The Architecture of Chemical Alternatives Assessment

Informed substitution of hazardous chemicals through the lens of California's Safer Consumer Products Alternatives Analysis: Best practices, challenges, and opportunities

California adopted the Safer Consumer Products (SCP) regulations in 2013, which mandate that companies that manufacture specific products containing designated chemicals of concern complete an Alternatives Analysis. Alternatives Analysis is a process to avoid regrettable substitution by identifying, comparing, and selecting safer alternatives based on technical functions, hazards, exposure pathways, life-cycle multimedia impacts, and economic impacts. The SCP Alternatives Analysis builds upon and expands existing frameworks for alternatives assessments (AAs). The aim of this study was to identify practices from AA that facilitate the robust assessment of alternatives and that align with SCP requirements and identify gaps in the practice. We evaluated completed AAs for methods regarding transparency and careful documentation of information sources, data gaps, uncertainty, criteria, and justification for decision-making. The AAs in this review demonstrate some of the challenges in the field. Most AAs have a constrained scope and only consider chemical substitutes rather than a broad array of functional alternatives. Their scopes were also limited in the hazard endpoints that were evaluated. This was most noted with ecotoxicity endpoints, which were generally confined to aquatic toxicity. The majority of AAs do not explicitly explain their decision-making methods or adequately discuss tradeoffs across the adverse impacts. The AAs also lack the analysis in the exposure, life-cycle impacts, and economic impacts that are required in the SCP Alternatives Analysis process. Further, we recommend strategies and research opportunities to address these challenges and strengthen the practice of AAs. Integr Environ Assess Manag 2022;18:1007-1019. © 2021 SETAC.

Enhancing Scientific Support for the Stockholm Convention's Implementation: An Analysis of Policy Needs for Scientific Evidence

The Stockholm Convention is key to addressing the global threats of persistent organic pollutants (POPs) to humanity and the environment. It has been successful in identifying new POPs, but its national implementation remains challenging, particularly by low- and middle-income Parties. Concerted action is needed to assist Parties in implementing the Convention's obligations. This analysis aims to identify and recommend research and scientific support needed for timely implementation of the Convention. We aim this analysis at scientists and experts from a variety of natural and social sciences and from all sectors (academia, civil society, industry, and government institutions), as well as research funding agencies. Further, we provide practical guidance to scientists and experts to promote the visibility and accessibility of their work for the Convention's implementation, followed by recommendations for sustaining scientific support to the Convention. This study is the first of a series on analyzing policy needs for scientific evidence under global governance on chemicals and waste.

Finding essentiality feasible: common questions and misinterpretations concerning the "essential-use" concept

The essential-use concept is a tool that can guide the phase-out of per- and polyfluoroalkyl substances (PFAS) and potentially other substances of concern. This concept is a novel approach to chemicals management that determines whether using substances of concern, such as PFAS, is truly essential for a given functionality. To assess the essentiality of a particular use case, three considerations need to be addressed: (1) the function (chemical, end use and service) that the chemical provides in the use case, (2) whether the function is necessary for health and safety and critical for the functioning of society and (3) if the function is necessary, whether there are viable alternatives for the chemical for this particular use. A few illustrative examples of the three-step process are provided for use cases of PFAS. The essential-use concept takes chemicals management away from a substance-by-substance approach to a group approach. For PFAS and other substances of concern, it offers a more rapid pathway toward effective management or phase-out. Parts of the concept of essential use have already been widely applied in global treaties and international regulations and it has also been recently used by product manufacturers and retailers to phase out substances of concern from supply chains. Herein some of the common questions and misinterpretations regarding the practical application of the essential-use concept are reviewed, and answers and further clarifications are provided.

Artificial Turf Infill: A Comparative Assessment of Chemical Contents

Concerns have been raised regarding toxic chemicals found in tire crumb used as infill in artificial turf and other play surfaces. A hazard-based analysis was conducted, comparing tire crumb with other materials marketed as alternative infills. These include other synthetic polymers as well as plant- and mineral-based materials. The comparison focused on the presence, absence, number, and concentration of chemicals of concern. No infill material was clearly free of concerns, but several are likely to be somewhat safer than tire crumb. Some alternative materials contain some of the same chemicals of concern as those found in tire crumb; however, they may contain a smaller number of these chemicals, and the chemicals may be present in lower quantities. Communities making choices about playing surfaces are encouraged to examine the full range of options, including the option of organically managed natural grass.

