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 CITATIONS READS 18 115 4 authors, including: Ken Geiser Joel Tickner University of Massachusetts Lowell University of Massachusetts Lowell 54 PUBLICATIONS 879 CITATIONS 81 PUBLICATIONS 2,824 CITATIONS SEE PROFILE SEE PROFILE Sally Edwards University of Massachusetts Lowell 8 PUBLICATIONS 373 CITATIONS SEE PROFILE 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 1. INTRODUCTION 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; email@example.com. 1 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) 2. DRIVERS OF CHEMICAL SUBSTITUTION 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 products).(14) 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 R resources such as GoodGuide,(20) the Skin Deep (21) (22) 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) Perspectives 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. 3. THE VALUE OF ALTERNATIVES ASSESSMENT 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 3 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. 4. DEFINING ALTERNATIVES ASSESSMENT 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 4 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, r 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) r 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 Perspectives 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 altogether. 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. 5. THE ALTERNATIVES ASSESSMENT BLUEPRINT 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 5 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- 6 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 Implementaon 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 Perspectives propose investments to develop new alternatives or suggest procedures to minimize exposures in the meantime. 7 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 generation) 5.2.4. Step 5. Compare Performance and Consider Impacts 188.8.131.52. 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, 184.108.40.206. 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 assessments). 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 selection. 8 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) 6. FUTURE DIRECTIONS 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 alternatives. 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. ACKNOWLEDGMENTS 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. REFERENCES 1. Massachusetts Toxic Use Reduction Institute. Trichloroethylene: Use Nationally and in Massachusetts. Available at: http:// www.turi.org/TURI_Publications/TURI_Chemical_Fact_ Sheets/Trichloroethylene_TCE_Fact_Sheet/TCE_Facts/Use_ Nationally_and_in_Massachusetts. 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