Identifying and Reducing Environmental Health Risks of Chemicals in Our Society: Workshop Summary (2014)

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6 Current Efforts to Reduce the Risk of Chemicals in Our Society The workshop’s fifth session was devoted to a variety of approaches that institutions have taken to reduce chemical risks. As session chair Al McGartland, Director of the National Center for Environmental Economics at the U.S. Environmental Protection Agency (EPA), noted in his opening remarks, the session’s seven speakers have two things in common. First, they are all leaders in green chemistry, sustainability, or related fields. And, second, they all have broad familiarity with both the scientific aspects and the institutional aspects of finding and implementing solutions to problems related to chemical risks. It seems likely, McGartland commented, that success requires both scientific and institutional competence. CASE STUDY: SUSTAINABILITY AND GREEN PROGRAMS AT THE NATIONAL INSTITUTE OF ENVIRONMENTAL HEALTH SCIENCES In the session’s first presentation, Trisha Castranio, Sustainability Analyst at the National Institute of Environmental Health Sciences (NIEHS), described the sustainability, eco-friendly, and green business practices at NIEHS. Castranio, who develops sustainability policies and environmental management goals for NIEHS and is responsible for evaluating the effectiveness of its stewardship initiatives, offered a detailed accounting of exactly how the institute works to reduce the amount of harmful chemicals that it uses and disposes of. She began with a brief description of NIEHS. It is a biomedical research facility. Its intramural program has more than 100 groups working onsite, while its extramural program operates 17 different 101 

102 ENVIRONMENTAL HEALTH RISKS OF CHEMICALS programs and centers doing work in disease research and exposure research. Both the intramural and extramural programs are very productive and regularly contribute to the peer-reviewed literature. The institute places a great deal of emphasis on sustainability issues and green business practices, and it has had success in those areas, Castranio said. “We have been awarded Green Championship awards from the Department of Health and Human Services for 3 of the last 4 years,” she reported. The institute also received one award for sustainability reporting and another for environmental stewardship for its composting program. Much of what the NIEHS has done over the past 5 years to move in the direction of sustainability and green practices has been harvesting “low-hanging fruit,” Castranio said. The initiatives include such things as installing the more energy-efficient light-emitting diode (LED) lighting, composting food wastes from the cafeteria, and encouraging more recycling. One initiative, whose goal was to reduce energy use and thus the production of greenhouse gases, replaced old, less-efficient ultra-low- temperature freezers with newer, much more efficient freezers. Each of the older freezers used as much energy as an 1,800-square-foot home, Castranio said. “This project was a great way to not only reduce the carbon footprint, but it also got people to go through their freezers,” she said. Because laboratories had to get rid of two old freezers to get one new freezer, the researchers had an incentive to get rid of items that had been in their freezers but were no longer needed. NIEHS has reduced water usage by 35 percent over the past few years, Castranio said, and it has reduced energy use in various ways, from overnight shutdowns for the information technology groups to changing temperature settings in the buildings to require less heating or cooling. One of the most challenging issues has been dealing with the many different chemicals that are used in the NIEHS laboratories. The researchers there work with a wide variety of chemicals and reagents. Their jobs demand it, and they are generally very well organized and careful in their handling of the chemicals. But they tend to have a lot of chemicals—often far more than they need. A group of researchers may have been working in the same laboratories for 30 years, with postdoctoral students coming in for a few years and leaving again, and it is natural to want to save the different materials that have been used in various experiments over the years, Castranio said. “People think, I am saving this for this person, and somebody might need that and the next 

CURRENT EFFORTS TO REDUCE THE RISK OF CHEMICALS 103 person might work on that. And then these tend to build up. That belongs to somebody else. They are not going to get rid of it. Nobody wants to touch it. That kind of thing.” Part of her job is to reduce the amount of chemicals in the laboratories. The first step is to get researchers to take a careful look at what they have and create an inventory. That allows Castranio to keep track of usage, which is the first step in developing plans to reduce the amount of chemicals the laboratory is using and to attempt to move to chemicals that are greener. Of course, the first requirement is that the researchers must be able to use the materials that they need in order to do their work effectively, but there will be some materials that researchers can use less of or can replace with something greener. “They are going to have some things that affect them directly and other things that do not,” she said. “There will be some give and take. It is going to be on an individual basis.” In looking to reduce the laboratory’s use of toxic and harmful chemicals, it was important to not overlook common spaces, Castranio. Equipment rooms and storage rooms tend to become catchall spaces. Researchers will buy large quantities of various materials and place them there. The cold rooms also end up being catchall spaces whether they require cold storage or not. All of these spaces require a walkthrough to see what is there and what can be disposed of. One key to using fewer and greener chemicals is simply to get the researchers thinking about the chemicals from a life-cycle perspective. “Once we can get people to think about where their chemicals are going, where they come from, what is going to happen to them after that, then we can get them to reduce and possibly find a new way to do that type of research,” she said. “The most important thing for me is to reveal the face behind the bottle. That means . . . how to handle this chemical or how to handle that potential waste. Before you, somebody harvested it or somebody synthesized it. Somebody packaged it. Somebody shipped it. Somebody brought it to you. Somebody put it on your desk. Now it is on your desk. Then where does it go? Who is going to handle it? Who picks it up? Who takes it there? Where does it go after that? These are the things that I think will help people think twice about how much they use.” 

