Uploaded by Emre Akcaoglu

Geiser et al-Risk Analysis

See discussions, stats, and author profiles for this publication at: https://www.researchgate.net/publication/285585412
The Architecture of Chemical Alternatives Assessment
Article in Risk Analysis · December 2015
DOI: 10.1111/risa.12507
4 authors, including:
Ken Geiser
Joel Tickner
University of Massachusetts Lowell
University of Massachusetts Lowell
Sally Edwards
University of Massachusetts Lowell
Some of the authors of this publication are also working on these related projects:
Mainstreaming sound chemicals management @ UN Environment Chemicals Branch View project
Global Chemicals Assessment View project
All content following this page was uploaded by Sally Edwards on 23 March 2020.
The user has requested enhancement of the downloaded file.
Risk Analysis
DOI: 10.1111/risa.12507
The Architecture of Chemical Alternatives Assessment
Kenneth Geiser,1 Joel Tickner,1,∗ Sally Edwards,1 and Mark Rossi2
Chemical alternatives assessment is a method rapidly developing for use by businesses, governments, and nongovernment organizations seeking to substitute chemicals of concern in
production processes and products. Chemical alternatives assessment is defined as a process
for identifying, comparing, and selecting safer alternatives to chemicals of concern (including
those in materials, processes, or technologies) on the basis of their hazards, performance, and
economic viability. The process is intended to provide guidance for assuring that chemicals of
concern are replaced with safer alternatives that are not likely to be later regretted. Conceptually, the assessment methods are developed from a set of three foundational pillars and five
common principles. Based on a number of emerging alternatives assessment initiatives, in
this commentary, we outline a chemical alternatives assessment blueprint structured around
three broad steps: Scope, Assessment, and Selection and Implementation. Specific tasks and
tools are identified for each of these three steps. While it is recognized that on-going practice
will further refine and develop the method and tools, it is important that the structure of the
assessment process remain flexible, adaptive, and focused on the substitution of chemicals of
concern with safer alternatives.
KEY WORDS: Alternatives assessment; chemical alternatives assessment; chemical substitution; functional use; safer alternatives
the state documented a 97% reduction in TCE use
in the metal-working and fabrication sector.(1)
Beginning in 2007, Hewlett Packard (HP) began to phase out the use of brominated flame retardants in its laptop housings. With the incentive of the
E.U. restrictions on brominated flame retardants, HP
launched an intensive effort to identify safer flame
retardants by requiring suppliers to perform hazard
assessments of the alternatives. Because the substitution of one chemical for another can cost tens of millions of dollars, HP wanted to ensure that the alternatives selected would not need to be replaced because
they were subsequently found to be hazardous.(2)
Both of these cases share a common element:
the careful evaluation and selection of safer alternatives to a chemical of concern to reduce the
use of hazardous chemicals. The Commonwealth
of Massachusetts and HP employed “chemical
alternatives assessment” to facilitate the transition
to safer chemicals in production processes and
During the 1990s, the Massachusetts Toxics
Use Reduction Institute (TURI) worked with the
Commonwealth’s metal-working companies to
reduce the use of the solvent trichloroethylene
(TCE) in metal-degreasing operations. TCE is a
known carcinogen and neurotoxicant as well as
a common constituent of hazardous waste from
metal-working shops. Working together, TURI and
the companies identified a wide range of substitutes
for TCE by performing hazard, performance, and
cost assessments of the alternatives. After many of
the companies adopted the preferred alternatives,
1 Lowell
Center for Sustainable Production, University of Massachusetts Lowell, MA, USA.
2 Clean Production Action, Medford, MA, USA.
∗ Address correspondence to Joel Tickner, Lowell Center for Sustainable Production, University of Massachusetts, Lowell, MA,
USA; joel_tickner@uml.edu.
C 2015 Society for Risk Analysis
0272-4332/15/0100-0001$22.00/1 2
products. Chemical alternatives assessment is a conventional decision support method adapted to meet
the needs of businesses, governments, and scientists
in identifying and selecting alternatives to hazardous
chemicals. These assessments use a set of tools for
characterizing chemicals of concern and identifying,
comparing, and selecting safer alternatives that
avoid substitutions of one chemical of concern with
another of equal or greater concern.
Chemical alternatives assessment is not new.
