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

1. Infusing TSCA with Green Chemistry: The Role of Innovation in Chemical Risk Management Dr. Kira Matus Senior Policy Analyst Center for Green Chemistry and Green Engineering Yale University June 11, 2010

2. Green Chemistry 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.

3. A major change from traditional approaches to chemistry • 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

4. 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 genuinesustainability 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.

5. 12 Principles of Green Chemistry • Prevention • Atom Economy • Less Hazardous Chemical Syntheses • Designing Safer Chemicals • Safer Solvents and Auxiliaries • Design for Energy Efficiency • Use of Renewable Feedstocks • Reduce Derivatives • Catalysis • Design for Degradation • Real-time Analysis for Pollution Prevention • Inherently Safer Chemistry for Accident Prevention

6. Three-fold Optimization Green Chemistry

7. Innovation for 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 time

8. Green Chemistry and Regulation: The Yale Center for GC&GE What role should green chemistry and green engineering play in a reformed TSCA?

9. Key Questions

10. How can, and should, “reformed TSCA” impact innovation? • Must not stifle innovation generally with unnecessary resource burdens, and • Should favor innovations that improve safety and reduce environmental impacts.

11. Why are green chemistry and green engineering critical parts of resilient, forward-looking chemical risk management, and how should they be built into the regulatory system?

12. 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

13. Green Chemistry in TSCA: 1976-Present • 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

14. Green Chemistry in theSafe Chemicals Act of 2010 • “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

15. Reactive Approach • Incentives are to fix problems once they occur • Efficient? • What does this mean for health of people and the environment? • Is this even feasible?

16. Green Chemistry: Beyond “Green Alternatives”

17. Barriers to GC Implementation • Technical • Regulatory • Economic • Cultural • Organizational • Definition and Metrics TSCA reform is an opportunity to reduce barriers

18. Embedding GC in TSCA • Start to think PROACTIVELY • Data • Incentives • Awareness • Collaboration • Prevention • Hazard Reduction • Forward-looking • Continuous Improvement

19. Potential Benefits • 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

20. Policy Recommendations • 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”

21. Policy Recommendations • 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

22. Policy Recommendations • 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.

23. Policy Recommendations • 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

24. Policy Recommendations • Recognize and support state-level programs • Education • R&D • Technical outreach programs for small and medium sized firms

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

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

27. Conclusions • 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

28. Conclusions • GC is a market-oriented, economically favorable, preventativeapproach • Act in advance of impacts • Enhance the broader sustainability of the chemical enterprise in the United States.

29. Acknowledgements • Dr. Julie B Zimmerman • Dr. Evan Beach • Erin McBurney Workshop Participants • Charles Auer • Klaus Berend, • Blake Biles • Gregory Bond • William Clark • Joseph Fiksel • Bob Israel • Warren Muir • Tom Osimitz • Michael Parr • John Wargo • Jeffrey Wong • Jim Young