|Approaches for better information and monitoring of POPs in articles|
|Monitoring of POPs in articles and products|
|Alternative assessment approaches for chemical alternatives|
|Screening of potential POPs in chemical databases|
|Tools for the assessment of POPs properties of chemicals|
|Toxicity assessment of alternatives|
|Case study: Scientific assessment of a PFOS alternatives in chromium plating|
While the guidance document from the POPs Review Committee has been specifically developed for the assessment of POPs alternatives, several reports, projects and methodologies for the assessment of chemical alternatives have been developed and are publicly available. These chemical alternative assessment approaches and tools can also support the assessment of the alternatives to POPs chemicals and help to ensure that alternatives are not other POPs or POPs-like chemical.
The OECD Ad Hoc Group on Substitution of Harmful Chemicals conducted and published in 2013 a review of the current status of substitution and alternatives assessment practices. The knowledge gained through the review process was the foundation for the development of the OECD Substitution and Alternatives Assessment Toolbox to support decision-making.
The toolbox comprises of four resource areas. The Alternatives Assessment Tool Selector area is a filterable inventory of chemical hazard assessment tools and data sources to help in the identification of the most relevant tools to substitution and alternatives assessment goals. A listing of non-hazard assessment tools is also available. The Alternatives Assessment Frameworks area offers a summary of the current frameworks that can be used to assess alternatives. Guides and other resources for conducting a chemical substitution or alternatives assessment are included. The Case Studies and Other Resources area provides links to case studies, toolkits, and product rating systems that provide examples, insights, and lessons learned on substitution and alternatives assessment approaches. The Regulations and Restrictions area includes a list of regulations and restrictions throughout OECD member countries that are driving the increased need for chemical substitution and alternatives assessment approaches.
Some of the most helpful materials and approaches are compiled in this section.
Common Principles of Alternatives Assessment
Assessing the relative hazard of alternatives to chemicals of concern has become an increasingly powerful and robust approach to implementing changes to promote safer chemicals and materials that are technically and economically feasible. The Toxics Use Reduction Institute (TURI) is a leading organization promoting this approach and has conducted a number of formal alternatives assessments. According to TURI, an alternatives assessment looks comprehensively at the uses of chemicals of concern, and the availability of safer, technically feasible and affordable alternatives. These alternatives may include chemical substitutions, process modifications, product redesigns, or other changes that facilitate the shift to safer processes and products.
TURI has contributed to the development of a harmonized set of principles for alternatives assessment methodology. The Commons Principles of Alternatives Assessment, designed to guide any alternatives assessment project. The Commons Principles are:
Useful resources for information related to hazard assessment and reduction include:
A) Available screening methods for more quickly identifying preferable chemicals:
B) Methods for displaying data to facilitate decision making on alternatives:
Case study: The Massachusetts Toxics Use Reduction Act (TURA)
Under the Massachusetts Toxics Use Reduction Act (TURA), companies that use toxic chemicals above a specified threshold are required to report on their use of the chemical each year and conduct Toxics Use Reduction Planning every two years. The law is designed as a complement to other environmental and occupational safety laws. It is intended to encourage companies to reduce toxics as a means to comply with other laws, and to reduce total use of toxic chemicals while enhancing company performance.
A Toxic Use Reduction Plan must establish two- and five-year goals for by-product reduction of listed chemicals used in that facility/company. Plan documents are maintained at the facility, and a plan summary is submitted to the State. Plans may be inspected by a governmental official on request. Plans are formally updated every two years, including an assessment of the implementation schedule and Toxic Use Reduction commitments.
In the Toxics Use Reduction Planning process, companies are required to identify opportunities for reducing or eliminating the chemical of concern; analyze any hazards of alternatives they identify; and conduct a technical and economic feasibility analysis. Based on the results of this required analysis, companies choose which options to implement.
Use reporting includes total amount of the chemical manufactured, processed, or otherwise used; amount generated as byproduct; and amount “shipped in product” (included in the final product), as well as information on waste emitted or transferred offsite. The requirement to track the amount generated as by-product helps to highlight inefficiencies in industrial processes and can motivate businesses to improve production processes. The requirement to track the amount shipped in product makes it possible to determine what chemicals are incorporated into a final product or article. All this information is made available to the public, except in cases in which the Massachusetts Department of Environmental Protection grants a company a trade secret exemption.