This type of comparative chemical substitution
approach has been used to support waste reduction,
pollution prevention, and chemical accident prevention for almost three decades, and alternatives
assessment requirements have been written into national and global policies such as the Montreal Protocol and European health and safety legislation.(3–5)
Alternatives assessment is a core element of the National Environmental Policy Act’s requirements for
environmental impact assessment, the goal of which
is to foster better decisions and “excellent action”
through the identification of reasonable alternatives
that will avoid or minimize adverse impacts.(6,7)
In early debates regarding chemical risk assessment and risk management, Ashford and colleagues
introduced the concept of “technology options analysis (TOA)” as a decision analysis tool to identify
alternatives to hazardous chemicals in use in order
to promote primary environmental and occupational
health protections.(8) In the pollution prevention
context, Geiser describes facility planning (a centerpiece of the Massachusetts Toxics Use Reduction
approach) as a means to document how and why
chemicals are being used, establish priorities and
goals for toxics reduction, identify and evaluate potential alternatives, and monitor implementation.(9)
To support evolving pollution prevention and toxics
reduction initiatives, during the 1990s, the U.S.
Environmental Protection Agency (EPA) commissioned a series of reports that sought to evaluate
and develop tools and methods to support chemical
substitution. One such report, by the University of
Tennessee Center for Clean Technologies and Clean
Products, evaluated 51 different chemical ranking
and scoring systems that could be used in both a
qualitative risk ranking or chemical substitution
context.(10) Similar methodological development
occurred in Europe to support chemical substitution
and cleaner production policies.
Nonetheless, over the past decade there has been
a significant growth in market and policy pressures
for chemical substitution, particularly at the product
Geiser et al.
level, resulting in development of a number of new
tools, frameworks, and initiatives for alternatives assessment both in the United States and in Europe.
This commentary explores the foundations and
structure of chemical alternatives assessment and offers effective models for its implementation. While
alternatives assessment is a generic process, the focus
here is on chemical alternatives assessment, meaning
assessments of chemical, material, product, process,
and design alternatives to hazardous chemicals.3(11)
Everyday exposures to hazardous chemicals in
consumer products are of increasing concern to scientists, regulators, and consumers. Governments and
universities are investing significant research dollars
to study the toxicity of chemicals of wide concern,
such as bisphenol-A (BPA), phthalates, and halogenated flame retardants. The President’s Cancer
Panel and the Centers for Disease Control’s National
Conversation on Chemical Exposures both note that
while synthetic chemicals have contributed to modern society, they also have significant impacts on
human health.(12,13) Increasingly, government agencies at the state, federal, and international levels
are restricting or requiring substitution of specific
chemicals of concern in particular applications and
products (such as phthalates and BPA in children’s
At the same time, environmental advocates, with
broad support from consumers, are pressing companies to remove hazardous chemicals from their products. Health Care Without Harm,(15) the Healthy
Building Network,(16) Greenpeace,(17) the Campaign
for Safe Cosmetics,(18) and Safer Chemicals Healthy
Families(19) are among many groups actively campaigning for safer products. Consumer information
resources such as GoodGuide,(20) the Skin Deep
Cosmetics Database,
and Healthy Stuff
identify products to avoid based on their hazardous
chemistry and the availability of safer alternatives.
Driven by new government regulations and
growing consumer pressures, major brands, healthcare providers, and retailers are creating processes to
evaluate alternatives to chemicals of concern and using restricted substance lists (RSLs) to guide suppliers in avoiding these chemicals. Leading firms such
as Nike,(23) Steelcase,(27) Johnson and Johnson,(25)
Seventh Generation,(26) and Levi Strauss(27) all have
3 For
a good review, see Hester and Harrison.(11)
active chemicals management programs.(28) Kaiser
Permanente(29) and Dignity Health,(30) two of the nation’s largest nonprofit health-care providers, have
extensive programs designed for suppliers to avoid
chemicals of concern. Walmart recently announced
a policy for preferring suppliers that avoid 10
high-priority chemicals of concern and publicly disclose the chemical ingredients in their products.(31)
Target’s new chemical policy prefers suppliers that
avoid over a thousand chemicals of concern in certain products.(32)
Often absent from this growing drive to remove
dangerous chemicals from products is attention to
the methods and processes of alternatives assessment
to ensure substitution that avoids the selection of
hazardous alternatives.
Environmental health science, with its focus
on how environmental factors impact human and
ecosystem health, lays the foundation for chemical alternatives assessment. Greater knowledge of
chemical hazards and potential exposures enables
both the identification of chemicals of concern as
well as safer alternatives. Yet when environmental
health research is conducted in the regulatory environment, the practice of risk assessment often leads
to extended debates, stalled scientific panels, and,
ultimately, inaction. The recent controversies over
BPA, formaldehyde, and brominated flame retardant chemicals exemplify the need to move from a
problem-centered approach where governments and
corporations invest tens of millions of dollars into
understanding mechanisms of toxicity and associated
exposures, to a solution-oriented approach where research focuses more directly on the evaluation and
development of safer substitutes.(33)
Chemical alternatives assessment provides a
means for engaging corporations, governments,
workers, and citizens in searching for safer solutions.
As a 2012 National Academy of Sciences panel
on science for the U.S. EPA’s future concluded:
“The focus on problem identification sometimes
occurs at the expense of efforts to use scientific
tools to develop safer technologies and solutions.