104 ENVIRONMENTAL HEALTH RISKS OF CHEMICALS On the operational side, Castranio said, one of the most important things is making sure that environmental considerations are part of the planning from the inception of a project and do not come in as an afterthought. Waiting until the project is 90 percent complete never works because “there is no extra money, and green almost always means more money,” she said. “It has to get in at the beginning, and then you can have the trade-offs.” Such thinking is more difficult with research projects, she noted. “I had some people come to me and want to talk about ‘greening the grants.’ Grants are merit-based scientific funding. We cannot really choose funding based on how green their process is.” However, she added, it is possible to talk to the scientists and have them make efforts to keep their projects as green as possible. From her experience at NIEHS, she offered advice for anyone who wishes to institute programs to reduce the amount of chemicals used by society. It starts with measuring and reporting, for it is vital to know what one is dealing with. Once you have a clear baseline, you begin to set goals, implement programs to reduce chemicals, and make sure that best practices are shared widely. The scientists at NIEHS have a dual purpose, she said. They do scientific experiments that relate to toxicology, but they also should be doing them in the least toxic way. “We are an environmental institute. We should be doing this.” CASE STUDY: JOHNSON & JOHNSON The session’s second speaker was Zephanie Jordan, Vice President of Global Regulatory Affairs and Product Stewardship at Johnson & Johnson. To put her talk in context, Jordan explained that Johnson & Johnson has three major divisions—the pharmaceutical products division, the medical devices division, and a consumer products division—and that she works in the consumer products division. The goal of Johnson & Johnson’s sustainability initiative, which was launched in 2011, is summed up by the slogan, “Caring for a healthy future.” In particular, the company’s sustainability initiative has three main aims: to promote healthy people and communities; to promote a healthy planet, minimizing waste and conserving finite resources; and to promote healthy business, which the company believes will follow naturally from focusing on healthy people and a healthy planet. “What we 

CURRENT EFFORTS TO REDUCE THE RISK OF CHEMICALS 105 mean by healthy business,” Jordan explained, “is that the most trusted brands will thrive and endure.” A key to building this sort of consumer trust, she said, is ensuring transparency “into what we do and how we do it.” In August 2012 the company launched its Safety and Care Commitment, which Jordan characterized as an effort to provide better transparency into the safety assurance processes that Johnson & Johnson uses in the development of its products and also into the policies governing ingredients in various products, such as beauty care products and baby care products, where concerns about safety are particularly acute. The company has a five-level safety assurance process, Jordan explained. The five levels are sourcing raw materials, toxicology assessment, clinical evaluation, in-use testing, and continuing evaluation. Johnson & Johnson’s background in pharmaceuticals shapes its approach to sourcing materials, Jordan said. “That background in health care causes us to look first through a safety lens,” she said. “We have very high standards and sustainability principles for our ingredients. We only partner with suppliers that can meet those standards.” To illustrate, she noted that the company requires each of its suppliers to fill out a 12- category questionnaire covering a wide range of topics. “We were one of the first companies to move to next-generation ingredient reviews where we require all of our suppliers to disclose compositional information down to one part per million,” she said. Because the general standard is in the range of 100 to 1,000 parts per million, the company believes its approach to be at least 100 times more sensitive. For each of its suppliers Johnson & Johnson requires independent certification of various aspects of the firm’s operations, from conditions on its production floor to its business practices before it will partner with that firm. Second, each ingredient that Johnson & Johnson uses must pass a toxicology assessment. The first step in that assessment is for the company’s global team of toxicologists to assess the data that are available. They look at both the hazard and the risk that an ingredient might pose. “We meet or exceed regulatory standards for all of our materials,” Jordan said. The company also examines how an ingredient is going to be used. “Is it likely to be used in a shampoo that gets washed off? Is it likely to be used in a lotion that gets left on the skin?” The company uses that information to put the safety assessment in context. Next the company carries out a clinical evaluation for each of the formulations that it develops, looking at both efficacy and safety. In particular, the evaluations assess the safety of specific concentrations and 

106 ENVIRONMENTAL HEALTH RISKS OF CHEMICALS ingredient formulations. The products are tested for such things as irritation, sensitivity, and response to sunlight. Because it is not enough to look at the products in a controlled clinical setting, before a product goes to market the company will also put it into user testing. “We have a bank of volunteers around the world that take the products into their homes and use them,” Jordan said. “We are looking for unanticipated ways that consumers or people may use our products so that we can adjust the formulation or the label information to ensure that they are going to be safely and effectively used in the home.” The last level is the continuing evaluation. “We talk about this as step five,” she said, “but it underpins the whole process. It never stops. We are always evaluating our products.” The company has an ingredients working group made up of scientists and medical professionals from across the globe that is constantly reviewing new and emerging data. They are evaluating three things, Jordan said. First is the science and what is emerging in terms of the research concerning the ingredients the company uses. Second is regulatory trends, and third is consumer attitudes. “They are looking at what consumer sentiment is telling us about what we ought to do with our ingredients,” she said. From that the working group makes recommendations on product formulations, labeling, packaging, and instructions for use and these are taken up in our internal policies. The working group has a good track record, Jordan said. “Typically, we find that this group has made recommendations and we have implemented those into our ingredient usage policies years before there have been regulated controls on ingredients.” To improve the sustainability of its products, Johnson & Johnson instituted its Earthwards program, which is an internal certification program for its products. As company researchers are developing a new product, they must consider seven areas in terms of sustainability: materials, packaging, energy, waste, water, social, and innovation. “Each product is scored against these,” Jordan said, and a product is awarded Earthwards certification if it shows significant improvement over existing products in at least three of the seven areas. “We do not have to achieve certification for every single product,” she said, “but we have to score against these. It is intended to ensure our scientists look for improvements in every one of these areas.” A second voluntary program that the company instituted is called Global Aquatic Ingredient Assessment, or GAIA. It is a tool that the company uses internally to assess the impact that an ingredient or 

