Infusing TSCA with Green Chemistry: Infusing TSCA with Green Chemistry: The Role of Innovation in Chemical Risk The Role of Innovation in Chemical Risk
ManagementManagement
Dr. Kira Matus
Senior Policy AnalystCenter for Green Chemistry and Green EngineeringYale University
June 11, 2010
Green chemistry is the design of chemical products and processes that reduce or eliminate the use and generation of hazardous substances.
• Anastas, P. T. and Warner, J. C. Green Chemistry: Theory and Practice, Oxford University Press: New York, 2000.
• Prevent use and/or generation of hazardous chemicals
• Chemistry for sustainability• “Benign by design”• Pollution prevention at the molecular level, NOT
waste remediation or pollutant detection
Provide a framework for design of new materials, products, and processes.
Focused on sustainable design criteria Proven time and again to be the source of innovative
solutions to a wide range of problems Systematic integration of these principles is key to
achieving genuine sustainability for the simultaneous benefit of the environment, economy, and society.
• Anastas, P. T. and Warner, J. C. Green Chemistry: Theory and Practice, Oxford University Press: New York, 2000.
1. Prevention2. Atom Economy3. Less Hazardous Chemical Syntheses4. Designing Safer Chemicals5. Safer Solvents and Auxiliaries6. Design for Energy Efficiency7. Use of Renewable Feedstocks8. Reduce Derivatives9. Catalysis10. Design for Degradation11. Real-time Analysis for Pollution Prevention12. Inherently Safer Chemistry for Accident Prevention
• Molecular Design
• Life-Cycle Thinking:• Anticipate potential impacts• Consider entire process, from input materials
through end-of-life
• Interdisciplinary• Chemistry• Environmental Science• Toxicology• Engineering• Economics
Get it right the first timeGet it right the first time
What role should green chemistry and green engineering play in a reformed TSCA?
Key Questions about TSCA Reform to Develop a GC&E Strategy
What are the drivers behind the movement for TSCA reform?
What are the goals of a “reformed TSCA”? What are the key lessons from the last 30 years of TSCA
in practice? What does it take to construct an adaptive, flexible,
resilient chemicals policy? How can, or should, “reformed TSCA” impact
innovation? How can green chemistry and green engineering be
critical parts of resilient, forward-looking chemical risk management, and how should they be built into the regulatory system?
◦ Must not stifle innovation generally with unnecessary resource burdens, and
◦ Should favor innovations that improve safety and reduce environmental impacts.
Adoption of an anticipatory, preventative approach to chemicals management based on inherent hazards
Mechanisms and incentives to provide financial, technical and policy support for GC&E innovation
Incentives for GC&E in any review process Continuous improvement
• No explicit inclusion of green chemistry• Registration exemption (pre-1976) favors older,
existing technologies• No minimum health and safety data
requirements• Difficult to compel testing• CBI – limitations on data availability
“SAFER ALTERNATIVES AND GREEN CHEMISTRY AND ENGINEERING”
• National GC research centers• GC research grants• GC workforce education and training• Incentives:
• Expedited review for safer alternatives• Labels for safer alternatives• Awards and incentives for safer
alternatives
Incentives are to fix problems once they occur◦ Efficient?◦ What does this mean for health of people and the
environment?◦ Is this even feasible?
•Technical•Regulatory•Economic•Cultural•Organizational•Definition and Metrics
TSCA reform is an TSCA reform is an opportunityopportunity to to reduce barriersreduce barriers
Start to think PROACTIVELYPROACTIVELY
• Data• Incentives• Awareness• Collaboration• Prevention
• Hazard Reduction• Forward-looking• Continuous Improvement
Increase the availability of more benign chemicals => reduce the overall TSCA workload
Encourage the development of advanced life cycle assessment and modeling tools
Contribute to fundamental solutions that are robust over the long term
Make use of GC to evaluate health, safety, and environmental impacts
◦ Authority to compel submission of green
chemistry metrics as part of its data required for chemical evaluations.
◦ Program for public reporting of green chemistry information submitted by firms
◦ Use submitted green chemistry data as a baseline for determination of “greener alternatives”
Create incentives for better performance on health, safety, and environmental criteria, and/or to switch to less hazardous alternatives.
◦ Establish and consistently enforce standards for manufacture and use of hazardous chemicals.
◦ Design preferential pre-manufacture notice timelines and information requirements
◦ Positive incentive mechanisms
Use information collected by the EPA to help drive GC forward.◦ Accumulate data on impacts, and deploy it to
help develop tools to improve the design and analysis of chemicals (i.e. systems to aid with molecular design, information for use in LCA, etc…)
◦ Act as a center for the communication of information regarding impacts of chemicals in use and potential alternatives.
Implement a coordinated, inter-agency R&D fund overseen by a variety of agencies
◦ Basic R&D funding for major, pre-competitive platforms and technologies in priority chemical sectors
◦ Large scale funding (like DARPA, DOE) to help green innovations in key areas transition from the laboratory to full-scale industrial use
Recognize and support state-level programs
◦ Education◦ R&D◦ Technical outreach programs for small and
medium sized firms
Recognize and broaden Design for the Environment (DfE) and other cooperative programs between industry and government.
• TSCA is just one piece of the puzzle• Other chemical regulation (federal)• International perspective (i.e. REACH)• Green Chemistry specific regulation• State level programs
Use GC as a powerful tool to develop the next generation of chemical innovations
More efficient to design chemicals to be as benign as possible from the outset,
Eliminate the need to develop safer alternatives
GC is a market-oriented, economically favorable, preventative approach ◦ Act in advance of impacts
Enhance the broader sustainability of the chemical enterprise in the United States.
Dr. Julie B Zimmerman Dr. Evan Beach Erin McBurney
Workshop ParticipantsCharles AuerKlaus Berend, Blake BilesGregory BondWilliam ClarkJoseph FikselBob IsraelWarren MuirTom OsimitzMichael ParrJohn Wargo Jeffrey WongJim Young