Defining problems without a comparable effort to
find solutions can diminish the value of applied
research efforts.”(34) Not only can effective alternatives assessments generate better solutions, these
evaluations can provide incentives and guidance for
technical innovation and safer chemistries. Biologist
Mary O’Brien notes that “one of the most essential,
and powerful steps to change is understanding that
there are alternatives.”(35)
Corporate and government decisionmakers often know which chemicals they want to avoid, but
may be uncertain about what chemical, product, or
process redesigns are truly safer. In seeking to avoid
chemicals of concern, they may select alternatives
that at first appear to be good choices (for ease of
substitution, regulatory, performance, cost, or health
and safety reasons), but later turn out to exhibit
equal or, sometimes, more hazardous properties. Examples of regrettable substitutes include brominated
flame retardants, chlorofluorocarbons, chlorinated
solvents, and PCBs, all of which were used as substitutes for chemicals that presented acute occupational
hazards or the risks of fires and explosions.(3)
Recognizing the challenges of uninformed
chemical substitutions, an increasing number of
public policies require formalized alternatives
assessments.(3) For example, applicants for authorization of substances of very high concern under the
E.U. REACH Regulation must provide an “analysis
of alternatives” that considers their risks, the technical and economic feasibility of substitutes, and, in
some cases, various socioeconomic factors.(36) The
states of Washington and Maine both include requirements for conducting alternatives assessments
on priority hazardous chemicals in recent legislation. The new California Safer Consumer Product
Regulations require that companies wishing to sell
targeted products containing designated chemicals
of concern must complete alternatives assessments
to assist the state in implementing appropriate
regulatory responses.
Chemical alternatives assessment is a process
for identifying, comparing, and selecting safer alternatives to chemicals of concern (including those in
materials, processes, or technologies) on the basis of
their hazards, performance, and economic viability.
The primary objective of alternatives assessment is
to reduce risk to humans and the environment by
selecting safer alternatives based on the inherent
chemical and physical properties of chemicals.4(37)
The U.S. EPA calls this “informed substitution,”
4 Safer
alternative: an option, including the option of not continuing an activity, that is healthier for humans and the environment
than the existing means of meeting that need. For example, safer
Geiser et al.
which is defined as “a considered transition from a
chemical of particular concern to safer chemicals or
nonchemical alternatives.”(38)
Several chemical alternative assessment frameworks and methods have been developed in recent
years and more are likely to be created in the near
future.(39) In reviewing current methodologies, three
underlying pillars are identified.
r First,
chemical alternatives assessments are
action-oriented. Their intent is to support the
substitution of chemicals of concern with safer
alternatives. This action orientation helps to ensure that the analyses are sufficient to make
decisions and avoid lengthy studies that lead
to inaction. The National Environmental Policy Act’s Environmental Impact Assessment
(EIS) regulation includes a requirement for
alternatives assessment with regard to government proposals that might impact environmental quality. It states this action-orientation goal
eloquently: “NEPA’s purpose is not to generate
paperwork—even excellent paperwork—but to
foster excellent action . . . ”; the EIS “should
present the environmental impacts of the proposal and the alternatives in comparative form,
thus sharply defining the issues and providing a
clear basis for choice among options to the decision maker and the public.”(40)
Second, chemical alternatives assessments reduce risks by identifying chemicals that are
safer based on their inherent chemical and
physical properties. While some approaches
include attention to exposure considerations
(through evaluation of intrinsic properties such
as persistence and biodegradation or other
such surrogates or comparative characterization), chemical alternatives assessments primarily compare alternatives to hazardous chemicals based on the intrinsic properties of the
chemicals. Alternatives assessments start with
a different set of questions than a traditional risk assessment.(41) Rather than asking “is it safe?” or “is the risk acceptable?”
alternatives assessment asks “is it necessary?”
and “are there safer, feasible alternatives?” This
focus is consistent with how chemists approach
safer chemical design: modify the intrinsic char-
alternatives to a particular chemical may include a chemical substitute or a redesign that eliminates the need for any chemical
addition; see Tickner and Eliason.(37)
acteristics of a chemical to reduce hazard or enhance performance rather than establish exposure controls. It is also consistent with the hierarchy of controls and primary prevention as
practiced in occupational health.(42)
Third, the starting point of chemical alternatives assessment is the functional use or
“service” of the chemical. By focusing on functional use rather than the particular chemical
of concern, the assessment of alternatives is
able to move from “avoiding the chemical of
concern” to considering a broader range of
alternatives, including whether the particular
function is actually needed, such as antimicrobials in hand soaps (termed “functional
substitution”).(43) Chemical function can be
narrowly defined at the chemical level (such
as a plasticizer in polyvinyl chloride plastic) or
broadly defined at the product level (such as
a flexible polymer). In the U.S. EPA’s Safer
Choices program the agency provides toxicological guidance on what constitutes a safer
chemical for each functional use. Formulators
then certify that their alternative meets those
criteria, allowing for “best in class” alternatives
to be used for particular functional uses.(38)
The framing of function may increase the scope
and complexity of the assessment, but may
also open up opportunities for innovation and
fundamental product or chemical redesign.