CURRENT EFFORTS TO REDUCE THE RISK OF CHEMICALS 107 formulation might have on the environment. In particular, the company scores a product on three measures: persistence, bioaccumulation, and toxicity. As part of its Safety and Care Commitment, the company is making public some of its internal ingredient standards in an effort to put itself in a leadership position on certain products of concern. “Essentially, we made some commitments to remove certain ingredients or trace materials or restrict their use in the categories of products,” Jordan said. “We did not necessarily do this for safety reasons. We did it because consumer perception and sentiment was such that even if we continued to use some of these ingredients that are safe, they were not acceptable from a consumer perception perspective.” As an example, she described the company’s position on formaldehyde-releasing preservatives. These chemicals are generally very effective and very safe, Jordan said. There is, for instance, 14 times more formaldehyde in an apple than in a bottle of Johnson & Johnson’s baby shampoo. “You would need to bathe a baby 40 million times in 1 day to achieve the California Proposition 65 level for labeling.” Nonetheless, there is enormous public pressure to move away from these preservatives, and so Johnson & Johnson set a goal of removing formaldehyde-releasing preservatives from all of its baby products by December 2013 and decided not to use them in any new adult products unless a special exception is granted. The company is walking a fine line here, Jordan said. “We have to be very careful about unintended consequences when we do things like this. . . . When we are taking something out of our products, we have to be very sure that what we are replacing it with is going to be suitable and appropriate and that we do not see unintended consequences in other ways.” For example, because of public pressure, the industry is moving away from some preservatives to others, and increased exposure to these preservatives has led to an increase in sensitization rates in one instance. The company’s reformulation work is a “mammoth task,” she said. “We are reformulating around 200 products over the course of a couple of years. It takes us 18 months to 2-and-a-half years to reformulate a single product because we go through that five-level safety assurance process for every product that we formulate. We are doing this on a global scale. We have diverted resources to this effort because this is considered to be a high priority for the organization.” In closing, Jordan offered two parting thoughts. First, she said, it is vitally important that decisions about chemicals and ingredients be based 

108 ENVIRONMENTAL HEALTH RISKS OF CHEMICALS on data and that the decisions be put into context with a risk-based approach. Second, it is crucial how information about these products is transmitted to the public. “We know that people that use our products want helpful information and they want assurance of safety,” she said. “There is mass confusion in the society about these ingredients. We have been trying to work out how to solve that part of the problem. Our thinking is moving toward less about providing details on ingredients that can be misinterpreted and more in terms of driving behavior change and helping consumers ask the right questions as they choose products for themselves and their families.” CASE STUDY: DOW CHEMICAL COMPANY The next speaker was Connie Deford, Director of Global Products, Sustainability, and Compliance at Dow Chemical Company. She is responsible for leading Dow’s global product sustainability program, and she described those sustainability efforts to the workshop audience. Dow was founded in 1897 by Herbert Henry Dow in Midland, Michigan. Dow chose that particular location, Deford explained, because of the presence of brine wells, which served as a source of chlorine and caustic soda, which were important raw materials for the new chemical company. Today the company has annual sales of $60 billion and has 188 manufacturing sites in 36 countries. It supplies plastics and chemical products to customers in 160 countries. Deford began her discussion of Dow’s sustainability program by talking about motivations. “Environmental health and safety and sustain- ability are at the core of what our company is all about,” she said. There are a number of specific motivations, including the local protection of human health and the environment, addressing climate change, encouraging energy efficiency and conservation, product safety leadership, and contributing to community success. “Certainly, our customers and our customers’ customers are key drivers for many of our programs and activities in the sustainability space,” she added. “Most of you are probably very familiar with Walmart’s support of The Sustainability Consortia. Most recently, Target has introduced their sustainable product standard. Clearly, we listen to those retailer activities. These retailers’ actions are motivators for the kind of work that we are doing.” The company also pays attention to 

