• How is safer defined? • Prioritization of 1000s of chemicals and hundreds of
uses
Implementation• Technical barriers that can compromise performance• Lack of cost-effective or viable alternatives• Lack of good incentives/disincentives• Poorly designed regulatory structures can work against
implementation
The Need for Green ChemistryThe Need for Green Chemistry
10% of chemicals in production are low hazard10% of chemicals in production are low hazard
25% of hazardous production chemicals 25% of hazardous production chemicals could be substituted with currently could be substituted with currently available, low hazard substitutesavailable, low hazard substitutes
65% of hazardous production chemicals 65% of hazardous production chemicals have no currently available low hazard have no currently available low hazard substitutessubstitutes
Reference: John Warner, Reference: John Warner, Warner,-Babcock InstituteWarner,-Babcock Institute
Barriers to Green Chemistry and safer alternatives at numerous levelsBarriers to Green Chemistry and safer alternatives at numerous levels Institutional
• Designers rule – cost, performance first• Technology lock-in• Lack of technical or science capacity in firms,
particularly SMEs• Costs of more dangerous chemicals and products not
internalized• Little incentive to change, little recognition or
investment
Educational• Chemists not trained in toxicology• Designers not taught about environment and health• Science of problems separated from science of
solutions
Institutional• Designers rule – cost, performance first• Technology lock-in• Lack of technical or science capacity in firms,
particularly SMEs• Costs of more dangerous chemicals and products not
internalized• Little incentive to change, little recognition or
investment
Educational• Chemists not trained in toxicology• Designers not taught about environment and health• Science of problems separated from science of
solutions
What are prerequisites for a transition to Green Chemistry and safer alternativesWhat are prerequisites for a transition to Green Chemistry and safer alternatives
Leadership and commitment Clear definitions and metrics Good information on chemical uses, hazards, and
potential exposures Tools to rapidly and thoughtfully compare
alternative chemicals, processes, and products Policies that incentivize safer chemicals and
disincentivize more problematic ones – requirements to explore and seek alternatives
KEY: RECOGNIZE DIFFERENT NEEDS AND MOTIVATIONS OF DIFFERENT ACTORS ALONG SUPPLY CHAINS
Leadership and commitment Clear definitions and metrics Good information on chemical uses, hazards, and
potential exposures Tools to rapidly and thoughtfully compare
alternative chemicals, processes, and products Policies that incentivize safer chemicals and
disincentivize more problematic ones – requirements to explore and seek alternatives
KEY: RECOGNIZE DIFFERENT NEEDS AND MOTIVATIONS OF DIFFERENT ACTORS ALONG SUPPLY CHAINS
Green ChemistryGreen Chemistry
Definition:
“Green chemistry is the utilization of a set of principles that reduces or eliminates the use or generation of hazardous substances in the design, manufacture and application of chemical products.”
-Anastas and Warner, Green Chemistry: Theory and Practice, 1998
Definition:
“Green chemistry is the utilization of a set of principles that reduces or eliminates the use or generation of hazardous substances in the design, manufacture and application of chemical products.”
-Anastas and Warner, Green Chemistry: Theory and Practice, 1998
Learning from the States: Massachusetts Toxics Use Reduction ProgramLearning from the States: Massachusetts Toxics Use Reduction Program
Understand function and use of chemicals Examine alternatives Innovation and technical support Measure progress and re-evaluate Results: 1990-2000
• 60% reduction in waste• 40% reduction in use• 80% reduction in emissions
Benefits to industry $15 million (not considering health/environmental benefits)
Understand function and use of chemicals Examine alternatives Innovation and technical support Measure progress and re-evaluate Results: 1990-2000
• 60% reduction in waste• 40% reduction in use• 80% reduction in emissions
Benefits to industry $15 million (not considering health/environmental benefits)
MA TCE Cleaning Use Data
0
0.5
1
1.5
2
2.5
1990 1996 2001 2002
millions of pounds
The Result of the MA Toxics Use Reduction Planning and Technical Support Process
The Precursors to ChangeThe Precursors to Change
Willingness(motivation, compliance, fear, courage, commitment)
Opportunity(awareness, interest, learning, access, timing)
Capacity(resources, intelligence, knowledge, assistance)
Willingness(motivation, compliance, fear, courage, commitment)
Opportunity(awareness, interest, learning, access, timing)
Capacity(resources, intelligence, knowledge, assistance)
Policy options to strengthen Green Chemistry and safer alternatives effortsPolicy options to strengthen Green Chemistry and safer alternatives efforts
Information options• Establish a list of chemicals and chemical
categories of concern – those that should be avoided
• Establish a database of safer alternatives to chemicals of concern for users
• Issue clear guidance for chemical manufacturers and users on safer chemical design – list of “greener chemicals”
Information options• Establish a list of chemicals and chemical
categories of concern – those that should be avoided
• Establish a database of safer alternatives to chemicals of concern for users
• Issue clear guidance for chemical manufacturers and users on safer chemical design – list of “greener chemicals”
Policy options to strengthen Green Chemistry and safer alternatives effortsPolicy options to strengthen Green Chemistry and safer alternatives efforts
Safer alternatives review requirements• Establish a functional use-based prioritization and
management program
• Create requirements for firms manufacturing or using chemicals of concern to explore alternatives (substitutes analysis)
• Require that chemical risk assessments include an alternatives assessment component
