Alternatives Assessment Webinar

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1 Alternatives Assessment Webinar Quick Chemical Assessment Tool National Pollution Prevention Roundtable Webinar 6 December 2012 Alex Stone

2 Outline 1. Why Companies Care About Toxic Chemicals.. 2. Business Response to hazardous chemicals 3. Regulatory approaches to dealing with toxic chemicals 4. Companies need to avoid Regrettable Substitution 5. Safer Substitutes: The new focus on Alternatives Assessment 6. Introduction to the QCAT

3 1. Why Companies Care About Toxic Chemicals..

4 Toxic Chemical Concerns Rising consumer awareness of chemicals Presence in consumer products Presence in their neighborhood and how it affects their quality of life Risk to worker health and safety Impacts to businesses Increased costs Increased emphasis on brand name Regulations Increased regulation generally and globally

5 Pres. Obama s Cancer Panel (2010) 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.

6 Chemical regulation in supply chain Additional substances continue to be added Requirements vary between companies Difficult and costly to remove materials as regulations expand

7 Advantage to companies Advantages to knowing your chemicals and avoiding hazards allows companies to: Respond to inquiries about impacts of chemicals in your products Respond to increasing regulation of chemicals Position yourself in the marketplace as your institutional buyers require more information Companies better prepare for increasing trend requiring more assessment and justification of hazardous chemicals More on this later on discussion of legislation

8 2. Business Response to Hazardous Chemicals: Restricted Substances Lists (RSLs)

9 Business response Create Restricted Substances Lists (RSLs) RSLs - list of chemicals companies ban from use Chemicals of concern come from: Authoritative sources Regulatory bans Consumer concerns Industry sectors concerns Examples of RSLs Plastics/Electronics: Hewlett Packard Apparel: Nike, REI, Levi Straus, AAFA Nike RSL: e_aug_2011.pdf Personal Care Products: Johnson & Johnson

10 Chemicals on RSLs Authoritative sources Regulatory requirements (labeling, reporting, etc.) Screening lists Consumer Concerns: chemicals identified by consumers as something to avoid Business priorities: chemicals eliminated based on policy or promotional decisions Lots more out there!

11 RSL Strengths and Weaknesses Positives (for companies/governments) - Highlights toxic chemicals - Can lead to elimination of toxic chemicals - Shows willingness to eliminate use of toxic chemicals Weaknesses (for companies/governments) Does not include all chemicals of concern No consistency Hard to keep up-to-date Says nothing about chemicals not on list (regrettable substitution)

12 3. Companies need to avoid Regrettable Substitutions

13 Regrettable Substitution 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 with hexane - 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

14 Phase out hazardous chemicals yes! But how can companies avoid regrettable substitutions?

15 Avoiding Regrettable Substitution Require complete disclosure of all chemicals in products Product declarations (Seagate, Seventh Generation) Require documentation that alternatives are less toxic than chemical of concern Alternatives assessment (HP, other progressive companies) Risk Assessment (Johnson & Johnson, Colgate Palmolive, other Personal Care Product companies)

16 4. Safer Substitutes: The new focus on Alternatives Assessments

17 From P2 to Alternatives Assessment Alternative Assessment (AA): process for identifying and comparing potential chemical and non-chemical alternatives used as substitutes to replace chemicals or technologies of high concern Chemical Hazard assessment core part of AA Hazard: negative impact upon human health or environment Carcinogenicity, mutagenicity, reproductive toxicity, etc. Persistence, bioaccumulation, aquatic toxicity, etc. 8 states currently working on AA guidance States: CA, CT, MA, MI, MN, NY, OR, WA Constructed using modules covering individual parts of an AA including hazard, exposure, cost and availability, performance, life-cycle, etc.

18 Alternatives Assessment Benefits Risk Function (Hazard, Exposure) Optimized Risk-reduction becomes a two step process: 1. Identify chemicals with lowest possible hazard 2. Evaluate exposure of chemicals with lowest hazard Goal is to select alternative that has inherently low hazard and lowest possible exposure potential Exposure evaluation alone will not be employed to allow continued use of toxic chemicals as both steps are critical More info: Assessment/bid/208726/Alternatives-Assessments-Webinar-Slides-Recording

19 AA benefits for companies Most companies can t control exposure but can control hazard by selecting safer chemicals Inherently safer chemicals in products have benefits throughout entire life-cycle Reduces brand risk for companies Risk assessment is a complicated and expensive process for companies requiring high degree of technical expertise Alternative Assessment guidance and tools now appearing

20 Alternatives Assessment: the wave of the future Continues to grow as focus - EPA Design for the Environment - US State assessments (ex. ME and WA) - AA incorporated in CA state regulations - Europe s REACH regulations include AA AA is still evolving Company leaders (ex. Hewlett-Packard) adopting AA tools now Guidance and tools available for small and medium size businesses

