The use of alternatives assessment in chemicals management policies: Needs for greater impact

Alternatives assessment is a methodology used to identify, evaluate, and compare potential chemical and nonchemical solutions with a substance of concern. It is required in several chemicals management regulatory frameworks, with the objective of supporting the transition to safer chemistry and avoiding regrettable substitutions. Using expert input from symposium presentations and a discussion group hosted by the Association for the Advancement of Alternatives Assessment, four case examples of the use of alternatives assessment in regulatory frameworks were evaluated and compared: (1) the US Environmental Protection Agency Significant New Alternatives Policy (USEPA SNAP), (2) authorization provisions in the EU REACH (Registration, Evaluation, Authorisation, and Restriction of Chemicals) regulation, (3) the California (CA) Safer Consumer Products (SCP) Program, and (4) the Safer Products for Washington (WA) Program. Factors such as the purpose of the alternatives assessment, the timeline of actions, who completes the assessment, the role of stakeholder engagement, and the regulatory response options for each policy are outlined. Through these presentations and expert discussions, four lessons learned about the use of alternatives assessments in regulatory policy emerged: (1) the goal and purpose of the regulatory framework significantly affects its ability to result in safer substitution, (2) existing frameworks struggle with data access and insufficient stakeholder engagement, (3) some frameworks lack clear decision rules regarding what is a safer and feasible alternative, and (4) regulatory response options provide limited authority for enforcement and do not adequately address options where alternatives are unavailable or limited. Five recommendations address these lessons as well as how the application of alternatives assessment in regulatory settings could have greater impact in the future. This synthesis is not meant to be a comprehensive policy analysis, but rather an assessment based on the perspectives from experts in the field, which should be supplemented by formal policy analysis as policies are implemented over time. Integr Environ Assess Manag 2023;00:1-11. © 2023 The Authors. Integrated Environmental Assessment and Management published by Wiley Periodicals LLC on behalf of Society of Environmental Toxicology & Chemistry (SETAC).

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.

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.

Reinvigorating Engagement and Collaboration through Interprofessional Education (RECIPE) in nursing and public health students

An interprofessional education (IPE) activity was piloted in an undergraduate Research Methods course with sophomore nursing and public health students. Students worked in small mixed groups mentored by course professors to critique a research article. The study aims to evaluate the IPE effectiveness in promoting students’ readiness for IPE, and facilitating students’ learning, critical thinking, and communication. Online survey with the Readiness for Interprofessional Learning Scale was administered to nursing and public health students pre- and post-IPE activity implementation. Nursing students’ evaluation of the research critique assignment was compared with other nursing course sections. The study found that nursing students rated IPE better in facilitating critical thinking and communication than one previous class section without an IPE component. Students’ qualitative comments suggested that future IPE will benefit from smaller groups, more even distribution of students from different disciplines, more shared faculty lectures, and integrating interactive group discussions.

Advancing alternatives analysis: The role of predictive toxicology in selecting safer chemical products and processes

Alternatives analysis (AA) is a method used in regulation and product design to identify, assess, and evaluate the safety and viability of potential substitutes for hazardous chemicals. It requires toxicological data for the existing chemical and potential alternatives. Predictive toxicology uses in silico and in vitro approaches, computational models, and other tools to expedite toxicological data generation in a more cost-effective manner than traditional approaches. The present article briefly reviews the challenges associated with using predictive toxicology in regulatory AA, then presents 4 recommendations for its advancement. It recommends using case studies to advance the integration of predictive toxicology into AA, adopting a stepwise process to employing predictive toxicology in AA beginning with prioritization of chemicals of concern, leveraging existing resources to advance the integration of predictive toxicology into the practice of AA, and supporting transdisciplinary efforts. The further incorporation of predictive toxicology into AA would advance the ability of companies and regulators to select alternatives to harmful ingredients, and potentially increase the use of predictive toxicology in regulation more broadly. Integr Environ Assess Manag 2017;13:915-925. © 2017 SETAC.

