U.S. EPA Design for the Environment Program
Great Lakes Green Chemistry Network
Alternatives Assessment and Safer Product Labeling as Drivers for Green Chemistry
January 11, 2012
Clive Davies
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Contents
• Alternatives Assessments for Priority Chemicals – Priority Chemicals
– Criteria
– Community of Practice
• Safer Product Labeling Program – Requirements for the DfE Label
– Value of the DfE Label
– DfE criteria drives development of safer chemicals
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• Alternatives Assessments
• Lifecycle Assessments
• Safer Product Labeling Program
Multi-Stakeholder Projects at DfE
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What are Chemical Alternatives Assessments?
Broadly: Alternatives Assessment is a process for identifying and comparing
potential chemical and non-chemical alternatives that can be used as substitutes
to replace priority chemicals or technologies.
DfE Chemical Alternatives Assessment (see our full methodology on the web site):
• Convene Stakeholders
• Identify potential alternatives
• Evaluate priority chemicals & potential alternatives
» High, Moderate, or Low ratings for:
• Human health effects
• Environmental fate & effects
• Provide information manufacturers can use to create more
sustainable products through “informed substitution” & help
minimize potential for unintended consequences
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DfE Alternatives Assessments for Priority Chemicals
• Tetrabromobisphenol A (TBBPA) in Printed Circuit Boards – combustion testing underway
• Nonylphenol and nonylphenol ethoxylates (NP/NPE) – final report Spring 2012
• Bisphenol A (BPA) in Thermal Paper – draft report March 2012
• Flame Retardant Alternatives to decabromodiphenyl ether (decaBDE)
used in many plastics – draft report March 2012
• Flame Retardant Alternatives to hexabromocyclododecane (HBCD)
in insulation board – draft report Summer 2012
• Phthalates – list of potential alternatives February 2012
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Endpoints Covered in the DfE Alternatives Assessment Criteria
Human Health Toxicity
• Acute mammalian toxicity • Carcinogenicity • Mutagenicity/
Genotoxicity • Reproductive Toxicity • Developmental Toxicity • Neurotoxicity • Repeated Dose Toxicity • Respiratory Sensitization • Skin Sensitization • Eye and Skin
Irritation/Corrosivity • Endocrine Activity
Environmental Fate &
Effects
• Aquatic toxicity
• Environmental persistence
• Bioaccumulation
Additional Endpoints • Physical hazards
• Ecotoxicity (birds, bees)
• And more
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1st DfE Alternatives Assessment: Flame Retardants in Furniture Foam (2005)
Ecotoxicity Hazard Concern
Human Health Hazard Concern
Environmental Hazard Concern
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Growing Community of Practice
Others are conducting Alternatives Assessments using
related methods:
• States and NGOs
– Washington, Maine and TURI in Massachusetts
– Clean Production Action’s (CPA) Green Screen
– Green chemistry & Commerce Council (GC3)
• Companies and trade associations
– HP
– Nike
– Phosphorous, Inorganic & Nitrogen Flame Retardants Association
(PINFA)
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Green Chemistry & Alternatives Assessments
• Alternatives Assessments identify potential alternatives
– Some may be safer
– Some may be associated with trade-offs
– In some cases green chemistry alternatives are not identified
Green Chemistry Challenge
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DfE Label: Multi-Attribute, Lifecycle-Based
• Human health effects
• Environmental health effects
• VOC content
• Packaging
• Auditing
• Ingredient disclosure
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Requirements for the DfE Label
• Standard for Safer Cleaning Products – Whole product requirements, such as pH and
synergistic effects
– Product performance
– Audits
– Ingredient disclosure
• Criteria for Safer Ingredients
– Surfactants
– Solvents
– Chelating Agents
– Fragrances
– Master Criteria (for all other ingredient classes)
• Partnership Agreement – 3 years
Available at www.epa.gov/dfe.
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Value of the DfE Label
• Standard Describes What’s Not Allowed:
– Identified through authoritative lists
– Analogs to listed chemicals are not allowed
• Standard Also Describes What is Allowed:
– Criteria for Safer Ingredients
– Data are required to meet these criteria
– No data = fail
• Suppliers develop safer chemicals and test data
– New chemicals with test data (biodegradation, carcinogenicity,
aquatic toxicity, etc.)
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say “the government should set higher standards for environmental labels on products”
[Green Gauge Survey of Consumers, 2009]
95% Would buy green/safer
63% Looked for green /safer
[Deloitte Green Shopper Survey, 2009
65%
22% bought Safer/Green
Demand for Safer (Green) Products
A top consumers reason for buying green:
Limit exposure to toxins & chemicals
[The Shelton Group]
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DfE Criteria Drive Development of Safer Chemicals & Data
• Definition for safer chemicals by functional use class
• DfE criteria promotes development of safer chemicals – Surfactants (not previously in commerce) which are more rapidly
biodegradable
– Dow, BASF, Akzo Nobel
• DfE criteria have driven development of new test data – Biodegradation
– Aquatic toxicity
– Carcinogenicity
• GreenBlue’s Cleangredients houses safer alternative chemicals
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Regional, State-based & Local Alternatives Assessment & Labeling Opportunities
• Potential pilot projects, alternatives/labeling trials or emerging
chemical concerns arise that are outside of the DfE Program
– Contact your EPA Regional Office for assistance
• U.S. EPA Region 5 and the Great Lakes National Program Office
(GLNPO) have toxics reduction, green chemistry and alternatives
analysis opportunities that support alternatives assessment and
chemical product communication / management for:
– Small- to mid-size businesses
– Sector-specific activities
– Emerging substances or risks (e.g., State or local chemicals of concern,
industry-identified green alternatives, etc.)
– Voluntary Best Practice(s) (e.g., Green Engineering)
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• Region 5 and GLNPO are available to engage with
parties seeking to explore those opportunities
• Contacts:
– Region 5 (TSCA): Brad Grams, (312) 886-7747
– GLNPO (P2/Toxics): Ted Smith, (312) 353-6571
Regional, State-based & Local Alternatives Assessment & Labeling Opportunities
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EPA Screening Models Can Fill Data Gaps
• ECOSAR – estimates acute and chronic aquatic toxicity
• Oncologic® – expert system to evaluate potential carcinogenicity
• EPI SuiteTM – suite of models covering physical/chemical
properties as well as persistence and bioaccumulation
• OECD QSAR Toolbox
NPPTAC Interim Work Group Discussion Document – Not For Distribution