21 5. Development of Alternatives Assessment Tools

22 Alternatives Assessment Foundation Originated same time as Green Chemistry Principles (1998) 12 Principles to create products that are benign by design Starts at the formulating stage Implemented solely on new products Alternatives assessment developed to improve existing products US EPA Design for Environment (DfE) Program (1992) Voluntary program to work with businesses to reduce toxic use Established 16 toxicity criteria used to compare alternatives Established alternatives assessment process Conducts alternatives assessments Initiated product certification program

23 GreenScreen developed from US EPA Design for Environment DfE method adapted by Clean Production Action (CPA) - DfE does not make decisions about acceptability of alternatives - CPA adapted DfE methodology and created GreenScreen for Safer Chemicals Differences between GreenScreen and DfE method - GreenScreen ranks chemicals in specific benchmarks from Benchmark 1 (avoid) to Benchmark 4 (prefer) - Standardized methodology - Made it more useable by organizations GreenScreen adopted by US states and progressive companies - US States: Washington, Maine, California - Companies: Hewlett-Packard, et al.

24 US EPA DfE Method Assesses hazards of chemicals against 16 human health, environmental and physical criteria

25 Most chemicals have data gaps Challenges of screening chemicals 85% of chemicals lack complete hazard information GreenScreen deals uses modeling (QSAR) where possible and notes lower confidence gaps are filled in with modeling data GreenScreen penalizes alternatives with data gaps in benchmarking process

26 6. Introduction to the Quick Chemical Assessment Tool QCAT

27 New GreenScreen based tools ListTranslator - Easily accessible tool for users new to alternatives assessment - Compares alternative against lists of chemicals of concern - Quickly identifies chemicals to avoid and why Quick Chemicals Assessment Tool (QCAT) - Starts with ListTranslator - Adds more sources of data - Improved identification of chemicals to avoid and why

28 Quick Chemical Assessment Tool (QCAT) Stripped down version of GreenScreen Improved identification of Benchmark I chemicals Does not identify greener alternatives Easier to use than GreenScreen Intended for use by companies with limited resources and expertise Allows companies to become familiar with alternatives assessment process

29 QCAT (cont.) Available on web:

30 QCAT (cont.) Background - Developed as a tool for small and medium businesses with limited resources and expertise - Between more complicated GreenScreen and simpler ListTranslator - Consists of two data evaluation steps List comparison (similar to ListTranslator) Data from additional databases and other readily available sources - Method only ~20 pages but ~80 pages of screen captures and detailed information on how to access desired information Positives and negatives - Part of an alternatives assessment - Simpler and easier to implement - Fewer Regrettable Substitutions - Not as complete as more detailed alternatives assessment so less confidence that alternative is truly green How does QCAT work?

31 QCAT (cont.) QCAT GS Human Health: Tier I Carcinogenicity (C) X X Mutagenicity & Genotoxicity (M) X X Reproductive toxicity (R) X X Developmental toxicity (incl. developmental neurotoxicity) (D) X X Endocrine activity (E) X X Tier II Acute Mammalian Toxicity (AT) X X Systemic & organ effects toxicity incl. Immunotoxicity (ST) X Neurotoxicity (N) X Sensitization: Skin (SnS) X Sensitization: Respiratory (SnR) X Irritation & Corrosivity: Skin (IrS) X Irritation & Corrosivity: Eye (IrE) X Ecological: Acute Aquatic Toxicity (AA) X X Chronic Aquatic Toxicity (CA) X Other Ecotoxicity Studies, when available (optional except for Benchmark 4) (Eo) X Environmental: Persistence (P) X X Bioaccumulation (B) X X Physical: Reactivity (R) X Flammability (F) X

32 QCAT (cont.) QCAT prioritizes: CMRs PBTs Aquatic toxics Worker Health & Safety Contains 2 steps: 1. ListTranslator 2. Additional data sources

33 QCAT (cont.) Implementation: 1. Step 1: Evaluate alternatives using ListTranslator 2. Eliminate Grade F alternatives 3. Step 2: Evaluate using additional data sources 4. Eliminate Grade F alternatives 5. Grade chemicals based upon GS criteria

34 QCAT Step 1 Sources: Background - Compares alternatives with authoritative lists of toxic chemicals California Proposition 65 List of carcinogencs and reproductive toxics International Agency for Research on Cancer carcinogens National Toxicology Program Lists of carcinogens and reproductive toxics Etc. - Any chemical on authoritative list and identified as a serious concern assigned a Grade F - Companies can quickly and easily identify hazardous chemicals to avoid or substitute - Automated for easy use as ListTranslator

35 ListTranslator Where can you find it? Pharos database created by Healthy Building Network GreenWERCS, data provider to Wal-Mart Under development: UC Berkeley developing 3 rd software portal for accessing ListTranslator

