Infusing TSCA with Green Chemistry: Infusing TSCA with Green Chemistry: The Role of Innovation in Chemical Risk The Role of Innovation in Chemical Risk

ManagementManagement

Dr. Kira Matus

Senior Policy AnalystCenter for Green Chemistry and Green EngineeringYale University

June 11, 2010

Green chemistry is the design of chemical products and processes that reduce or eliminate the use and generation of hazardous substances.

• Anastas, P. T. and Warner, J. C. Green Chemistry: Theory and Practice, Oxford University Press: New York, 2000.

• Prevent use and/or generation of hazardous chemicals

• Chemistry for sustainability• “Benign by design”• Pollution prevention at the molecular level, NOT

waste remediation or pollutant detection

Provide a framework for design of new materials, products, and processes.

Focused on sustainable design criteria Proven time and again to be the source of innovative

solutions to a wide range of problems Systematic integration of these principles is key to

achieving genuine sustainability for the simultaneous benefit of the environment, economy, and society.

• Anastas, P. T. and Warner, J. C. Green Chemistry: Theory and Practice, Oxford University Press: New York, 2000.

1. Prevention2. Atom Economy3. Less Hazardous Chemical Syntheses4. Designing Safer Chemicals5. Safer Solvents and Auxiliaries6. Design for Energy Efficiency7. Use of Renewable Feedstocks8. Reduce Derivatives9. Catalysis10. Design for Degradation11. Real-time Analysis for Pollution Prevention12. Inherently Safer Chemistry for Accident Prevention

• Molecular Design

• Life-Cycle Thinking:• Anticipate potential impacts• Consider entire process, from input materials

through end-of-life

• Interdisciplinary• Chemistry• Environmental Science• Toxicology• Engineering• Economics

Get it right the first timeGet it right the first time

What role should green chemistry and green engineering play in a reformed TSCA?

Key Questions about TSCA Reform to Develop a GC&E Strategy

What are the drivers behind the movement for TSCA reform?

What are the goals of a “reformed TSCA”? What are the key lessons from the last 30 years of TSCA

in practice? What does it take to construct an adaptive, flexible,

resilient chemicals policy? How can, or should, “reformed TSCA” impact

innovation? How can green chemistry and green engineering be

critical parts of resilient, forward-looking chemical risk management, and how should they be built into the regulatory system?

◦ Must not stifle innovation generally with unnecessary resource burdens, and

◦ Should favor innovations that improve safety and reduce environmental impacts.

Adoption of an anticipatory, preventative approach to chemicals management based on inherent hazards

Mechanisms and incentives to provide financial, technical and policy support for GC&E innovation

Incentives for GC&E in any review process Continuous improvement

• No explicit inclusion of green chemistry• Registration exemption (pre-1976) favors older,

existing technologies• No minimum health and safety data

requirements• Difficult to compel testing• CBI – limitations on data availability

“SAFER ALTERNATIVES AND GREEN CHEMISTRY AND ENGINEERING”

• National GC research centers• GC research grants• GC workforce education and training• Incentives:

• Expedited review for safer alternatives• Labels for safer alternatives• Awards and incentives for safer

alternatives

Incentives are to fix problems once they occur◦ Efficient?◦ What does this mean for health of people and the

environment?◦ Is this even feasible?

•Technical•Regulatory•Economic•Cultural•Organizational•Definition and Metrics

TSCA reform is an TSCA reform is an opportunityopportunity to to reduce barriersreduce barriers

Start to think PROACTIVELYPROACTIVELY

• Data• Incentives• Awareness• Collaboration• Prevention

• Hazard Reduction• Forward-looking• Continuous Improvement

Increase the availability of more benign chemicals => reduce the overall TSCA workload

Encourage the development of advanced life cycle assessment and modeling tools

Contribute to fundamental solutions that are robust over the long term

Make use of GC to evaluate health, safety, and environmental impacts

◦ Authority to compel submission of green

chemistry metrics as part of its data required for chemical evaluations.

◦ Program for public reporting of green chemistry information submitted by firms

◦ Use submitted green chemistry data as a baseline for determination of “greener alternatives”

Create incentives for better performance on health, safety, and environmental criteria, and/or to switch to less hazardous alternatives.

◦ Establish and consistently enforce standards for manufacture and use of hazardous chemicals.

◦ Design preferential pre-manufacture notice timelines and information requirements

◦ Positive incentive mechanisms

Use information collected by the EPA to help drive GC forward.◦ Accumulate data on impacts, and deploy it to

help develop tools to improve the design and analysis of chemicals (i.e. systems to aid with molecular design, information for use in LCA, etc…)

◦ Act as a center for the communication of information regarding impacts of chemicals in use and potential alternatives.

Implement a coordinated, inter-agency R&D fund overseen by a variety of agencies

◦ Basic R&D funding for major, pre-competitive platforms and technologies in priority chemical sectors

◦ Large scale funding (like DARPA, DOE) to help green innovations in key areas transition from the laboratory to full-scale industrial use

Recognize and support state-level programs

◦ Education◦ R&D◦ Technical outreach programs for small and

medium sized firms

Recognize and broaden Design for the Environment (DfE) and other cooperative programs between industry and government.

• TSCA is just one piece of the puzzle• Other chemical regulation (federal)• International perspective (i.e. REACH)• Green Chemistry specific regulation• State level programs

Use GC as a powerful tool to develop the next generation of chemical innovations

More efficient to design chemicals to be as benign as possible from the outset,

Eliminate the need to develop safer alternatives

GC is a market-oriented, economically favorable, preventative approach ◦ Act in advance of impacts

Enhance the broader sustainability of the chemical enterprise in the United States.

Dr. Julie B Zimmerman Dr. Evan Beach Erin McBurney

Workshop ParticipantsCharles AuerKlaus Berend, Blake BilesGregory BondWilliam ClarkJoseph FikselBob IsraelWarren MuirTom OsimitzMichael ParrJohn Wargo Jeffrey WongJim Young