Advancing alternatives assessment for safer chemical substitution: A research and practice agenda

Alternatives assessment has emerged as a science policy field that supports the evaluation and adoption of safer chemistries in manufacturing processes and consumer products. The recent surge in the development and practice of alternatives assessment has revealed notable methodological challenges. Spurred by this need, we convened an informal community of practice comprising industry experts, academics, and scientists within government and nongovernmental organizations to prioritize a research and practice agenda for the next 5 years that, if implemented, would significantly advance the field of alternatives assessment. With input from over 40 experts, the agenda outlines specific needs to advance methods, tools, and guidance in 5 critical areas: hazard assessment, comparative exposure characterization, life cycle considerations, decision making, and professional practice. Fifteen research and practice needs were identified, ranging from relatively simple efforts to define a minimum hazard data set to the development of more complex performance and decision-analytic methods and data integration tools. Some research needs involve adapting existing approaches to the alternatives assessment context, while others will require the development of entirely new methods and tools. The proposed research and practice agenda is ambitious. Implementing it will require expanding the current network of researchers from academia, government, and industry, as well as increased funding for methodological, application, and evaluation research. Integr Environ Assess Manag 2018;00:000-000. © 2018 SETAC.

The concept of essential use for determining when uses of PFASs can be phased out

Because of the extreme persistence of per- and polyfluoroalkyl substances (PFASs) and their associated risks, the Madrid Statement argues for stopping their use where they are deemed not essential or when safer alternatives exist. To determine when uses of PFASs have an essential function in modern society, and when they do not, is not an easy task. Here, we: (1) develop the concept of "essential use" based on an existing approach described in the Montreal Protocol, (2) apply the concept to various uses of PFASs to determine the feasibility of elimination or substitution of PFASs in each use category, and (3) outline the challenges for phasing out uses of PFASs in society. In brief, we developed three distinct categories to describe the different levels of essentiality of individual uses. A phase-out of many uses of PFASs can be implemented because they are not necessary for the betterment of society in terms of health and safety, or because functional alternatives are currently available that can be substituted into these products or applications. Some specific uses of PFASs would be considered essential because they provide for vital functions and are currently without established alternatives. However, this essentiality should not be considered as permanent; rather, constant efforts are needed to search for alternatives. We provide a description of several ongoing uses of PFASs and discuss whether these uses are essential or non-essential according to the three essentiality categories. It is not possible to describe each use case of PFASs in detail in this single article. For follow-up work, we suggest further refining the assessment of the use cases of PFASs covered here, where necessary, and expanding the application of this concept to all other uses of PFASs. The concept of essential use can also be applied in the management of other chemicals, or groups of chemicals, of concern.

Lessons from the 2018 International Symposium on Alternatives Assessment: Advances and Reflections on Practice and Ongoing Needs to Build the Field

Alternatives assessment is gaining traction as a systematic method to support the informed substitution of chemicals of concern. The 2nd International Symposium on Alternatives Assessment, on 1-2 November 2018, convened nearly 150 professionals from government agencies, industry, consultant firms, academia, and advocacy organizations to advance a greater understanding of the evolving methods, practices, and challenges in the use of alternatives assessment. This article reviews highlights and lessons from the symposium, including 1) notable advances in methods, 2) shared insights from practitioners on best practices as well as inherent tensions and challenges, and 3) research and practice needs in the field that can be addressed by organizations such as the newly launched Association for the Advancement of Alternatives Assessment. Being interdisciplinary in nature, the establishment of educational frameworks across disciplines and inclusion of diverse expertise in hazard and exposure assessments, life cycle impacts considerations, design principles, and economic and engineering evaluations will ensure continued growth of the field. Integr Environ Assess Manag 2019;00:1-8. © 2019 SETAC.

The California Safer Consumer Products Program: Evaluating a Novel Chemical Policy Strategy

In 2008, California enacted laws to restructure chemical policy and promote green chemistry. Ten years after the passage of California’s green chemistry laws, we assessed their performance through structured interviews with a sample of experts from government, academia, business, and the nonprofit sector. We combined the interviews with a scoping literature review to propose a new ten-point framework for evaluating the effectiveness of a chemical regulatory policy, and we assessed the performance of the California law against this framework. The California program performed well on transparency of the regulatory process; protecting vulnerable populations; placing the primary burden on the manufacturer; breadth of regulatory authority; and advancing the public right-to-know. Areas of weakness include unclear authority to require data on chemical use in products; an inefficient pace of implementation; and limited incentives for innovation. Promoting safer chemicals in products will require additional incentives to protect public health and the environment.