CURRENT EFFORTS TO REDUCE THE RISK OF CHEMICALS 109 regulations and green certification programs “to signal where we should spend our time and energy and focus our innovation efforts.” To identify and address sustainability issues in its existing products, Dow takes a multipronged approach, Deford said. One key tool is the use of life-cycle assessments. These assessments go beyond simply looking for potential hazards. “We look at what type of waste might be generated and emission from our manufacturing processes,” she said. “We look at what happens at the end of the life cycle. Are there things that we can do working with our customers to improve their utilization of our products? These are key ways in which we identify opportunities to look at addressing gaps in the sustainability space for our existing product portfolio.” The company also assesses products against its 2015 sustainable chemistry goal criteria.1 In its efforts to meet these goals the company looks at a variety of criteria for its products. “We start at the very beginning—the raw material extraction point. What can we do? Is there more that we can do relative to sourcing of raw materials? Can we do more recycling within our operations?” In addition to looking for ways to use more renewable and recyclable materials, the company also looks for ways to make its manufacturing process more efficient and ways to use less energy in transporting the products. “We partner closely with our supply chain organization, looking at opportunities to relocate facilities nearer our facilities.” They also examine the various ways their products are used, looking for opportunities to move in the direction of greater sustainability. To strengthen its product safety program—which is another prong of the sustainability effort—the company uses the prioritization tool developed by the American Chemistry Council (and described in the presentation by Christina Franz in Chapter 4). “We look critically at products that are going into consumer applications, as well as products that might have a higher degree of hazard,” she said. “We do not look at every chemical and application the same.” Another aspect of strengthening the safety program is a critical look at the company’s ingredient disclosure practices. “We are listening to our customers and customers’ customers asking and wanting to know more about those materials that are in the products that we supply to them,” she said. “We are challenging our businesses to look critically at how important is it to maintain that confidentiality.” It is important to find the 1 Further information on Dow’s Sustainability Goals is available at http://www.dow.com/sustainability/goals (accessed April 2, 2014). 

110 ENVIRONMENTAL HEALTH RISKS OF CHEMICALS right balance between providing the product information that customers want and need to know versus not providing too much product information to competitors and thus losing competitive advantage. “We are continually challenging our businesses about how to do a better job in that regard.” To illustrate Dow’s approach to sustainability and some of the challenges in such an endeavor, Deford offered two case studies. The first concerned the search for alternatives to nonylphenol ethoxylates (NPEs). These chemicals have historically been used as surfactants. They continue to be widely used in applications where their exposure to the environment can be minimized, but the company was looking for viable alternatives for uses in which the chemical may be released into the environment. “There are lots of surfactants out there,” she said. “It was not an issue to find a surfactant to replace NPEs. The challenge has always been finding a surfactant that is cost effective and stable in the environment that it needs to be used with a price that is similar to NPEs. NPEs are an very cost-effective surfactants.” The company developed a new line of surfactants, the ECOSURF EH Surfactants. Readily biodegradable and with low aquatic toxicity, they were designed to help formulators meet rising expectations for performance and convenience, Deford said. In particular, they can help formulators comply with regulations and more stringent health and environmental certification programs. It took significant investment to develop those new surfactants, she said. The company not only had to design new chemistry, but it had to gather data to help customers understand how it would perform in different applications as well as data regarding the new chemicals’ health and environmental implications. Dow also had to make the capital investment to reconfigure a manufacturing facility to make the new surfactants. Unfortunately, the cost of the new chemicals has resulted in limited success even though tests showed them to be particularly effective in certain agricultural formations. “It demonstrates that although it is a very effective technology, it also has to be cost effective.” The second case study Deford offered concerned the development of a polymeric flame retardant to replace hexabromocyclododecane. HBCD, as it is known, has been used as a flame retardant for a long time in a variety of different applications. One of those applications is use in extruded polystyrene (XPS) foam, such as the STYROFOAM® brand rigid insulation that Dow manufactures. Dow researchers played a key 

CURRENT EFFORTS TO REDUCE THE RISK OF CHEMICALS 111 role, Deford said, in the development of polymeric flame retardant, or Poly FR, as an alternative to HBCD as a flame retardant in XPS foam. Poly FR is a large-molecular-weight material that does not have the potential to bioaccumulate, and it does not have the same toxicity concerns as are associated with HBCD, Deford said. Recently the Design for the Environment program at the EPA released a draft report that found Poly FR to be a viable alternative to HBCD and that predicted that Poly FR would be safer than HBCD. The development of Poly FR required an even greater investment than the development of the ECOSURF EH surfactants, Deford said. “There were many years of effort expended in looking at an alternative to HBCD,” she said. “We screened commercially available products, but in the end, this was a unique chemistry that was identified to replace the material.” Significant time, effort, and expense went into development and laboratory testing as well as conducting product certification testing to confirm performance. Adjustments also were required in formulations. Poly FR is clearly a success story, she said, but it is a success story that illustrates just how much time and energy and investment it can take to replace a successful product. For that reason it is crucial that Dow be able to learn about the environment, health, and safety potential of new products as quickly as possible. The company is committed to bringing products to market that are safer and more sustainable than the products they have been selling in the past, but they need to be able to predict with some accuracy which potential products are likely to be successful. Dow is beginning to utilize its predictive toxicology testing to meet its information needs during product development. The company has been working with the EPA, academic researchers, and others to optimize such testing. Dow also uses a life-cycle assessment to determine how sustainable a new product is likely to be. And, Deford said, the company uses “a very rigorous stage gate process so that at various stages we are asking ourselves those right questions about whether or not a material is more sustainable than the material that we are replacing.” In particular, Dow judges each new material on six dimensions of sustainability: economic, social, greenhouse gas emissions, water, resource use (energy and raw materials), and the Dow 2015 Goals Composite. If at any stage the new material does not seem to be a significant improvement, the company will not move on to the next stage of development. 