The “Commons Principles for Alternatives
Assessment” embody these common pillars
(see Table I).(44) These principles, developed by a
collaboration of alternatives assessment researchers
and practitioners, are designed to guide a process for
informed decision making that supports the adoption
of safer substitutes and the elimination of hazardous
chemicals. They recognize that there may be no fully
“safe” alternative and acknowledge the importance
of minimizing exposure if the selected alternative presents concerns. The principles emphasize the
need for chemical alternatives assessments to use the
best available information. This includes integrating
information from authoritative government lists,
toxicological testing, data from high throughput
screening, and predictive modeling. The principles
highlight the importance of transparency about the
values, assumptions, and information that inform the
assessment, including points of uncertainty and data
gaps. Because assessments consider many attributes,
selection of an alternative may involve tradeoffs that
Table I. The Commons Principles for Alternatives Assessment
Reduce Hazard: Reduce hazard by replacing a chemical
of concern with a less hazardous alternative. This
approach provides an effective means to reduce risk
associated with a product or process if the potential for
exposure remains the same or lower. Consider
reformulation to avoid use of the chemical of concern
Minimize Exposure: Assess use patterns and exposure
pathways to limit exposure to alternatives that may
also present risks.
Use Best Available Information: Obtain access to and use
information that assists in distinguishing between
possible choices. Before selecting preferred options,
characterize the product and process sufficiently to
avoid choosing alternatives that may result in
unintended adverse consequences.
Require Disclosure and Transparency: Require disclosure
across the supply chain regarding key chemical and
technical information. Engage stakeholders throughout
the assessment process to promote transparency in
regard to alternatives assessment methodologies
employed, data used to characterize alternatives,
assumptions made, and decision-making rules applied.
Resolve Tradeoffs: Use information about the product’s
life-cycle to better understand potential benefits,
impacts, and mitigation options associated with
different alternatives. When substitution options do
not provide a clearly preferable solution, consider
organizational goals and values to determine
appropriate weighting of decision criteria and identify
acceptable tradeoffs.
Take Action: Take action to eliminate or substitute
potentially hazardous chemicals. Choose safer
alternatives that are commercially available,
technically and economically feasible, and satisfy the
performance requirements of the process/product.
Collaborate with supply chain partners to drive
innovation in the development and adoption of safer
substitutes. Review new information to ensure that the
option selected remains a safer choice.
require qualitative judgments based on the goals of
the assessment and the weight of evidence. Finally,
the principles encourage an action orientation and
a focus on continuous improvement and innovation
toward safer substitutes.
A number of different frameworks have been
developed that specify the process and steps of a
chemical alternatives assessment, with an increasing
number in recent years,(45,57) including the National
Research Council Framework for Selection of
Chemical Alternatives,(46) the Lowell Center for
Sustainable Production Alternatives Assessment
Framework,(47) the U.S. EPA Design for Environment (DfE) Alternatives Assessment Guidance,(48)
the BizNGO Working Group for Safer Chemicals
and Sustainable Materials Alternatives Assessment
Protocol,(49) and the Interstate Chemicals Clearinghouse (IC2) Alternatives Assessment Guide.(50)
The approaches exhibited in the various frameworks demonstrate that there is not a single chemical alternatives assessment process, although they
are generally similar in approach with some differences in how hazards, exposures, and life-cycle elements are compared. However, different sectors,
products, and chemical functions may require different approaches. In meeting a wide array of goals,
conditions, and audiences, chemicals alternatives assessment processes need to be flexible and adaptive while encompassing the three common pillars
and principles described above. The step-wise approach presented in many frameworks allows for a
common scaffolding that guides the assessment while
providing opportunities to modify its implementation through the selection of appropriate assessment
methods and tools.
Most alternatives assessment frameworks include a series of iterative steps that form the underlying scaffolding for an assessment and can be grouped
into three areas: Scope, Assessment, and Selection
and Implementation (see Fig. 1).
The Scope sets the goals and boundaries of the
assessment. The Assessment provides the scaffolding for comparing the chemical of concern and the
alternatives. Selection and Implementation involve
identifying preferred alternatives and planning for
substitution. For each of the steps, various analytic
methods can be employed to compare alternatives,
such as hazard assessment, exposure assessment, cost
and performance assessment, and life-cycle assessment. These analytic methods are used in the alternatives assessment process, depending on the goals
and context of the assessor.
