Require Safer Substitutes and Solutions: Making the Substitution Principle the Cornerstone of Sustainable Chemical Policies

Abstract

Currently, chemical regulations in the United States do not prioritize the production and use of inherently safe chemicals. At present, when regulations get passed to target a chemical for control, safer substitutes are not the goal nor are there specific guidelines or tools used to achieve Green Chemistry, Clean Production, or sustainable product design. In most cases, the replacement is often just as hazardous or simply a reduction of the quantity or concentration of the toxic substance that has been targeted. In contrast, by placing the Substitution Principle at the heart of new chemical policies and regulations, hazardous chemicals would be replaced with less hazardous alternatives or preferably alternatives for which no hazards can be identified. This would hasten the uptake of Green Chemistry, or environmentally benign chemical synthesis. Substituting hazardous chemicals goes beyond finding a drop-in chemical alternative and can include systems, materials or process changes. Regulatory drivers include a clear timeline for phase out of priority chemicals based on their inherent hazard, mandatory substitution planning for hazardous chemicals, financial and technical support for companies to find safer materials, and increased funding for green chemistry development and uptake by companies.

Mapping the contours of an emerging phase out science

“…These historical and ongoing experiences suggest that a holistic understanding of phase-out is required, along with policy designs that embed phase-out goals into agendas for broader sustainability transformations [15]. Such policies should avoid the trap of targeting problematic technologies, substances and processes as individual components, with limited efforts to confront the broader systemic forces that sustain their production and use [28,45].…”

Industry and geographic patterns of use and emission of carcinogens in Ontario, Canada, 2011–2015

“…In addition, since particulate matter has been identified as a major air pollutant contributing to the environmental burden of cancer in Ontario (Cancer Care Ontario, Ontario Agency for Health Protection and Promotion 2016 ), efforts should be made to reduce these emissions from all sectors. By shifting towards greener chemistry alternatives, sectors could take steps to reduce, substitute, or eliminate the use and release of hazardous industrial pollutants by altering production processes or redesigning products and systems (Thorpe and Rossi 2007 ).…”

The California Safer Consumer Products Program: Evaluating a Novel Chemical Policy Strategy

“…In the early 2000s, due to frustration with risk-based chemical regulation, several policy experts proposed a different approach based on hazard identification and alternatives analysis (AA). 9–13 This approach sets as a goal the elimination of the hazard (and associated risk), by replacing toxic chemicals with safer alternatives. Establishment of a hazard removes the need to conduct a full quantitative risk assessment, although some knowledge of exposure remains necessary to prioritize chemicals.…”