36 ListTranslator Example - Pharos

37 Live demo of Pharos Pharos link: Advantages Inexpensive ($180 per year) Provides single source for chemicals on authoritative lists Automatically coverts results to GreenScreen benchmarks

38 Step 2 Sources Databases and documents with readily available information: Databases European Union REACH Hazardous Substances Database Registry of Toxic Effects from Chemical Substances (RTECS) Documents European Union Risk Assessments OECD Safety Information Datasheets (SIDS) Modeling data EPA PBT Profiler Japan GHS Risk Phrases

39 Step 2 Sources EPA PBT Profiler P B

40 Assigning Rank with QCAT QCAT instructs on how to assess data and assign ranking Appendix 8: Chemical Ranking Criteria From PBT Profiler From above Table: Rank = H

41 Assigning Rank with QCAT (cont.) From PBT Profiler From above Table: Rank (w) = M Rank (s) = H Rank (sed or ss) = vh Ranks (a) = H

42 Assigning Rank with QCAT (cont.) Assessment of data Human - Group 1 Human - Group 2 Eco Fate Physica l C M R D E AT ST N SnS SnR Ir s IrE AA CA Eo P B Ex F Chlorinated DG L L L DG M?????? M?? vh vl?? Fluorinated L L L L DG L?????? DG?? vh vl??? identifies criteria not evaluated DG indicates data gap Grade chemical based upon this data

43 Final QCAT Results Based upon GS benchmarking criteria Grade A Low P + Low T (AA, AT and all HH endpoints). Grade B Moderate P; or Moderate B; or Moderate AA; or Moderate AT or one or more HH endpoints. Grade C Moderate P + Moderate B + Moderate T (AA, AT, or any HH endpoint); or High P & High B; or High P + Moderate T (AA, AT, or any HH endpoint); or High B + Moderate T (AA, AT, or any HH endpoint); or Very High T (AA or AT). Grade F PBT = High P + High B + [Very High T (AA or AT) or High T (HH)]; or vpvb = very High P + very High B; or vpt = very High P + [very High T (AA or AT) or High T (HH)]; or vbt = very High B + [very High T (AA or AT) or High T (HH)]; or High T (HH).

44 Assigning Rank Assessment of data Human - Group 1 Human - Group 2 Eco Fate Physical C M R D E AT ST N SnS SnR Irs IrE AA CA Eo P B Ex F Chlorinated DG L L L DG M?????? M?? vh vl?? Fluorinated L L L L DG L?????? DG?? vh vl?? Grade Initial Final Chlorinated C C Fluorinated B F DG

45 Who is using QCAT? Who is currently using it? - Washington Pollution Prevention Staff - Consultants (Pollution Prevention Resource Center) - Companies as a screening tool (HP) - Organizations as a screening tool (GC3) Future Plans - Develop case studies with small and medium businesses - Begin posting both QCAT and GreenScreen assessments on the Interstate Chemicals Clearinghouse (IC2) database - Upgrade to include most recent information (Pharos ListTranslator, for example)

46 Where do companies start? Start asking about alternatives - Ask your supplier - Ask your supplier s competition - If you have them, approach your P2 support staff - Ask business associations - Just ask around and see what is happening! If you have an alternative, how do you know its safer? - Get training on techniques like GreenScreen, QCAT, etc. - Start collecting data for comparison Alternatives Assessment is a journey! You don t have to reach Nirvana with the first step! Incremental improvement is okay!

47 Options for small businesses Has it already been evaluated? Check: DfE, IC2 If not, do it yourself! - Run an evaluation using the GS ListTranslator - If not enough, use QCAT to find sources not in GS ListTranslator to give you even more information - Need more? Conduct a more thorough evaluation (ex: ME s deca-bde in shipping pallets alternatives assessment) Try to develop in-house expertise - Train staff - Experience using a ListTranslator cheapest option - Experience using QCAT slightly more expensive - Experience using GreenScreen develop or hire expertise

48 6. Conclusions

49 Summary Increasing concerns about toxic chemicals are causing companies to look for safer alternatives to toxic chemicals in their products Toxic chemicals are undergoing increasing scrutiny and regulation Risk Assessment tools are not adequate on their own to assess alternatives to toxic chemicals Developing science of alternatives assessment is the wave of the future: company leaders adopting this approach All companies should know all their chemical use and their inherent hazards to mitigate business risk New Tools like QCAT now available

50 Resources EPA Design for the Environment: GreenScreen: Quick Chemical Assessment Tool (QCAT): Pharos database: TheWercs: Multi-state alternatives assessment guidance: Nike: RSL: ance_aug_2011.pdf Sustainability:

51 Contacts Alex Stone Safer Chemical Alternative Chemist Washington State Department of Ecology (360) Ken Zarker Manager, Pollution Prevention & Regulatory Assistance Washington State Department of Ecology (360)

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