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

Alternatives Assessments

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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

Safer Product Labeling Program

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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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Growth in Labeled Products

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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

grams.bradley@epa.gov

– GLNPO (P2/Toxics): Ted Smith, (312) 353-6571

smith.edwin@epa.gov

Regional, State-based & Local Alternatives Assessment & Labeling Opportunities

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THANK YOU!

Clive Davies

davies.clive@epa.gov

202-564-3821

www.epa.gov/dfe

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Back-pocket slides follow

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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