1. Alex Stone Washington Department of Ecology NAHMMA Meeting 2 June 2015 Alternatives Assessment: The Search for Safer Substitutes

2. Contents  Definitions  Explain why we care  Summarize recent activities in Alternatives Assessment

3. Definitions

4. 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

5. Phase out hazardous chemicals yes! But how can one avoid regrettable substitutions?

6. Alternatives Assessment Definition: – 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

7. 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

8. Chemical Hazard Assessment Definition: – 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 Pharos Database – ChemHat ChemHat – Interstate Chemicals Clearinghouse CHA Database Interstate Chemicals Clearinghouse CHA Database – GreenScreen and GreenScreen Store GreenScreen and GreenScreen Store – OECD Toolbox OECD Toolbox – Quick Chemical Assessment Tool (QCAT) Quick Chemical Assessment Tool (QCAT)

9. Why We Care!

10. 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

11. 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)

12. 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?

13. Additional Concerns

14. Autism Concerns (cont.) Recent data (2014) from the Centers for Disease Control and Prevention

15. 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.

16. 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

17. 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 function 1 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

18. Recent Activities in Alternatives Assessment

19. 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

20. IC2 AA Guide http://theic2.org/article/download-pdf/file_name/IC2_AA_Guide_Version_1.0.pdf

21. 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

22. 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

23. OECD Toolbox – Organization for Economic Cooperation and Development (OECD) recently released AA ToolboxAA Toolbox – Assist users with AA

24. 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)

26. Contacts Alex Stone Washington Department of Ecology Safer Chemical Alternative Chemist (360) 407-6758 Alex.Stone@ecy.wa.gov Ken Zarker Washington Department of Ecology Pollution Prevention and Regulatory Assistance (360) 407-6724 Ken.Zarker@ecy.wa.gov