112 ENVIRONMENTAL HEALTH RISKS OF CHEMICALS CASE STUDY: AMERICAN CHEMICAL SOCIETY GREEN CHEMISTRY INSTITUTE David Constable, Director of the American Chemical Society’s (ACS’s) Green Chemistry Institute, spoke next. In his presentation he made the case that innovating toward sustainability in chemistry is a business imperative. He began by drawing a distinction between end products becoming greener and the chemical building blocks that are used to create those end products becoming greener. Both tasks are important, but the latter may be more difficult. The challenge, Constable said, is that chemists must work with what is available, “and the basic building blocks and what is at hand for your average chemist is inherently hazardous and toxic. The chemicals and chemistries that chemists use are based in technologies that are 150-plus years old, by and large. They are inherently using toxic materials. Chemists are creatures of habit, and they use the same things over and over again.” But it is not just a matter of habit, he said. The chemical reactions and processes that chemists rely on today have been refined by decades of experimentation and improvement. They are easily obtained at low cost, they react in predictable ways, they have been optimized to produce maximum yields, they take place via thermodynamically and kinetically favorable reactions, and they generally do not require sophisticated reactors or technology in the laboratory. On the negative side of the equation, however, the current chemical building blocks have a variety of sustainability risks. Their feedstocks are sometimes hazardous to human health or the environment, the intermediate materials in the processes can also be hazardous, the chemical processes that are used can be high risk, and there can be inappropriate engineering or process controls. Thus, despite the advantages of today’s chemical building blocks, there are a variety of reasons to look for greener alternatives. However, Constable said, it will not be easy to change behaviors and preferences in the chemists who do this work. “The entire system is likely to have to change.” First, the types of chemicals that chemists work with will need to be changed. “Chemists do what they do because the molecules that they are working with are reactive molecules by definition,” he said. In other words, chemists tend to choose chemicals that can be put together in a reaction vessel and naturally react with one another, with no additional 

CURRENT EFFORTS TO REDUCE THE RISK OF CHEMICALS 113 work required from the chemist. They generally do not think in terms of reactions that are not quite so natural but that can be produced under the proper conditions. “The point is the entire way in which chemists are educated . . . does not necessarily get them to the place that we need them to be.” Chemists also tend to think in terms of maximizing yield, Constable said, but that is not a good measure for green chemistry, in which other factors are more important. Chemists like to use chemicals that are familiar and easily obtained. “Chemists reach for the same solvents that they have used for years. They use the same framework molecules. They go to the same purveyors of chemicals, and that is all they use.” Green chemistry will require that they leave this comfort zone. Given this inertia, what steps could encourage the sort of innovation that will be necessary to move to green chemistry? Constable first mentioned the regulatory option. “If you regulate something out of existence, people do not have any choice but to find something different,” he said. “It is not really the preferred way to do it, but it will get people to think about it.” But what many supporters of green chemistry foresee is that it will even- tually be possible to develop green chemistry to the point that it will naturally edge out traditional chemistry. This will require green chemistry to hit what Constable described as the “sweet spot”: green chemistry that is environmentally preferred to traditional chemistry, is economically viable, and offers equal or better performance. There are a variety of reasons for businesses to move to green chemistry, he said. For example, it can cut costs in various ways. “If you are not having to deal with managing toxic chemicals, it is inherently cheaper,” he said. The biggest cost of running a laboratory is the ventilation through the hoods, not the chemistry itself, so if it were possible to do chemistry in a way that did not require hoods, that would lead to a substantial decrease in energy costs. There are also a number of intangibles related to how customers view green products versus traditional products. For example, he said, people are very concerned about the toxic chemicals in the supply chain, even if the finished products are not hazardous. Green chemistry could remove that problem. One of the ways the ACS Green Chemistry Institute has been trying to encourage the development and use of green chemistry is through the creation of industry roundtables. “We have asked companies to get together and to talk about issues in a collaborative and noncompetitive way.” The purpose of the roundtables is to address technical challenges, 

114 ENVIRONMENTAL HEALTH RISKS OF CHEMICALS develop decision-making tools, inform the research agenda, drive the use of good science in setting policy, and influence the adoption of green chemistry throughout the supply chain. One of the three roundtables that the ACS Green Chemistry Institute has established is a pharmaceutical industry roundtable, which started up in 2005. This sort of cooperation among pharmaceutical companies makes sense, Constable said, because the companies compete on the basis of active pharmaceutical ingredients, not the chemicals and chemistries by which the products are made. “There is an awful lot of room to talk about how to get toxics out of products and processes without affecting what they actually compete on,” he said. Two other roundtables have been established within the past 5 years, a chemical manufacturer’s roundtable and a formulators’ roundtable. It has been difficult to get the major chemical manufacturers to the table, Constable said. “The reason for that is largely because they compete at lower margins, and they compete in some of the same product areas. Also they are more diversified.” Still, he said, there are areas in which chemical manufacturers may be able to cooperate, such as alternatives to distillation. In the manufacturing of chemical products, distillation processes account for more than 25 percent of the energy use. “If we can come up with alternatives to distillation, it will drive a lot of very good behaviors and outcomes from a green chemistry standpoint.” Another way to improve sustainability would be to develop new catalysts. Catalysis is used somewhere in the supply chain for probably 40 to 50 percent of the chemicals on the market, Constable said. “It is used everywhere, and everything that you use on a daily basis can usually be traced back to some catalytic process.” The major metals of concern that are used in catalysis are platinum-group metals, which include metals like platinum, palladium, rhodium, ruthenium, osmium, and iridium. What many people do not realize is that mining for these metals results in the release of a large number of toxic materials into the environment. “That is something that is not really perceived at the bench level of a chemist who is choosing a catalyst,” Constable said. But some of the more abundant metals whose mining is not so damaging to the environment can also serve as effective catalysts, or in many cases organic enzymes can serve as catalysts. So there are ways of making catalysis greener, but they require looking beyond the immediate chemical processes to think about the entire process, including the costs to the environment of mining the metals used as catalysts. 