Impact of European chemicals regulation on the industrial use of plasticizers and patterns of substitution in Scandinavia

REACH aims at promoting the safe use of chemicals in Europe, inter alia by identification and regulation of substances of very high concern (SVHCs). Once identified, SVHCs need to be substituted by safer alternatives. However, substitutes are frequently not safer than the substances that they replace but rather show similar hazard profiles, resulting in regrettable substitution. This paper investigates the impact of chemicals regulation on substitution of chemicals by analyzing time trends in the industrial use of chemicals from 2000 to 2014 in Scandinavia. It is shown that the use of ten water-relevant SVHCs decreased by about 90% in the considered period in Sweden as compared to a control group of unregulated substances which decreased by only 20%. A closer inspection of the use of 23 highly used plasticizers revealed that the use of regulated phthalate plasticizers decreased while the use of non-phthalate plasticizers increased. A first comparison of hazardous properties showed that during the 15-years period chemical substitution drastically reduced the chemical hazard burden of plasticizers in Scandinavia for both, the environment and human health. This study shows that regulation and the related discussion on chemicals safety have significantly reduced the chemical hazard burden from plasticizers in Scandinavia since the year 2000. It is assumed that similar trends can be found for the whole European Union. To combat regrettable substitution, mitigation options are suggested, including information-based tools for the identification of safer alternatives and an improved accessibility of information on production volumes and uses of chemicals to allow for an improved assessment of chemical's risk.

Chemical alternatives assessment of different flame retardants - A case study including multi-walled carbon nanotubes as synergist

Flame retardants (FRs) are a diverse group of chemicals used as additives in a wide range of products to inhibit, suppress, or delay ignition and to prevent the spread of fire. Halogenated FRs (HFRs) are widely used because of their low impact on other material properties and the low loading levels necessary to meet the required flame retardancy. Health and environmental hazards associated with some halogenated FRs have driven research for identifying safer alternatives. A variety of halogen-free FRs are available on the market, including organic (phosphorus and nitrogen based chemicals) and inorganic (metals) materials. Multi-walled carbon nanotubes (MWCNT) have been demonstrated to act as an effective/synergistic co-additive in some FR applications and could thereby contribute to reducing the loading of FRs in products and improving their performance. As part of the FP7 project DEROCA we carried out a chemical alternatives assessment (CAA). This is a methodology for identifying, comparing and selecting safer alternatives to chemicals of concern based on criteria for categorising human and environmental toxicity as well as environmental fate. In the project we assessed the hazard data of different halogen-free FRs to be applied in 5 industrial and consumer products and here we present the results for MWCNT, aluminium diethylphosphinate, aluminium trihydroxide, N-alkoxy hindered amines and red phosphorus compared to the HFR decabromodiphenylether. We consulted the REACH guidance, the criteria of the U.S.-EPA Design for Environment (DfE) and the GreenScreen® Assessment to assess and compare intrinsic properties affecting the hazard potential. A comparison/ranking of exposure reference values such as Derived No Effect Levels (DNELs) showed that FRs of concern are not identified by a low DNEL. A comparison based on hazard designations according to the U.S.-EPA DfE and GreenScreen® for human health endpoints, aquatic toxicity and environmental fate showed that the major differences between FRs of concern and their proposed alternatives are the potential for bioaccumulation and CMR (carcinogenic, mutagenic or reprotoxic) effects. As most alternatives are inorganic chemicals, persistence (alone) is not a suitable criterion. From our experiences in carrying out a CAA we conclude: i) REACH registration dossiers provide a comprehensive source of hazard information for an alternative assessment. It is important to consider that the presented data is subject to changes and its quality is variable. ii) Correct identification of the chemicals is crucial to retrieve the right data. This can be challenging for mixtures, reaction products or nanomaterials or when only trade names are available. iii) The quality of the data and the practice on how to fill data gaps can have a huge impact on the results and conclusions. iv) Current assessment criteria have mainly been developed for organic chemicals and create challenges when applied to inorganic solids, including nanomaterials. It is therefore crucial to analyse and report uncertainties for each decision making step.