Over the first ten years of TURA, from 1990 to 2000, companies subject to the law reduced their use of toxic chemicals by 40%, by-product by 58%, and emissions by 90%. From 2000 to 2012, companies continued to make progress, reducing use by 23%, by-product by 42%, and emissions by 73%. These reductions were achieved largely by adopting more efficient manufacturing methods that in turn saved the firms money.
A survey of companies subject to TURA found that 51% experienced improved worker health and safety; 41% achieved financial savings; 33% achieved improved compliance with other state or federal regulations; 29% achieved improvements in production efficiency; and 21% achieved improved product marketing.
The Toxics Use Reduction Act defines several activities that can qualify as toxics use reduction. These include: input substitution, product reformulation, production unit redesign and modification, production unit modernization, improved operations and maintenance, and “integral recycling” (re-use of a material that occurs strictly within a single, hard-piped production process). In any case in which a company considers substituting one chemical for another, the TURA process requires a thorough evaluation of the environmental health and safety characteristics of the alternative.
The development of a common set of principles for alternatives assessment by the Toxics Use Reduction Institute and other institutions has contributed to this reduction by facilitating the introduction of safer alternatives.
 Massey RI, Tenney H, Harriman E (2011) “Higher Hazard Substances Under the Massachusetts Toxics Use Reduction Act: Lessons from the First Four Years.” New Solutions 21:3, 457-476.
 Massey RI (2011) Program assessment at the 20 year mark: experiences of Massachusetts companies and communities with the Toxics Use Reduction Act (TURA) program. Journal of Cleaner Production 19, 2012, 505-516.
The Lowell Center for Sustainable Production has developed its Alternatives Assessment framework with the goal of creating an open source framework for the relatively quick assessment of safer and more socially just alternatives to chemicals, materials, and products of concern and guidance have been developed. Within their activities they have assessed alternatives for HCBD.
EPA's Design for the Environment process
The EPA's Design for the Environment (DfE) program is using a step-by-step process for conducting alternative assessment for enabling substitution to safer chemicals The "Alternatives Assessment Criteria for Hazard Evaluation" guidance goes through the step-by-step process that DfE is using in conducting alternatives assessments for chemicals as part of the EPA's Chemical Action Plans. .
Practical example of EPA's Design for the Environment (DfE) program related to POPs are the US EPA approach for use of alternatives in Printed Circuit Boards and assessment of alternatives to c-PentaBDE in PUR foam (Case study: Assessment of alternatives to c-PentaBDE in PUR foam in Alternatives to POP-PBDEs of Part III).
Case study: US EPA approach for use of alternatives in Printed Circuit Boards
C-PentaBDE and HBCD have been used to a smaller extent in printed circuit boards. Within the USEPA program on “Design for the Environment” the electronics industry formed a partnership to develop information that will improve their understanding of the environmental and human health impacts of new and current materials that can be used to meet the fire safety requirements for circuit boards (US EPA 2008). One aim of the work was that the information from the partnership will allow industry to consider these impacts along with cost and performance of circuit boards as they review alternative materials and technologies. Participation of all interest groups was aimed at ensuring that the full range of views was considered from the start of the project and that they were incorporated appropriately into the project objective and methodology.
The partnership incorporated life cycle thinking into the project as it explored the potential hazards associated with flame retardants and potential exposures throughout the life cycle of flame retardants as used in FR-4 printed circuit boards. The scope included aspects of the life cycle where public and occupational exposures could occur. For example, consideration of exposures from incineration or burning at end-of-life was included, as were exposures from manufacturing and use.
The initial hazard assessment was conducted using EPA's criteria for the New Chemicals Program under the Toxic Substances Control Act (TSCA) to evaluate hazard concerns for each flame retardant formulation. The analysis explored hazard data associated with potential exposure scenarios. The partnership did not conduct a full risk assessment. The project is not a life cycle assessment, which inventories inputs and outputs from all (or most) processes throughout the life cycle and evaluates the environmental impacts associated with those inputs and outputs.