CURRENT EFFORTS TO REDUCE THE RISK OF CHEMICALS 115 There are also a large number of ways to move toward sustainability by engineering new chemical processes for use in manufacturing chemical products. For example, Constable said, the pharmaceutical industry today uses mostly batch chemical processing. Moving to bioprocessing and continuous processing would be a way to increase energy efficiency and to reduce the production of toxics and unwanted byproducts. Another area is separation and reaction technologies. These account for an enormous amount of energy use and waste, he said, and simply looking for better solvents hold tremendous potential for reducing the amount of toxics and wastes produced. Finally, Constable spoke about some of the challenges facing those who are trying to move the industry to greater sustainability. Institutional inertia is a huge problem, he said. Chemical companies are used to making chemicals in a certain way; it is what they know, and it is not easy to get them to take an entirely new approach. A related hurdle is the capital that is invested in doing things the traditional way. Furthermore, when financial analysts examine the costs of doing things the traditional way versus using green chemistry, the traditional measures of analysis they use generally point to the traditional ways of doing chemistry. Many of the ways green chemistry offers a financial advantage, such as in the savings related to sustainability and life-cycle considerations, are generally not considered in traditional measures of profitability. In addition to such institutional issues there are human behavioral factors that come into play as well. “I would say that a lot of what we talk about boils down to behavioral changes in people at the bench level,” Constable said. Furthermore, when senior management is planning for the future, other issues than green chemistry tend to dominate the discussions about sustainable development and corporate social responsibility. Another issue involves the educational system: As long as chemists are taught only the traditional chemistry in school, it will remain difficult to convince them to transition to green chemistry. More generally, people naturally tend to be risk averse and resistant to change. Developing a new system of green chemistry that can replace the existing chemistry will require finding ways to overcome all of these challenges. 

116 ENVIRONMENTAL HEALTH RISKS OF CHEMICALS CASE STUDY: SUBSTITUTE IT NOW AND GREENSCREEN The next speaker was Beverley Thorpe, Consulting Co-Director of Communications and Advocacy for Clean Production Action, who spoke about two initiatives to advance safer chemicals in the marketplace. The first was the Substitute It Now, or SIN, List, which was created by the International Chemical Secretariat, based in Sweden. The second was GreenScreen, a comparative chemical hazard assessment method for identifying safer chemical substitutions for chemicals of concern. Clean Production Action is a small nongovernmental organization (NGO) based in Somerville, Massachusetts. It designs and develops strategic solutions to promote green chemistry products and sustainable materials. It networks with many governments, industry leaders, and other NGOs around the world, Thorpe said. Through that networking it comes into contact with a variety of ideas and methods for moving the economy forward with safer materials. One such method is the SIN List, which was developed by ChemSec, a nonprofit based in Gothenburg, Sweden, in cooperation with about nine other NGOs around Europe. In following the negotiations that eventually led to the Registration, Evaluation, Authorisation, and Restriction of Chemicals (REACH) legislation, which now governs much of the chemical use in Europe (see Chapter 2), the NGOs came up with the idea of creating a list of the chemicals for which it was most urgent to develop safer substitutes, she explained. That idea became the SIN List. The SIN List was intended, Thorpe said, to help businesses anticipate which chemicals are likely to be listed on REACH’s restricted list as well as to clarify for businesses the criteria that will be used to determine which substances would most likely make the candidate list of chemicals that would then need to seek authorization for continued use in the European market. By making it easier for business to understand how various chemicals would meet the REACH classification for chemicals of concern, Thorpe said, the SIN List could help companies fast-track these for substitution. REACH came into effect in June 2007, and the first SIN List was created in 2008. Version 2.1 of the SIN List was released in 2013. The development of the REACH restricted list has been a slow ongoing process, and the idea behind the SIN List is to create this list of chemicals of concern quicker. There is no regulatory power behind the SIN List, Thorpe noted, “but it is based on peer-reviewed publicly available data.” 