The applicability of chemical alternatives assessment for engineered nanomaterials

The use of alternatives assessment to substitute hazardous chemicals with inherently safer options is gaining momentum worldwide as a legislative and corporate strategy to minimize consumer, occupational, and environmental risks. Engineered nanomaterials represent an interesting case for alternatives assessment approaches, because they can be considered both emerging "chemicals" of concern, as well as potentially safer alternatives to hazardous chemicals. However, comparing the hazards of nanomaterials to traditional chemicals or to other nanomaterials is challenging, and critical elements in chemical hazard and exposure assessment may have to be fundamentally altered to sufficiently address nanomaterials. The aim of this paper is to assess the overall applicability of alternatives assessment methods for nanomaterials and to outline recommendations to enhance their use in this context. The present paper focuses on the adaptability of existing hazard and exposure assessment approaches to engineered nanomaterials as well as strategies to design inherently safer nanomaterials. We argue that alternatives assessment for nanomaterials is complicated by the sheer number of nanomaterials possible. As a result, the inclusion of new data tools that can efficiently and effectively evaluate nanomaterials as substitutes is needed to strengthen the alternatives assessment process. However, we conclude that with additional tools to enhance traditional hazard and exposure assessment modules of alternatives assessment, such as the use of mechanistic toxicity screens and control banding tools, alternatives assessment can be adapted to evaluate engineered nanomaterials as potential substitutes for chemicals of concern and to ensure safer nanomaterials are incorporated in the design of new products. Integr Environ Assess Manag 2017;13:177-187. © 2016 SETAC.

The Architecture of Chemical Alternatives Assessment

Chemical alternatives assessment is a method rapidly developing for use by businesses, governments, and nongovernment organizations seeking to substitute chemicals of concern in production processes and products. Chemical alternatives assessment is defined as a process for identifying, comparing, and selecting safer alternatives to chemicals of concern (including those in materials, processes, or technologies) on the basis of their hazards, performance, and economic viability. The process is intended to provide guidance for assuring that chemicals of concern are replaced with safer alternatives that are not likely to be later regretted. Conceptually, the assessment methods are developed from a set of three foundational pillars and five common principles. Based on a number of emerging alternatives assessment initiatives, in this commentary, we outline a chemical alternatives assessment blueprint structured around three broad steps: Scope, Assessment, and Selection and Implementation. Specific tasks and tools are identified for each of these three steps. While it is recognized that on-going practice will further refine and develop the method and tools, it is important that the structure of the assessment process remain flexible, adaptive, and focused on the substitution of chemicals of concern with safer alternatives.

The sustainability solutions agenda

Progress toward a more sustainable society is usually described in a "knowledge-first" framework, where science characterizes a problem in terms of its causes and mechanisms as a basis for subsequent action. Here we present a different approach-A Sustainability Solutions Agenda (SSA)-which seeks from the outset to identify the possible pathways to solutions. SSA focuses on uncovering paths to sustainability by improving current technological practice, and applying existing knowledge to identify and evaluate technological alternatives. SSA allows people and organizations to transition toward greater sustainability without sacrificing essential technological functions, and therefore does not threaten the interests that depend on those functions. Whereas knowledge-first approaches view scientific information as sufficient to convince people to take the right actions, even if those actions are perceived as against their immediate interests, SSA allows values to evolve toward greater attention to sustainability as a result of the positive experience of solving a problem.

Reforming state-level chemicals management policies in the United States: status, challenges, and opportunities

During the last several years there has been increasing public concern about chemicals in everyday products. Scientific studies are increasingly revealing the build-up of some substances in ecosystems and in our bodies and new findings are linking exposures to hazardous chemicals to a range of adverse human health effects. Despite these trends, there has been little federal initiative in the United States on reforming chemicals management policies for well over two decades, even though a variety of analyses have identified significant gaps in the regulatory structure. As has historically been the case, states are beginning to fill the holes in federal leadership. This article explores this emerging state leadership and establishes a vision for and elements of policies to reduce hazardous chemicals in the products we buy and the places we go. It examines international efforts to reform chemicals management policies, such as the European REACH legislation and corporate leadership in advancing safer products. Finally, it outlines specific challenges states face in developing integrated, comprehensive chemicals management policies. We conclude that while there are plenty of challenges to implementation of chemicals policy reforms, it is a propitious time for states to become leaders in policy innovation that can help achieve safer production systems and products for future generations. This article is part of a Lowell Center for Sustainable Production report entitled "Options for State Chemicals Policy Reform" that provides in-depth analysis of the pros and cons of policy options to address a range of aspects of state-level chemicals policy reform. The article has been edited slightly for use in New Solutions. The report has been widely distributed to policy-makers, advocates, and others across the United States.

