Chemical alternatives assessment is a relatively new and highly promising methodology for analyzing products and processes that affect human health or the environment.
In July 2005, the Commonwealth of Massachusetts requested that the Toxics Use Reduction Institute perform an alternatives assessment for five chemicals: lead, formaldehyde, perchloroethylene (PCE), hexavalent chromium, and di(2-ethylhexyl) phthalate (DEHP). For each chemical, the Institute was charged with identifying significant uses in manufacturing, consumer products, and other applications; reviewing health and environmental effects; and evaluating possible alternatives. The Institute was also directed to evaluate possible effects on Massachusetts employment and economic competitiveness associated with adoption of alternatives. The study was conducted within a single fiscal year, and had a total budget of $250,000.
Rather than attempt to study all uses of each chemical, the Institute selected priority categories of use for each chemical. Likewise, for each use studied, the Institute chose a subset of possible alternatives for analysis. A total of sixteen different use categories and approximately one hundred different alternatives were analyzed.
This summary of the approach and methodology helps to demonstrate the viability of alternatives assessment to support decisions about chemicals and their alternatives. The full report , presents extensive factual information on each alternative but does not provide a ranking of the alternatives. It does provide information that will allow users to make informed decisions and, in some cases, to design additional research to fill remaining information gaps.
During the year, five teams of Institute staff and outside experts performed parallel alternatives assessments using a common process and methodology. The project was divided into three phases. In the first phase, the Institute identified uses of the five chemicals within Massachusetts, and prioritized a subset of those uses to analyze in depth. In the second phase, the Institute identified alternatives and, again, chose priority alternatives for further study. In the third phase, the Institute conducted detailed research on each of the priority alternatives, gathering information on the health and environmental, technical, and economic aspects of each alternative. For each phase of the analysis, information from experts and publicly available resources was used. There was also extensive consultation with stakeholders, including industry representatives, government agencies, and public health, environmental and labor advocates.
Prioritization of Chemical Uses
To address the wide range of uses of each chemical considered, a subset of these uses was selected based on the importance of each use in Massachusetts, the potential availability of alternatives, the extent of possible exposures for workers and the general population, and the potential utility for Massachusetts businesses and citizens of the alternatives assessment. To maximize the value of this pilot project, an effort was made to include a mix of uses relevant for industry, small business, and consumer products. A low priority was placed on uses where alternatives are already being readily adopted, or where significant research on alternatives is being carried out by others.
Prioritization of Alternatives
Alternatives to toxic chemicals may include drop-in chemical substitutes, material substitutes, changes to manufacturing operations, changes to component/product design, and other technological or market solutions. The Institute identified more than 200 possible alternatives for the chemical uses of interest, then applied a health and environmental screen to all alternatives. The screen excluded any chemical that was a known or probable human carcinogen, failed a persistence, bioaccumulation, and toxicity (PBT) screen, or was included on the 1999 More Hazardous Chemicals list developed by the Massachusetts Toxics Use Reduction program's Science Advisory Board.
Of the options that passed this initial screening, the prioritized alternatives of for further study was based on additional information about viability, health and environmental effects, economic considerations, and importance to stakeholders. Products or materials manufactured in Massachusetts were given preference.
When several alternative chemicals or materials could be grouped together, the Institute selected a representative of that grouping for detailed consideration. Inclusion of an alternative in the assessment does not imply an endorsement of that alternative. Similarly, exclusion of an alternative from the assessment does not imply that it has been rejected. In some cases, such absence may mean alternatives have been studied in depth in another context. Some alternatives, particularly those comprised of single chemicals, were assessed as generic alternatives. Other alternatives vary considerably depending on the precise formulation or manufacturer, in which case a representative product was assessed.
The study included consideration of health and environmental effects, technical feasibility, and financial feasibility.
- Health and environmental effects. A subset of environment, health and safety (EH&S) endpoints was evaluated, but a detailed toxicological review for each alternative was not performed. Rather, the study relied on information obtained from authoritative bodies, emphasizing the most recent validated data or data that has been referenced by a US government agency. Where this type of information was not available, or where more recent studies called into question the results previously published by authoritative bodies, supplementary information was noted. The Institute relied on the U.S. EPA PBT Profiler software to gain information on persistence, bioaccumulation potential and toxicity. In cases in which it was necessary to evaluate chemicals in mixtures, the assessment considered each of the chemical constituents, excluding those making up 1% or less by mass of the mixture.
- Technical feasibility. The study identified and assessed application-specific performance requirements that must be met for each feasible alternative. The performance information that the Institute was able to obtain varied considerably among uses. For some uses information was obtained from published studies or directly from technical experts or several users of the alternatives. For other uses the Institute relied on information provided by product manufacturers. The type of performance information that was available for a given alternative will affect the degree and nature of follow-up that may be necessary for users to draw conclusions about technical feasibility for individual applications.
- Financial feasibility. Data sources for financial information included manufacturers, stakeholders, the Chemical Economics Handbook and other standard reference sources. In many cases, particularly for emerging alternatives, no hard cost information was available. In other cases, sufficient cost information exists to conclude that the alternative is either more or less costly than the current chemical use. The Institute recognizes that cost comparisons today may be of limited relevance for emerging technologies and technologies that are gaining in popularity, since learning curves, economies of scale, and other factors can reduce costs over time.
The study was not designed to assess the relative safety of one alternative over the other. Rather, alternatives were compared to the study chemical as a baseline. Users should use the large ammount of material presented here for guidance in conducting their own assessments, taking into account the values, priorities, and situation-specific requirements that are most relevant for their organizational, industrial, or policy goals.