CURRENT EFFORTS TO REDUCE THE RISK OF CHEMICALS 117 Currently, there are about 626 chemicals listed on the SIN List, she said, and they all meet the criteria specified by REACH of being CMRs (carcinogenic, mutagenic, or toxic to reproduction), PBTs (persistent, bioaccumulative, and toxic), vPvB (very persistent and very bioaccumulative), or substances of equivalent concern. Thorpe suggested that audience members should check out the SIN List. “This is a very interesting database,” she said. “It is clear, it is easy to negotiate, and it gives you tons of information.” It is possible to search the database using various criteria—such as health impacts, the sector in which the chemical appears, production volume, functional use of the chemical, or registration information such as whether the chemical has been put on the candidate list for authorization. The database also provides the names of producers and the locations of where the chemical is produced. The SIN List has already affected the chemical use choices of various businesses, Thorpe said. For example, Carrefour, which is Europe’s largest retailer, has added SIN to its own list of 600 substances of very high concern, which it sends to its suppliers so that they can begin work on substitution. Sara Lee’s Critical Ingredients Program integrates the SIN List, and Skanska, one of the largest construction firms in the world, has integrated SIN into its voluntary restricted substances list. Furthermore, Thorpe said, investors are also using the SIN List. One research company, MSCI, is applying the list to assess the business risk that companies might be facing in the future as REACH moves forward and chemicals for authorization are listed. In particular, MSCI is using the SIN List to identify the most at-risk product categories and therefore identify the most at-risk companies based on the number of SIN List chemicals they use in their products. The U.S. Department of Defense is also using the SIN List, Thorpe said. It wants to identify and proactively manage emerging contaminants that can adversely impact human health and the environment, and to better understand the effects that REACH might have on military readiness. Finally, it is using the SIN List as a leading indicator of potential substitutions in commercial off-the-shelf products. Thorpe next spoke about GreenScreen, a method for advancing informed substitution. “This is a method for comparative chemical hazard assessment developed in house by Dr. Lauren Heine and Dr. Mark Rossi,” she said. It builds on the Design for Environment approach of the EPA. It is freely and publicly accessible and can be downloaded from the Clean Production Action website (http://www.greenscreenchemicals.org). 

118 ENVIRONMENTAL HEALTH RISKS OF CHEMICALS A GreenScreen assessment is done in three steps: (1) assess and clarify hazards, (2) apply the benchmarks, and (3) make informed decisions. For the first step GreenScreen covers 18 hazard end points groups into four categories: Human Health Group I (carcinogenicity, reproductive toxicity, etc.), Human Health Group II (acute toxicity, neurotoxicity, skin sensitization, eye irritation, etc.), Environmental Toxicity and Fate (acute aquatic toxicity, bioaccumulation, etc.), and Physical Hazards (reactivity, flammability). Once the particular hazards have been identified, the more time- consuming step is applying the benchmarks to the hazard classifications in order to determine how much of a concern a particular chemical is. It is a complex process, but the outcome can be presented as a simple numerical score from 1 to 4, with 1 being “avoid/phase out” and 4 being “inherently low hazard.” “It is this benchmarking use of the GreenScreen that companies find useful because you are categorizing chemicals into this kind of continuous improvement,” Thorpe said. As an example of how companies are using GreenScreen, Thorpe described the experience of Hewlett-Packard (HP). HP is interested in GreenScreen, she said, because replacing materials is very expensive. “You do not want to invest in a multi-million-dollar new material and find 2 years later it is going to be restricted within regulation. It makes good economic sense to reduce your business risk and understand what is inherently safer. Plus they want to avoid unintended consequences and identify preferable materials.” HP uses GreenScreen to choose alternatives to substances of concern that must meet GreenScreen benchmark 2 or higher. The company also has found that by articulating material goals to its suppliers, it can really spur innovation, Thorpe said. “Using the GreenScreen benchmarks allows a company to not only tell suppliers what they do not want (e.g., their restricted substances list) but it allows a company to clearly identify the criteria of what they do want.” For example, one of HP’s goals is to phase out all halogenated flame retardants and polyvinyl chloride (PVC) polymers. It has integrated GreenScreen into its procurement and specifications to its supply chain. In the specific case of power cords, HP’s suppliers must meet GreenScreen benchmark 2 or higher to get on the approved materials list. The company has now screened well over 30 materials, and several have been approved. The screening is mandatory, Thorpe said, and is in addition to all the usual standard and regulatory requirements. HP requires full disclosure under confidentiality agreements. 

CURRENT EFFORTS TO REDUCE THE RISK OF CHEMICALS 119 “What they find is that the formulators are very engaged,” Thorpe said. “They are actively performing GreenScreens. They like it because you are giving them very clear criteria. You are seeing this innovation within the supply chain, which we find really interesting.” Thorpe provided a direct quote from one of HP’s suppliers, Jonathan Plisco of PolyOne, explaining the advantages of GreenScreen: “The more you know about what you are putting into your products, the more likely you are to make choices in product development.” In the future, Thorpe said, HP will expand the use of GreenScreen to other materials it procures from suppliers, and the company is also helping integrate GreenScreen into the electronic sector generally. Other information technology companies are now using GreenScreen as well, she said, and HP is helping to introduce GreenScreen methodology into ecolabels. Finally, Thorpe described a set of principles for assessing alternative chemicals that were formulated in 2013 by a group of environmental health scientists, advocates, policy makers, and academics. The Commons Principles for Alternatives Assessment2 are based on earlier work done by the Lowell Center for Sustainable Production, the Toxics Use Reduction Institute, the Environmental Defense Fund, and the BizNGO Working Group. The aim is to phase out hazardous materials, phase in safer substitutions, and eliminate hazardous chemicals wherever possible. The group settled on six fundamental principles: (1) reduce hazard, (2) minimize exposure, (3) use best available information, (4) require disclosure and transparency, (5) resolve trade-offs, and (6) take action. Or, as Thorpe summarized it, “Our whole modus operandi is to move off of inherently hazardous materials to safer alternatives through informed substitution and more information.” 2 The Common Principles for Alternatives Assessment are a set of common definitions and principles for chemicals alternative assessment to be shared and used in framing discussions about alternatives assessment and to guide decision making about safer chemical use. Further information is available at http://www.bizngo.org/alternatives-assessment/commons-principles-alt-assessment (accessed March 31, 2014). 