Human exposure to PBDEs: associations of PBDE body burdens with food consumption and house dust concentrations

This study was designed to determine the body burden of polybrominated diphenyl ethers (PBDEs) among first-time mothers in the Greater Boston, Massachusetts area and to explore key routes of exposure. We collected breast milk samples from 46 first-time mothers, 2-8 weeks after birth. We also sampled house dust from the homes of a subset of participants by vacuuming commonly used areas. Data on personal characteristics, diet, home furniture, and electrical devices were gathered from each participant using a questionnaire. Breast milk and dust samples were analyzed for PBDEs using gas chromatography/ mass spectrometry. PBDE concentrations were log-normally distributed in breast milk and dust. We found statistically significant, positive associations between PBDE concentrations in breast milk and house dust (r = 0.76, p = 0.003, not including BDE-209), as well as with reported dietary habits, particularly the consumption of dairy products (r = 0.41, p = 0.005) and meat (r = 0.37, p = 0.01). Due to low detection rates, it was not possible to draw conclusions about the association between BDE-209 in milk and dust. Our results support the hypothesis that the indoor environment and diet both play prominent roles in adult human exposure to PBDEs.

What Does the Precautionary Principle Mean for Evidence-Based Dentistry?

The precautionary principle calls for preventive actions in the face of uncertain information about risks. It serves as a compass to better guide more health-protective decisions in the face of complex risks. Applying precaution requires thinking more broadly about risks, taking an interdisciplinary approach to science and policy, and considering a wide range of alternatives to potentially harmful activities. While often criticized as antiscientific, the precautionary principle represents a challenge to scientists and public health professionals to develop newer and more effective tools for characterizing and preventing complex risks, in addition to being more explicit about uncertainties. This article examines the role and application of precaution in the context of dental practice, where activities that may convey risks also have public health benefits, and risk trade offs are a possibility. We conclude that the precautionary principle is not at odds with, but rather complements evidence-based practice in situations of scientific uncertainty and complex risks.

Community-initiated breast cancer and environment studies and the precautionary principle

The precautionary principle implies the need for research paradigms that contribute to "strength of the evidence" assessments of the plausibility of health effects when scientific uncertainty is likely to persist and prevention is the underlying goal. Previous discussions of science that inform precautionary decision making are augmented by examining three activist-initiated breast cancer and environment studies--the Long Island, New York, and Cape Cod, Massachusetts, studies and the National Institute of Environmental Health Sciences breast cancer and environment centers. These studies show how the choice of research questions affects the potential of results to inform action. They illustrate a spectrum of public involvement, population- and individual-level epidemiologic study designs, and the crucial importance of developing and applying new exposure assessment methods. The exposure studies are key because they are critical in assessing plausibility (without exposure to a causal agent, there is no health effect), are prerequisite to health studies, and identify preventable exposures that could be reduced by precautionary policies, even in the absence of strong evidence of harm. The breast cancer studies have contributed to environmental and biological sampling programs for endocrine-disrupting compounds in drinking water and household air and dust and the application of geographic information systems for surveillance and historical exposure assessment. They leave unanswered questions about when to invest in large epidemiologic studies, when negative results are sufficient, and how to pursue ambiguous positive results in further research and policy.

Evaluation and further development of EASE model 2.0

EASE (Estimation and Assessment of Substance Exposure) is a general model that may be used to predict workplace exposure to a wide range of substances hazardous to health. First developed in the early 1990s, it is now in its second Windows version. This paper provides a critical assessment of the utility and performance of the EASE model, and on the basis of this review, recommendations for the structure of a revised model are outlined. Twenty-seven stakeholders were interviewed about their previous use of EASE, perceived advantages and limitations of the model and suggestions for improvement. A subset of stakeholders was contacted on a second occasion to determine their views on the preferred outputs for an ideal exposure assessment model. Overall, stakeholders felt that the model should be updated to provide more accurate and precise exposure assessments. However, users also expressed the view that the simplicity and usability of the software model should not be compromised. Six studies investigating the validity of the inhalation exposure assessment section of EASE were identified. These showed that the model generally either predicted close to the measured exposures or overestimated exposure; though performance was highly variable. Two studies investigated the validity of the dermal exposure assessment and found that EASE produced considerable overestimates of actual dermal exposure (the amount of a substance that actually lands on the skin). A conceptual model of exposure was developed to investigate whether the structure of the EASE model is appropriate. Although EASE has a number of characteristics that describe exposure, it is a greatly simplified model and does not include all the important exposure determinants. More importantly, EASE can produce estimates of exposure that are ambiguous or incomplete. Our conceptual model may provide a rational basis for developing an improved version of EASE but further consultation is needed to decide the purpose and intended use of any successor to EASE.