5.1. Scope
5.1.1. Step 1. Define Goal and Scope
An effective chemical alternatives assessment
begins with a clarification of the goals, life-cycle
boundaries, types of alternatives (e.g., chemical,
material, product, or system alternatives), and se-
Geiser et al.
I. Scope
1. Define Goal and Scope
2. Characterize Chemical of Concern
3. Idenfy/Priorize Alternaves
II. Assessment
4. Assess Comparave Hazards
Fig. 1. The scaffolding of a chemicals alternatives assessment.
5. Compare Performance and Consider Impacts
6. Select Preferred Alternave
III. Selecon and
7. Implement Adopon of the Safer Alternave
lection of analytical methods (e.g., hazard assessment, life-cycle assessment, exposure assessment) to
be used. A government agency may simply need to
identify the existence of a range of acceptable alternatives before taking regulatory action on a chemical
of concern. A product manufacturer may be seeking alternatives to a chemical constituent in a product in order to satisfy a growing consumer demand
for safer products. Decisions need to be made about
health and environmental endpoints to evaluate, how
to consider exposure, whether a design change alternative is appropriate, and how much of the product’s
life-cycle needs to be considered.
5.2. Assessment
5.2.1. Step 2. Characterize the Chemical of Concern
The chemical of concern needs to be sufficiently
characterized in terms of its hazard traits, environmental fate, functional use, performance requirements, costs, and availability. When an assessment
is conducted by one company on one chemical of
concern for a specific functional use, the costs and
performance requirements may be fairly straightforward. These corporate assessments tend to be simpler and more streamlined than government assess-
ments. If the assessment is initiated by a government
agency seeking alternatives to a hazardous chemical targeted for regulation, the functional uses under consideration may need to be prioritized as there
may be many and varied uses of the targeted chemical. REACH provides a checklist for determining
functional requirements.(51)
5.2.2. Step 3. Identify and Prioritize Alternatives
Identifying alternatives begins with understanding the function of the chemical of concern. Internet
searches, market surveys, interviews with chemical
suppliers, or reviews of professional and scientific
literature may help to identify alternatives that
meet the functional use requirements. Considering
the functions of a chemical defines its “purpose,”
sharpens the search for alternatives, and encourages creativity in identifying alternatives, including
considering the necessity of the chemical function.
Alternatives currently on the market for similar applications suggest that they are potential substitutes.
Prescreening of alternatives is useful during this step
to eliminate chemicals that are clearly more hazardous than the targeted chemical or technically unacceptable. Where no potentially safer alternatives
can be identified, the assessment may need to
propose investments to develop new alternatives
or suggest procedures to minimize exposures in the
waste treatment costs) or externalized costs (e.g.,
worker health and safety), it may be useful to use
comprehensive capital budgeting tools such as full
cost accounting or life-cycle costing.(53)
5.2.3. Step 4. Assess Comparative Hazards
The U.S. EPA’s Criteria for Hazard Assessment and Clean Production Action’s GreenScreen
are commonly used tools for comparative hazard
assessment.(52) Both tools evaluate a range of human health and environmental endpoints and provide qualitative indicators to rate each alternative
and generate profiles that can be compared. Decision rules are included in these methods that address tradeoffs among hazardous attributes, weigh
different types of evidence, and determine how to
handle missing and uncertain data points. Those
alternatives that present equal or greater hazards can be screened out before consideration is
given to other environmental attributes (e.g., waste
generation, energy consumption, greenhouse gas
5.2.4. Step 5. Compare Performance and
Consider Impacts Assess performance, costs, and availability. Both performance and cost analyses are critical components of chemical alternatives assessments;
however, the needs of the initiator determines the
level of detail and associated analyses.
Performance Assessment: The performance of an
alternative is determined by its functional properties. Performance qualities can be readily determined
where there are formally established technical standards. In some cases, a supplier’s recommendations
or recognition that competitors have already adopted
an alternative may be sufficient for a firm to substitute. In more sensitive cases, a technical assessment
may require a market assessment, a review of technical reports, and/or laboratory testing.
Cost Assessments: Cost assessments evaluate
whether alternatives are price competitive and commercially available in quantities sufficient to meet
projected needs. Analysis of the initial costs associated with an alternative may include the costs of
the chemical and any capital costs for new equipment or production changes. Such costs can be factored out over time using conventional net present
value (NPV) analyses based on a discount rate and
period of investment. Because such analyses may not
include hidden costs (e.g., liability, compliance costs, Optional. Consider life-cycle impacts or
exposure concerns. Additional methods such as
life-cycle, exposure, and social impact assessments
may be incorporated into chemicals alternatives assessments where appropriate, required, or desired by
the initiator.
Life-Cycle Assessment: Such assessments can use
common life-cycle assessment methods to determine potential environmental, energy, and resource
consumption impacts from raw material extraction
through product use and disposal. While some alternatives assessment frameworks include the need for
“life-cycle thinking,” others recommend the use of
life-cycle assessment where life-cycle concerns arise.
