alex stone washington department of ecology nahmma meeting 2 june 2015 alternatives assessment: the...
TRANSCRIPT
Alex StoneWashington Department of
EcologyNAHMMA Meeting
2 June 2015
Alternatives Assessment: The Search for Safer Substitutes
Contents Definitions
Explain why we care
Summarize recent activities in Alternatives Assessment
Definitions
Regrettable Substitution• Definition: Replacement of toxic chemical with chemical
of equal or greater toxicity
• Historically occurred when chemical banned with no review of toxicity of replacement
• Ex: Replacing chlorinated solvents- CA banned use of many chlorinated solvents- Manufacturers replaced products containing chlorinated solvents with hexane- Few years after switch, employees started having neurological problems- Hexane identified as neurotoxic in 1960’s- Replaced with n-propyl bromide, another neurotoxicant
Phase out hazardous chemicals yes! But how can one avoid regrettable substitutions?
Alternatives AssessmentDefinition:– The objective of an alternatives assessment is to replace
chemicals of concern in products or processes with inherently safer alternatives, thereby protecting and enhancing human health and the environment.
Principles– Reduce risk by reducing hazard– Transparency– Flexibility– Life-cycle Thinking– Opportunities for Green Chemistry and Continuous
Improvement– Consider Uncertainties
Alternative Assessment Objective
Replace toxic chemicals with safer alternatives
If a safer alternative to a toxic chemical exists that completes the function of the product at a cost effective price, NO justification for continued use of toxic chemical
Money is saved by not using toxic chemicals including cost savings associated with:
– Manufacture, transport and potential spills– Release during use and end-of-life– Cleanup of contaminated sites– Regulatory costs of managing both chemicals and
dangerous waste
Major US and International companies require alternatives assessment because of these benefits
Chemical Hazard AssessmentDefinition:– A process for identifying, comparing and selecting safer chemical alternatives
to replace hazardous chemicals based on the inherent characteristics of the chemical impacting public health and the environment
Numerous tools available– Pharos Database– ChemHat– Interstate Chemicals Clearinghouse CHA Database– GreenScreen and GreenScreen Store– OECD Toolbox– Quick Chemical Assessment Tool (QCAT)
Why We Care!
Why conduct an Alternatives Assessment?
– Desire to get off toxic treadmill and stop regrettable substitutions from occurring
– Increased interest by State Legislatures in AA process along with chemical bans
– Two states currently have authority to require alternatives assessments
• California• Maine
– Increased industry interest and requests for assistance
– Health Impacts
The true burden of environmentally induced cancer has been grossly underestimated. With nearly 80,000 chemicals on the market in the United States, many of which are used by millions of Americans in their daily lives and are understudied and largely unregulated, exposure to environmental carcinogens is widespread.
Pres. Obama’s Cancer Panel (2010)
• Only 10 percent of breast cancers can be attributed to genetic mutations.
• Compelling scientific evidence points to some of 50,000 synthetic chemicals in use today as contributing to development of breast cancer, either by altering hormone function or gene expression.
Preventing Breast Cancer?
Additional Concerns
Autism Concerns (cont.)
Recent data (2014) from the Centers for Disease Control and Prevention
Oooh-Look Donald Duck!
Golly-There’s Pluto too!
Non-hazardous to children or adults, to pets or cloth. Certified to be absolutely safe for home use. Tested and recommended by Parents’ Magazine.
Chemical Hazard Assessment-Business
Perspective (HP)1
Faster, Easier to complete– Narrow, well-defined endpoints– Science-based– Facilitates relative quick assessments
Increasingly used by regulatory bodies
– Useful as an indicator of future restriction
– Aligns business with regulatory process
1 Information from a presentation at a Green Materials symposium made by Helen Holder of Hewlett-Packard on 23 March 2011
RA Concerns-Business Perspective (HP)1
• Not comparative– Not in a useful format for comparative
decisions– Chemists consider function when designing
formulations– Alternatives must be shown in relation to
other chemicals of the same function1 Information from a presentation at a Green Materials symposium made by Helen Holder of Hewlett-Packard on 23 March 2011
Is Risk Assessment the right tool for comparing alternatives to restricted substances in electronics?• Overwhelming to most decision-makers
– Most decision makers are procurement engineers– Overwhelmed by information out of their field– Can’t effectively incorporate into existing procurement process
Recent Activities in Alternatives Assessment
IC2 AA Guide
– Released IC2 Guide in Jan. 2014
– Guide detailed and complicated
– Based upon concept that an AA cannot be done using just one method
– Includes flexibility to meet wide range of needs
– States to adapt IC2 Guide to suit individual needs
– Ecology created Washington specific AA Guide
IC2 AA Guide
http://theic2.org/article/download-pdf/file_name/IC2_AA_Guide_Version_1.0.pdf
Guide Components
1. Identify COCs
2. Initial Evaluation
3. Scoping– Stakeholder– Decision Framework
4. Identification of Alternatives
5. Assess Alternatives– Hazard– Performance– Cost & Availability– Exposure– Materials Mgt– Social Impact– Life cycle
AA consists of five distinct steps
Other Frameworks– National Academy of Sciences (NAS) released an
alternatives assessment framework document in October 2014
– NAS framework based upon existing frameworks and is in agreement with the IC2 AA Guide
– Provides less concrete guidance than other frameworks
– Leaves many of the decisions to assessor or external parties• Ex: Less defined hazard assessment
OECD Toolbox– Organization for Economic Cooperation and
Development (OECD) recently released AA Toolbox– Assist users with AA
Summary– Although AA techniques still developing,
considerable activity occurring
– Resources made available to a wide range of potential users
– Training becoming more available• GreenScreen• Quick Chemical Assessment Tool (QCAT)
ContactsAlex StoneWashington Department of EcologySafer Chemical Alternative Chemist(360) [email protected]
Ken ZarkerWashington Department of EcologyPollution Prevention and Regulatory
Assistance(360) [email protected]