The 1991 cholera epidemic in Peru: not a case of precaution gone awry

The precautionary principle calls on decisionmakers to take preventive action in light of evidence indicating that there is a potential for harm to public health and the environment, even though the nature and magnitude of harm are not fully understood scientifically. Critics of the precautionary principle frequently argue that unbridled application of the principle leads to unintended damage to health and ecosystems (risk tradeoffs) and that precautious decision making leaves us vulnerable to "false-positive" risks that divert resources away from "real risks." The 1991 cholera epidemic in Peru is often cited as an example of these pitfalls of the precautionary principle. It has been mistakenly argued that application of the precautionary principle caused decisionmakers to stop chlorinating the water supply due to the risks of disinfection byproducts (DBPs), resulting in the epidemic. Through analyses of investigations conducted in the cities of Iquitos and Trujillo, Peru, literature review, and interviews with leading Peruvian infectious disease researchers, we determined that the epidemic was caused by a much more complex set of circumstances, including poor sanitation conditions, poor separation of water and waste streams, and inadequate water treatment and distribution systems. The evidence indicates that no decision was made to stop chlorinating on the basis of DBP concerns and that concerns raised about DBPs masked more important factors limiting expansion of chlorination. In fact, outside of Peru's capital Lima, chlorination of drinking water supplies at the time of the epidemic was limited at best. We conclude that the Peruvian cholera epidemic was not caused by a failure of precaution but rather by an inadequate public health infrastructure unable to control a known risk: that of microbial contamination of water supplies.

The problem of current toxic chemicals management

In this article, we explore the limitations of current chemicals management policies worldwide and the evolution of new European, International and U.S. policies to address the problem of toxic chemicals control. It is becoming increasingly apparent that current chemicals management policies in Europe and the United States are inadequate. There is a general lack of toxicity and exposure information on chemicals in commerce and the vast majority of chemicals were considered safe until proven guilty in legislation. Governments must then prove each chemical is dangerous through a slow and resource-intensive risk assessment process. For more than a decade, Nordic countries, such as Denmark and Sweden, have actively promoted integrated chemicals policies to address contamination of critical waterways. They have successfully used a variety of voluntary and mandatory policy tools, such as education, procurement, lists of chemicals of concern, eco-labeling, research and development on safer substitutes, and chemical phase-out requirements, to encourage companies using chemicals to reduce their reliance on harmful substances and to develop safer substitutes. While previously isolated to particular countries, innovative and exciting European-wide policies to promote sustainable chemicals management are now moving forward, including the recently published draft Registration, Evaluation and Authorization of CHemicals (REACH) policy of the European Union. A sweeping change in chemicals management policies in Europe is inevitable and it will ultimately affect manufacturers in the U.S. and globally. The European movement provides an opportunity to initiate a discussion on integrated chemicals policy in the U.S. where some innovative initiatives already are underway.

Primary prevention of chemical contamination

The current approach to addressing health and ecosystem risks from biosolids, or sludge, requires identification of so-called "safe" or "acceptable" levels of exposure and installation of controls to achieve such levels. This end-of-the pipe approach is inconsistent with the public health concept of primary prevention. Following an overview of the limitations in current approaches to understand and address risks of biosolids contamination, we present a new, preventative paradigm for addressing the hazards of sludge. We conclude that given the disparate and widely distributed sources of contaminants in biosolids and the amount of uncertainty in information about health and environmental effects, we need a new approach to this and other environmental dilemmas. This approach is embodied in the concept of the precautionary principle and public health goal-setting.

Reenergizing public health through precaution

The precautionary principle has provoked a spirited debate among environmentalists worldwide, but it is equally relevant to public health and shares much with primary prevention. Its central components are (1) taking preventive action in the face of uncertainty; (2) shifting the burden of proof to the proponents of an activity; (3) exploring a wide range of alternatives to possibly harmful actions; and (4) increasing public participation in decision making. Precaution is relevant to public health, because it can help to prevent unintended consequences of well-intentioned public health interventions by ensuring a more thorough assessment of the problems and proposed solutions. It can also be a positive force for change. Three aspects are stressed: promoting the search for safer technologies, encouraging greater democracy and openness in public health policy, and stimulating reevaluation of the methods of public health science.