Life-cycle thinking also encompasses social impact
assessment, which addresses the effects that alternatives may have on upstream or downstream production workers and communities now and in the
future (though this step may be separate in some
Exposure Assessment: Exposure assessments
identify potential exposure scenarios and determine
whether alternatives pose significant exposure concerns that should be addressed in the substitution
process. The NRC’s Framework for Selection of
Chemical Alternatives recommends that a comparative exposure assessment be conducted early in the
alternative assessment process along with a more
thorough evaluation of physiochemical properties of
alternatives, while the Biz/NGO protocol and the
IC2 Framework include provisions for conducting an
exposure assessment if needed after the hazard assessment is conducted.
5.3. Selection and Implementation
5.3.1. Step 6. Select the Preferred Alternative
The assessment may identify a single preferred
alternative or provide information on a range of
alternatives that may be preferred for different
attributes. Where no clearly preferred alternative appears, it is useful to display results in a
way that provides clear information to assist decisionmakers in identifying tradeoffs and making a
5.3.2. Step 7: Implement Adoption of the
Safer Alternative
Once the preferred alternative has been identified, planning for the substitution of the chemical of concern can begin. If the alternative is not a
simple “drop in” substitute, this may require planning for process changes, investments in further research, testing, or work with suppliers and customers
to adopt the preferred alternative. This last step is a
critical and often undervalued part of the alternatives
assessment process. It may require considerable resources in process or product redesign and technical
support and regular monitoring processes to identify
any unintended consequences early on in the adoption of the alternative.(54)
Given a number of drivers, alternatives assessment is a rapidly growing science policy field
with numerous emerging frameworks, chemical
hazard assessment tools, and practitioners. Despite
this growth, chemical alternatives assessment can
be challenging. The absence of data not only on
health and environmental impacts, but also on
performance, costs, and availability of alternatives
can lead to problematic uncertainties. Determining
what factors to include and exclude and determining
the boundaries of impacts can affect the weights
and preference rankings given to the various aspects
included in the comparisons. If there are not strong
decision rules and open and transparent procedures,
the subjective judgments made throughout the
process may preclude the replication of a chemical
alternatives assessment and leave the results open
to question. However, the frameworks and methods used in chemical alternatives assessment need
to remain flexible and adaptive and be no more
extensive than what is needed to make confidently
informed decisions. The procedures should be
simple and straightforward so as to avoid creating
burdensome analyses that delay rather than assist
effective decision making.
Recognizing these limitations, chemical alternatives assessments that include the common
features outlined above can provide significant value
in identifying and adopting safer chemicals. Such
assessments include logical decision-making steps,
formal procedures for handling diverse data types,
and transparent processes, all of which help to assure
confidence and reduce the probability of regrettable
decisions. Such chemical alternatives assessments
Geiser et al.
are best considered part of an iterative, continuous
improvement strategy. In some cases, the alternatives available may only be incrementally better, but
they still may provide an important step toward safer
chemistry while research continues on truly greener
In the immediate future, there is a need for case
studies utilizing different alternatives assessment
frameworks to help identify strengths and limitations
and inform future research to improve alternatives
assessment methods and practice. There is also a
need for collecting and cataloguing the findings
from completed alternatives assessments and the
many chemical alternatives that will be identified
over the next years. A European project called
SubsPort has begun such a compendium.(55) The
Interstate Chemicals Clearinghouse(56) and EPA’s
Safer Choice Program are developing databases of
safer chemicals. Such curated repositories for chemical alternatives assessments and information on
safer chemicals could reduce the need for repeated
assessments and offer a valuable resource for those
seeking safer alternatives.
As the environmental health sciences develop
increasing capacities to characterize the effects
of hazardous chemicals on human health and the
environment, it is equally important that new tools
and procedures are developed that are capable of
identifying safer chemicals and technologies. Risk
assessment and life-cycle assessment tools are commonly available, but these tools only address part
of this challenge. Chemical alternatives assessments
that focus on identifying safer substitutes add to
these tools and encourage informed decisions that
will more confidently lead towards the adoption and
use of safer chemicals.
The authors would like to thank members of the
Chemicals Commons Alternatives Assessment Community of Practice for their insights and experience in
developing this commentary. We would like to thank
the Forsythia Foundation for its support of the multistakeholder dialogue that led to this article. The authors report no financial or competing interests in the
material presented in this article.
1. Massachusetts Toxic Use Reduction Institute. Trichloroethylene: Use Nationally and in Massachusetts. Available at: http://
Nationally_and_in_Massachusetts. The process is detailed at
Massachusetts Toxics Use Reduction Institute, Trichloroethylene and Chlorinated Solvent Reduction. Available at: http://
Can_Help/Cleaning_Research_Projects/Trichloroethyleneand-Chlorinated-Solvents-Reduction, both Accessed April
12, 2014.