This partnership report provides objective information that will help members of the electronics industry more efficiently factor human health and environmental considerations into their decision-making when selecting flame retardants for printed circuit board applications (US EPA 2008)
 Lavoie ET; Heine LG; Holder H; Rossi MS; Lee REI; Connor EA; Vrabel MA; DiFiore DM; Davies CL (2010) Chemical Alternatives Assessment: Enabling Substitution to Safer Chemicals. Environmental Science & Technology 45, 1747-1747.
 US EPA (2008) Partnership to evaluate flame retardants in printed circuit boards. Draft November 2008. (The text is largely taken from project website)
Regulatory actions such as chemical or material restrictions can drive the need for alternatives assessment and the use of chemical hazard assessment methods such as the GreenScreen™ for Safer Chemicals. GreenScreen is a method for comparative Chemical Hazard Assessment (CHA) that can be used for identifying chemicals of high concern and safer alternatives. It is being used by industry, governments and NGOs as part of alternatives assessment to meet regulatory requirements and to support product design and development and materials procurement.
The GreenScreen™ can also be used to support environmentally preferable product procurement tools including standards, scorecards and ecolabels. It can be used to:
a) Help prioritize chemicals for further review and/or phase out;
b) Help companies identify safer alternative chemicals for use in formulations;
c) Meet client specifications for eliminating chemicals of high concern;
d) Support chemical management through environmental management systems;
e) Support corporate reporting on chemical uses;
f) Communicate materials goals and criteria to suppliers;
g) Serve as a resource for pollution prevention and technical assistance programs;
h) Guide internal product development processes.
To apply the GreenScreen for safer chemical alternatives, chemicals in products are screened against 18 human and environmental health hazard endpoints in order to identify any substance of very high concern and to differentiate among safer alternatives.
Four benchmark scores, ranging from 1-4, are possible in the GS method, with benchmark 4 representing the lowest hazard to humans or the environment. It is also possible for a chemical to receive an "unspecified (U)" Benchmark.
Both the GreenScreen hazard criteria and benchmarking system were developed to align with national and international precedents including the Globally Harmonized System of Classification and Labelling of Chemicals (GHS), OECD testing protocols and the European REACH legislation, while also ensuring that new and emerging science can be incorporated into the hazard assessment process.
The goal of the Substitution Portal (SUBSPORT) project is to develop an internet portal (http://subsport.eu) that constitutes a state-of-the-art resource on safer alternatives to the use of hazardous chemicals including POPs. It is a source of not just information on alternative substances and technologies, but also of tools and guidance for substance evaluation and substitution management.
A range of case studies related to POPs (POP-PBDE, PFOS and HBCD) are included and can be retrieved on the web-page. Some key case studies (e.g. on HBCD) are also mentioned and linked in this publication in the paragraphs of the related POPs.
The SUBSPORT web-site also refers to key POPRC documents related to substitution of POPs. The webpage is continuously updated.
At the European Union level a consortium comprising of Kooperationsstelle Hamburg IFE GmbH (KOOP), “Instituto Sindical de Trabajo Ambiente y Salud” (ISTAS), Madrid, International Chemical Secretariat (ChemSec), Gothenburg and Grontmij A/S, Copenhagen implemented for a 3 years period (Jan 2010 – March 2013) the SUBSPORT project, with financial support from the LIFE+ Programme of the European Union, Federal Institute for Occupational Safety and Health, Germany and Federal Ministry of Agriculture, Forestry, Environment and Water Management, Austria. The goal of the SUBSPORT project is to develop an internet portal that constitutes a state-of-the-art resource on safer alternatives to the use of hazardous chemicals. It should be a source of not just information on alternative substances and technologies, but also of tools and guidance for substance evaluation and substitution management.
The portal is intended to support companies in fulfilling substitution requirements of EU legislation, such as those specified under the REACH authorisation procedure, the Water Framework Directive or the Chemical Agents Directive. Furthermore other stakeholders like authorities, environmental and consumer organisations as well as scientific institutions will benefit from the portal. The internet portal SUBSPORT makes publicly available in four languages the information on:
In addition, the project created a network of experts and stakeholders who are active in substitution. The network assisted in content development and promotion of the portal as well as ensuring sustainable updates and maintenance. This contributed to the project’s goal of raising awareness and promoting safer alternatives. Furthermore, training on substitution methodology and alternatives assessment was provided.