• Green chemistry/safer alternatives challenge programs for high concern chemicals
Safer alternatives review requirements• Establish a functional use-based prioritization and
management program
• Create requirements for firms manufacturing or using chemicals of concern to explore alternatives (substitutes analysis)
• Require that chemical risk assessments include an alternatives assessment component
• Green chemistry/safer alternatives challenge programs for high concern chemicals
Policy options to strengthen Green Chemistry and safer alternatives effortsPolicy options to strengthen Green Chemistry and safer alternatives efforts
Creating green chemistry/safer alternatives Incentives• Partnership and research programs
• Procurement of safer chemicals and products
• Technical and networking support
• Establish pre-competitive consortia for green chemistry/DfE challenges
• Support state/regional green chemistry/safer alternatives technical support centers
Creating green chemistry/safer alternatives Incentives• Partnership and research programs
• Procurement of safer chemicals and products
• Technical and networking support
• Establish pre-competitive consortia for green chemistry/DfE challenges
• Support state/regional green chemistry/safer alternatives technical support centers
Policy options to strengthen Green Chemistry and safer alternatives effortsPolicy options to strengthen Green Chemistry and safer alternatives efforts
Education and research• Promote college and K-12 courses in green
chemistry
• Provide scholarships and graduate student research and internship support
• Tie research funding to green chemistry R&D
Supportive Policy• Develop adequate fees to fund safer alternatives
and green chemistry efforts (% of money from fees, fines, etc)
• Develop enforcement programs focused on green chemistry and safer alternatives
Education and research• Promote college and K-12 courses in green
chemistry
• Provide scholarships and graduate student research and internship support
• Tie research funding to green chemistry R&D
Supportive Policy• Develop adequate fees to fund safer alternatives
and green chemistry efforts (% of money from fees, fines, etc)
• Develop enforcement programs focused on green chemistry and safer alternatives
Take a comprehensive, integrated approach to all chemicals and impacts through lifecycles
Ensure adequate data collection and dissemination providing open access to information.
Establish processes that allow rapid chemical assessment, prioritization, and decision-making
Maximize information sharing and responsibility through supply chains
Establish processes to transition from more dangerous chemicals to safer alternatives
Promote green chemistry and safer product design, by promoting research and innovation
Take a comprehensive, integrated approach to all chemicals and impacts through lifecycles
Ensure adequate data collection and dissemination providing open access to information.
Establish processes that allow rapid chemical assessment, prioritization, and decision-making
Maximize information sharing and responsibility through supply chains
Establish processes to transition from more dangerous chemicals to safer alternatives
Promote green chemistry and safer product design, by promoting research and innovation
But TSCA reform isn’t enough: Need for Comprehensive Chemicals Policy
Moving towards comprehensive chemicals policyMoving towards comprehensive chemicals policy
Establish interagency taskforce on Safer Chemicals and Green Chemistry
Create new administrative structures that focus on all chemicals across jurisdictions and all phases of the lifecycle – a “chemicals agency?”
Marry environment and health protection aspects of green chemistry with economic, jobs and innovation.
Establish new science of green chemistry and safer alternatives assessment
Establish interagency taskforce on Safer Chemicals and Green Chemistry
Create new administrative structures that focus on all chemicals across jurisdictions and all phases of the lifecycle – a “chemicals agency?”
Marry environment and health protection aspects of green chemistry with economic, jobs and innovation.
Establish new science of green chemistry and safer alternatives assessment
ConclusionsConclusions If advancing green chemistry and safer
alternatives is a goal of TSCA reform then there must be a resource and regulatory commitment to make that happen.
While we still need research and data development on chemical hazards, we need significantly more research and action on chemical alternatives and how they can be implemented in practice
TSCA reform is a critical but insufficient step to advancing implementation of green chemistry and safer alternatives. A more comprehensive approach is needed.
Safer chemistry is not only an environment and health issue but also an economic one.
If advancing green chemistry and safer alternatives is a goal of TSCA reform then there must be a resource and regulatory commitment to make that happen.
While we still need research and data development on chemical hazards, we need significantly more research and action on chemical alternatives and how they can be implemented in practice
TSCA reform is a critical but insufficient step to advancing implementation of green chemistry and safer alternatives. A more comprehensive approach is needed.
Safer chemistry is not only an environment and health issue but also an economic one.
• “The ultimate facts here in dispute are on the frontiers of scientific knowledge and though the factual finger points, it does not conclude. Under the command of OSHA, it remains the duty of the Secretary to protect the working-man, and to act even in circumstances where existing methodology or research is deficient…. We wish to emphasize, the Secretary is not restricted by the status quo. He may raise standards which require improvements in existing technologies or which require the development of new technology and he is not limited to issuing standards based solely on devices already fully developed ”
• 2nd Circuit Court of Appeals, The Society of the Plastics Industry, Inc., v. Occupational Safety and Health Administration, 1975