Hewlett Packard. Substitution of Brominated Flame Retardants with Non-Halogenated Alternatives Using the Green
Screen for Safer Chemicals Alternatives Assessment Tool.
Available at: www.subsport.eu/case-stories/124-en?lang, Accessed April 12, 2014).
Tickner JA, Geiser K, Rudisill C, Schifano JN. Alternatives
assessment in regulatory policy: History and future directions. Pp. 256–295 in Hester RE, Harrison RM (eds). Chemical Alternatives Assessments. Cambridge: RSC Publishing,
Ashford NA, Hattis D, Heaton GG, Katz JI, Priest WC,
Zold, EM. Evaluating chemical regulations: Trade-off analysis and impact assessment for environmental decision-making.
NTIS#PB81–195067, 1980.
Ashford NS. Reducing physical hazards: Encouraging inherently safer production. Pp. 485–500 in Boethling R,
Voutchkova A, Anastas P (eds). Designing Safer Chemicals.
Handbook of Green Chemistry Series 9. Hoboken, NJ: WileyVCH, 2013.
Steinemann A. Improving alternatives for environmental impact assessment. Environmental Impact Assessment Review,
2001; 21:3–21.
Council on Environmental Quality. Regulations for Implementing the Procedural Provisions of the National Environmental Policy Act: 40 CRF 1500–1508. Washington, DC: U.S.
Council on Environmental Quality, 1992.
Ashford NA, Hattis D, Heaton GR, Katz JI, Priest WC, Zolt
EM. Evaluating chemical regulations: Trade-off analysis and
impact assessment for environmental decision-making. NTIS
#PB81-195067, 1980.
Geiser K. Source Reduction Plans: A Proposal. Medford, MA:
Tufts Center for Environmental Management, 1985.
Davis GA, Swanson M, Jones S. Comparative Evaluation
of Chemical Ranking and Scoring Methodologies. Knoxville,
TN: Center for Clean Products and Clean Technologies, University of Tennessee, 1994.
Hester RE, Harrison RM (eds). Chemical Alternatives Assessment, Issues in Environmental Science and Technology.
London: Royal Society of Chemistry, 2013.
National Conversation on Public Health and Chemical Exposures. Addressing Public Health and Chemical Exposures: An
Action Agenda. Centers for Disease Control, 2011. Available
at: http://www.nationalconversation.us/.
U.S. Department of Health and Human Services. National
Cancer Institute, President’s Cancer Panel, 2008–2009 Annual
Report. Environmental Cancer Risk: What We Can Do Now,
2010. Available at: http://deainfo.nci.nih.gov/advisory/pcp/
Tickner JA. From reactive chemicals control to comprehensive chemicals policy: An evolution and opportunity. Pp. 29–
47 in Bingham E, Cohrssen B (eds). Patty’s Toxicology, 6th ed.
New York: John Wiley & Sons, Inc., 2012.
Health Care Without Harm. Safer Chemicals. Available at:
Healthy Building Network. Pharos Project. Available at:
Greenpeace International. Detox Campaign. Available at:
Campaign for Safe Cosmetics. Available at: http://www.
Safer Chemicals Healthy Families. Available at: http://
20. Good Guide. Available at: http://www.goodguide.com/.
21. Environmental Working Group. Skin Deep Database. Available at: http://www.ewg.org/skindeep/.
22. Ecology Center. Healthy Stuff Database. Available at: http://
23. Nike, Inc. Material choice and impact. Available at: http://
24. Steelcase, Inc. Sustainability. Available at: http://www.
25. Johnson and Johnson, Inc. Strategic Framework. Available at:
26. Seventh Generation. Our Mission. Available at: http://
27. Levi Strauss and Company. Sustainability. Available at:
28. Tickner J, Coffin M. Drivers of business leadership in advancing safer chemicals and products: Challenges and opportunities. Pp. 123-143 in McNall SG, Hershauer JC, Basile G (eds).
The Business of Sustainability: Trends, Policies, Practices and
Stories of Success, I, II, III. New York: Praeger Press, 2011.
29. Kaiser Permanente. Environmental Stewardship. Available
at: http://share.kaiserpermanente.org/article/evironmental-stewardship-safer-chemicals/.
30. Dignity Health. Environment. Available at: http://www.
31. Walmart, Inc. Introduction to Sustainable Chemistry.
Available at: http://www.walmartsustainabilityhub.com/app/
32. Target, Inc. Target Sustainable Product Standard. Available
at: https://corporate.target.com/_media/>TargetCorp/csr/pdf/
33. Tickner JA. Science of problems, science of solutions or both?
A case example of bisphenol A. Journal of Epidemiology and
Community Health, 2011; 65:649–650.
