DfE Criteria for Alternatives to “Hazardous” Chemicals Needs to be Broader, Clearer, ACI Tells EPA
The U.S. Environmental Protection Agency (EPA) needs to better explain how it will apply proposed new criteria in its Design for the Environment (DfE) Program for evaluating and comparing the safety of chemicals in consumer products, says the American Cleaning Institute®.
The DfE program evaluates human health and environmental concerns associated with traditional and alternative chemicals and processes in a range of industries. EPA has developed Alternatives Assessment (AA) Criteria for Hazard Evaluation as a “transparent tool for evaluating and differentiating among chemicals based on their concern for human health and environmental hazard,” according to the Agency.
In January 31, 2011 comments to EPA, ACI says the agency should more clearly explain how the Criteria for Hazard Assessment will be used in the Alternatives Assessment process to compare multiple alternatives to one another.
Under EPA’s plan, substances will be categorized as either “High,” “Moderate,” or “Low” concern and, as a result, for any specific endpoint, one could place each substance on a continuum of relative hazard.
“However, the agency needs to clarify how one would utilize these categorization criteria to compile one continuum for a group of alternative materials being assessed against an existing material. It would seem that a key objective of the hazard evaluation process has not been addressed. It is important for all stakeholders to have the opportunity to comment on perhaps the most challenging, yet most important, aspect of the evaluation process,” wrote Dr. Paul DeLeo, ACI’s Senior Director of Environmental Safety.
ACI also says that EPA should apply broader sustainability criteria when evaluating a particular chemical and its uses against alternative chemicals for each of the same uses.
“EPA intends to rely disproportionately on hazard-based criteria when evaluating the (safe) use of a chemical substance in a product, and when identifying potential alternative,” wrote DeLeo. “Such a limited approach can be flawed on several levels especially when hazard-based metrics are applied as the sole criteria for chemical selection.
The hazard-evaluation-only approach proposed for the DfE AA Criteria also fails to consider other significant factors which influence the health and environmental impacts associated with a product. For many products, such as cleaning products, changes in certain components often can have significant impacts on the energy and water consumption characteristics associated with the use of the products. Therefore, for an alternatives assessment to effectively consider the potential human and environmental impacts of an alternative, consideration must be given to all phases of the product’s lifecycle to significantly improve the sustainability profile of a particular product.
EPA’s proposed hazard-evaluation-only approach for alternative assessment should be modified to more fully assess a product’s entire lifecycle and consider the health and environmental impacts of substituting alternative chemistries across the entirety of the product’s lifecycle.”
ACI also believes that EPA should reconsider and enhance the criteria it has selected, including the use of European Union criteria and authoritative lists which U.S. stakeholders were not able to comment on during their development in Europe.
ACI also pointed out to the Agency that since recent Chemical Action Plans (CAP) have included requirements that the Design for the Environment program be utilized to find safer alternatives in resulting chemical management requirements, the proposal should be subject to official public review and comment under the APA. Similarly, since EPA has already initiated a public review and comment on implementation of the GHS (Global Harmonized System for Labeling and Classification of Chemicals), the Agency should specifically address comments already submitted to the Agency before considering application of GHS criteria in this new program.
“ACI remains committed to working collaboratively with EPA to develop well recognized and reliable criteria for assessing chemicals-related risks and to identifying alternative chemistries which provide an effective means to reduce such risks,” added ACI’s Paul DeLeo.