In January the Interstate Chemicals Clearinghouse (IC2), and participating members published a new guide to chemical alternatives assessment. The IC2 Alternatives Assessment Guide is the product of 20 months of effort by the IC2's members and an extensive stakeholder-engagement process. This Guide is a tremendous resource for pollution prevention practitioners.
How does alternatives assessment relate to pollution prevention? There are many answers to this question, but the bottom line can be summarized in two words: regrettable substitution.
Example: The dirty truth about dry cleaning
One example that illustrates this challenge centers on chlorinated dry-cleaning solvents such perchloroethylene ("perc"). The human and environmental health issues related to perc increasingly have been recognized and many states have implemented programs to help dry cleaners transition away from perc.
A drop-in substitute, n-propyl bromide (nPB, also called 1-bromopropane), is a brominated solvent adopted in the 1990s as a substitute for trichloroethylene (TCE) in vapor degreasing and first marketed as a dry-cleaning solvent in 2006 (PDF). At that time, some people thought nPB might be a safer alternative to perc.
Unfortunately, evidence of nPB's deleterious human and environmental health effects has mounted. These include reproductive/developmental toxicity; neurotoxicity; possible if not probable carcinogenicity; and aquatic toxicity.
In 2012, the Massachusetts Toxics Use Reduction Institute conducted an assessment of seven alternatives to perc and found nPB to be the least safe. Recently, the Massachusetts Toxics Use Reduction Act (TURA) Administrative Council voted to add nPB to its Higher Hazard Substances list. Today, nPB hardly looks like a safer alternative to perc. In cases like this, proactive alternatives assessment can help, to prevent substituting one undesirable process chemical or ingredient for another.
Why we need alternatives assessment
Alternatives assessment largely grew out of toxics use reduction programs and P2. Like P2, AA reflects a changing mindset. Those of us who grew up in the long shadow of DDT, PCBs, asbestos, chlorofluorocarbons and other infamous toxics that were marketed as promising and safe are not so apt to assume that a given chemical carries low inherent hazard. That even useful chemicals may possess previously unrecognized hazard traits has entered the public consciousness.
AA is not merely a new perspective. It emphasizes rigorous evaluation of all options on the basis of their inherent hazard, in addition to performance and cost.
In California, the Safer Consumer Products regulations, which took effect in October, will require manufacturers to assess alternatives to specified chemicals of concern and make the results publicly available (although they may be redacted to protect confidential business information).
Recently, California identified the use of the chlorinated flame retardant tris (1,3-dichloro-2-propyl) phosphate in children's foam-padded sleeping products as a priority chemical and is proposing to require manufacturers to evaluate alternatives to TDCPP for this product category. The resulting AAs presumably would question this functional use of flame retardants, not merely the choice of chemical. Asking "Is it necessary?" is a key step in alternatives assessment, as it is in most pollution prevention opportunity assessments.
Companies at the forefront of sustainability have used AA to help satisfy consumer demands; maintain their leadership in the face of an expanding definition of product quality; anticipate and mitigate regulatory and market risk; and reduce costs related to managing hazardous chemicals.
Hewlett-Packard has received considerable attention in recent years for its use of AA and the GreenScreen® for Safer Chemicals as it endeavors to eliminate polyvinyl chloride, phthalates, brominated flame retardants, bisphenol A, perfluorinated compounds and other chemicals of high concern from its products. HP Senior Scientist Paul Mazurkiewicz says of the company's actions, "It only makes sense to replace materials with alternatives that are better with respect to EH&S."
Beyond leaders such as HP, it is difficult to know how many companies already employ AA. One complication is the lack of a standard (e.g., ISO) methodology for AA, as there are for other assessment processes such as life cycle assessment (ISO 14040).
Furthermore, businesses are often reluctant to disclose their internal processes. Consequently, we do not know how widely AA is being applied or whether companies are using similar approaches.
How to learn more about AA
At present, tallying the definitions, protocols and guides to AA is like trying to hit a moving target. An OECD 2013 AA meta-review concluded that the many definitions of AA are more alike than different. While some explicitly refer to chemicals alternatives assessment and others do not, most focus on hazard.
Whether one prefers the term alternatives assessment or chemical alternatives assessment, AA is a practical response to growing concerns about chemical hazards, increasing interest in transparency, and a recognition of the data gaps and uncertainty that remain.
The OECD AA meta-review identified several needs: harmonization of approaches; better data gathering and quality; heightened transparency and sharing of information; and improved accessibility to tools and guidance.
The IC2's AA Guide attempts to address some of these gaps. It is designed to help harmonize states' approaches to conducting AAs. The IC2 recognizes the benefits of consistency, as well as the fact that one approach will not work in all situations. Therefore, the Guide describes three approaches to conducting an AA. These frameworks allow the AA practitioner to decide whether it is more appropriate to evaluate different attributes (e.g., hazard, performance, cost and availability, life cycle impacts, social impacts) sequentially, simultaneously or in combination. They are able to select the framework most applicable to their situation. Even so, the AA Guide cannot encompass all scenarios, nor is it the last word.
The IC2 also has developed the Chemical Hazard Assessment Database, which makes it easier for AA and P2 practitioners to locate existing chemical hazard assessments. This resource currently includes 33 assessments, with more to come in the near future. Our collaboration with non-governmental organizations, consultants and businesses makes these efforts possible.
Alternatives assessment is in its adolescence. It is growing rapidly and is not yet mature. Consequently, many stakeholders are working to shape AA, for a great deal is at stake. P2 practitioners have much to offer in guiding this emerging discipline.
I encourage you to roll up your sleeves and get involved. If good AAs of perc as a dry-cleaning solvent had been available 10 years ago, fewer cleaning operations might today be facing a regrettable substitution and might have made a switch to a safer alternative, such as wet cleaning.
Top image of test tubes by luchschen via Shutterstock