34. National Research Council. Science for Environmental
Protection: The Road Ahead. Washington, DC: National
Academy Press, 2012.
35. O’Brien M. Making Better Environmental Decision: An Alternative to Risk Assessment. Cambridge: MIT Press, 2000.
36. European Chemicals Agency. Guidance on the Preparation of an Application for Authorization, 2011. Accessible
at: http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri =
37. Tickner J, Eliason P. Alternatives assessment for chemicals:
From problem-evaluation to solutions-assessment and implementation: A background paper created expressly for use in
the March 31–April1, 2011 Interagency Discussion on Alternatives Assessment, EPA Potomac Yards Conference Facility,
Crystal City, VA, March 24, 2011, unpublished.
38. U.S. Environmental Protection Agency. EPA’s Safer
Choice Standard, Feb. 2015. Available at: http://www2.epa.
39. National Research Council. A Framework to Guide the
Selection of Chemical Alternatives, 2014. Available at: http://
Cooperation and Development. Current Landscape of
Alternatives Assessment Current Practice: A MetaReview, ENV/JM/MONO (2013) 24, Paris, November,
2013. Available at: http://search.oecd.org/officialdocuments/
&docLanguage=En, Accessed March 10, 2014.
40. U.S. Council on Environmental Quality. Regulations for Implementing the Procedural Provisions of the National Environmental Policy Act, 4 CFR 1500–1508, Reprint, 2005, Sec.
Geiser et al.
15001p. Available at: http://energy.gov/sites/prod/files/NEPA40CFR1500_1508.pdf, Accessed February 26, 2014.
National Research Council. A Framework to Guide the
Selection of Chemical Alternatives, 2014. Available at: http://
U.S. Occupational Safety and Health Administration. Why
Transition to Safer Alternatives. Available at: https://
Tickner JA, Schifano JN, Blake A, Rudisill C, Mulvihill
MJ. Advancing safer alternatives through functional substitution. Environmental Science & Technology, 2015; 49(2):742–
Lowell Center for Sustainable Production et al. The Commons Principles for Alternatives Assessment, 2013. Available
at: http://www.bizngo.org/alternatives-assessment/commonsprinciples-alt-assessment, Accessed February 25, 2014.
Organization for Economic Cooperation and Development. Current Landscape of Alternatives Assessment
Current Practice: A Meta-Review, ENV/JM/MONO
(2013) 24, Paris, November 2013. Available at: http://
Accessed March 10, 2014.
National Research Council. A Framework to Guide the
Selection of Chemical Alternatives, 2014. Available at:
Lowell Center for Sustainable Production. Alternatives
Assessment Framework of the Lowell Center for Sustainable Production, 2006. Available at: http://www.
chemicalspolicy.org/downloads/FinalAltsAssess06.pdf, Accessed February 26, 2014.
U.S. Environmental Protection Agency. Design for Environment Program. Alternatives Assessment. Available at:
View publication stats
http://www2.epa.gov/saferchoice/design-environment-alternatives-assessments, Accessed September 2015.
Biz-NGO Working Group for Safer Chemicals and Sustainable Materials. Biz/NGO Chemical Alternatives Assessment Protocol, 2011. Available at: http://www.bizngo.org/
30nov2011.pdf, Accessed February 26, 2014.
Interstate Chemicals Clearinghouse. Alternatives Assessment Guide. Available at: http://www.newmoa.org/
prevention/ic2/aaguidance.cfm, Accessed February 26, 2014.
ECHA. 2011; Pp. 121–122. European Chemicals Agency.
Guidance on the preparation of an application for authorization; 2011. Accessible at: http://eur-lex.europa.eu/LexUriServ/
U.S. Environmental Protection Agency. Design for Environment, Criteria for Hazard Assessment. Available at: http://
www2.epa.gov/saferchoice/alternatives-assessment-criteriahazard-evaluation; Clean Production Action, Green
Screen for Safer Chemicals. Available at: http://www.
greenscreenchemicals.org Accessed March 10, 2014.
Yakhou M, Dorweiler V. Environmental accounting: An essential component of business strategy. Business Strategy and
the Environment, 2004; 13:65–77.
National Research Council. A Framework to Guide the
Selection of Chemical Alternatives, 2014. Available at: http://
SubsPort: Substitution Support Portal. Available at:
http://www.subsport.eu/, Accessed February 26, 2014.
Interstate Clearinghouse on Chemicals. Hazard Assessment.
Available at: http://www.theic2.org/hazard-assessment.
Jacobs MM, Malloy TF, Tickner JA, Edwards S. Alternatives
Assessment Frameworks: Research Needs for the Informed
Substitution of Hazardous Chemicals. Environ Health Perspect; http://dx.doi.org/10.1289/ehp.1409581.