The precautionary principle in environmental science

Environmental scientists play a key role in society's responses to environmental problems, and many of the studies they perform are intended ultimately to affect policy. The precautionary principle, proposed as a new guideline in environmental decision making, has four central components: taking preventive action in the face of uncertainty; shifting the burden of proof to the proponents of an activity; exploring a wide range of alternatives to possibly harmful actions; and increasing public participation in decision making. In this paper we examine the implications of the precautionary principle for environmental scientists, whose work often involves studying highly complex, poorly understood systems, while at the same time facing conflicting pressures from those who seek to balance economic growth and environmental protection. In this complicated and contested terrain, it is useful to examine the methodologies of science and to consider ways that, without compromising integrity and objectivity, research can be more or less helpful to those who would act with precaution. We argue that a shift to more precautionary policies creates opportunities and challenges for scientists to think differently about the ways they conduct studies and communicate results. There is a complicated feedback relation between the discoveries of science and the setting of policy. While maintaining their objectivity and focus on understanding the world, environmental scientists should be aware of the policy uses of their work and of their social responsibility to do science that protects human health and the environment. The precautionary principle highlights this tight, challenging linkage between science and policy.

Workshop on harmonization of serving future needs with occupational exposure databases--inhalation modeling, session IIIA

This workshop was one of several that took place at the International Symposium on Occupational Exposure Databases and Their Application for the Next Millennium held in London from November 1-3, 1999. About 30 delegates participated in the workshop. The agenda for the discussions was provided by a white paper prepared by the organizers. The workshop produced a conceptual outline for a general-purpose prediction model for inhalation exposure, and constructed a list of important input variables for successful model development. Evaluation of prototype models was discussed in some detail, and the workshop concluded with suggestions for taking forward the ideas discussed and maintaining the momentum and interest generated during the symposium.

Retrospective collection of exposure data from industry: results from a feasibility study in the United Kingdom

In the United Kingdom the Health and Safety Executive for some years has stored chemical exposure data in their National Exposure Database. However, it has been difficult to persuade industry and other organizations to contribute to this resource. The aim of this project was to devise a cost-effective method of obtaining occupational exposure data on chemicals from U.K. industry and other sources. Five strategies were used to identify data for three different substances: toluene, acrylonitrile, and ethylene oxide. In total, 810 organizations were contacted and over 45 percent responded. However, only 40 had relevant exposure data. Almost equal numbers of acceptable measurements were identified for toluene and acrylonitrile (2,770 and 2,000 respectively) with lesser ethylene oxide data (800). These measurements were drawn from a wide range of industries and are probably representative of measurements made by U.K. industry, although most of the data were from companies employing more than 100 people. During the second phase of the project, more than 3,000 measurements and associated contextual information were collected (499 for toluene, 1,516 for acrylonitrile, and 17 for ethylene oxide, with a further 1,004 measurements for 1 of 27 substances collected simultaneously with one of the above). The costs of identifying and collecting exposure data ranged from ł7 to ł380 per valid measurement, depending on the source of the data. We suggest that, rather than trying to retrospectively collect data, it is likely to be more cost-effective to enlist a number of occupational hygiene consults and industrial organizations to prospectively provide anonymized exposure measurements for inclusion in the Health and Safety Executives National Exposure Database.

Determination of the spatial response of neutron based analysers using a Monte Carlo based method

One of the principal advantages of using thermal neutron capture (TNC, also called prompt gamma neutron activation analysis or PGNAA) or neutron inelastic scattering (NIS) techniques for measuring elemental composition is the high penetrating power of both the incident neutrons and the resultant gamma-rays, which means that large sample volumes can be interrogated. Gauges based on these techniques are widely used in the mineral industry for on-line determination of the composition of bulk samples. However, attenuation of both neutrons and gamma-rays in the sample and geometric (source/detector distance) effects typically result in certain parts of the sample contributing more to the measured composition than others. In turn, this introduces errors in the determination of the composition of inhomogeneous samples. This paper discusses a combined Monte Carlo/analytical method for estimating the spatial response of a neutron gauge. Neutron propagation is handled using a Monte Carlo technique which allows an arbitrarily complex neutron source and gauge geometry to be specified. Gamma-ray production and detection is calculated analytically which leads to a dramatic increase in the efficiency of the method. As an example, the method is used to study ways of reducing the spatial sensitivity of on-belt composition measurements of cement raw meal.