120 ENVIRONMENTAL HEALTH RISKS OF CHEMICALS CASE STUDY: MASSACHUSETTS TOXICS USE REDUCTION INSTITUTE Liz Harriman, Deputy Director of the Toxics Use Reduction Institute (TURI) at the University of Massachusetts, Lowell, spoke next. She discussed the toxics use reduction program and then offered two case studies in finding safer alternatives to toxic chemicals. The Toxics Use Reduction Act, which established TURI, is intended to sustain and promote the competitive position of Massachusetts industry while promoting a reduction in their use of toxic chemicals. Harriman explained that the law requires businesses to analyze their use of toxic chemicals every other year, to look for opportunities to reduce their toxics use and waste, and to publicly report their toxic chemical use, but it does not require the businesses to implement anything. TURI has a number of roles that were set out by the Toxics Use Reduction Act. It provides information on toxic chemicals and safer alternatives as well as education, training, and tools for those working on toxics use reduction. It carries out research on and demonstrations of green chemistry and innovative technologies. It provides grants and supports academic research to help connect the needs of businesses with those who have the relevant knowledge about and capacity for reducing the use of toxic materials. “The decision makers that we are trying to reach are manufacturers, small businesses, community groups,” Harriman said. “We need to tailor the information we provide to that audience.” On the other hand, she added, “when we go to make decisions on what chemicals should be on the list of the program or should be prioritized, we make a much deeper dive. Our science advisory board requires extensive information to make those kinds of decisions.” TURI is also the science and policy arm of the program. As such it has released a number of reports describing the chemicals used in Massachusetts and various health issues that are known to be related to chemical use. However, she said, the objective of the reports was not to try to establish a direct link between chemical use in the state and cancer rates and other health statistics. “It was really to educate our toxics use reduction planners who were doing those assessments for companies about what the health risks are of the various chemicals they use and to educate the cancer industry and the cancer researchers about what chemicals are being used in industry that might affect cancer rates. It was very much informing each group.” 

CURREN NT EFFORTS TO O REDUCE THE RISK OF CHEMIICALS 1121 To o illustrate thee issues that TURI T deals wwith, she offerred a case study on perchloroethylen ne, a chemicall widely used in dry cleaninng, in industrrial vapor degreasing, d an nd in some pro oducts for connsumers and sm mall businesses, such as a brake clean ners. Perc, ass it is widelyy known, is a neurotoxin; is though ht to be a hum man carcinogeen; can cause damage to thhe liver, kidneey, and ceentral nervouss system; and is toxic to aqquatic organissms. Th he assessmentt of alternativ ves to perc waas carried outt with a generral model developed by b TURI in co onjunction wwith the Intersstate Chemicaals Clearinnghouse, IC2 2 (see Figure 6-1). The sevven-step process begins wiith defininng the goal an nd then identtifies the chem micals of highh concern. Sttep 3 is to identify alterrnatives to thoose chemicalss. These alterrnatives may be other chemicals orr products orr perhaps a pprocess that can satisfy tthe same need n as the chemical c in question. q Stepp 4 is to priooritize and prre- screenn the alternatiives, and Steep 5 is the allternatives asssessment. Thhis involvves a techniical and perrformance aassessment aas well as an enviroonmental, heaalth, and saffety assessmeent, which can be done in variouus ways—for example, by the GreenSccreen tool forr a chemical-tto- chemiccal substitutio on. There is also a financcial assessmeent to whatevver extent is possible. However, H Haarriman notedd, “We often ddo not have thhat 1. De efine Goal 2. ID Chemicals of o High Cooncern 3. Ide entify Alternatives 4. Prrioritize and Pre-Screen P Altternatives 5. Altternatives Assessment • Performance Technical/P Assessmen nt • EH&S Asse essment • Financial Assessment A 6. An nalyze Information 7. Se elect Alternative FIGUR RE 6-1 Safer alternatives a assessment modell. NOTE: EH&S = enviironmental heaalth and safety,, ID = identify.. SOURC CE: IC2 Safer Alternatives Assessment, A 20011. Reprintedd with permissiion from IC C2. 

122 ENVIRONMENTAL HEALTH RISKS OF CHEMICALS kind of information. That needs to be left up to companies to do, but we provide what we have.” Step 6 is to analyze all that information, and Step 7 is to select the alternative. One of the alternatives included in the assessment was n-propyl bromide, a chemical that would normally have been discarded in the initial screening because of its human health risks. However, because it is not yet regulated by the EPA, some vendors are selling it to dry cleaners as a substitute that can replace perchloroethylene with no more effort than changing the seals on the dry cleaning machines. “We included it here to try to make sure that dry cleaners were informed before they made that substitution,” Harriman explained. One of the most promising alternatives is wet cleaning, which uses computer-controlled equipment and special detergent packages to clean clothes with very little water; afterward the clothes are put into a dryer until they are almost dry, at which point they are removed from the dryer and finished with special finishing equipment. Wet cleaning saves energy, it saves money, it often saves water, it results in better indoor air quality, and its quality of cleaning equals that done with perc. There are now 11 dedicated wet cleaners in Massachusetts, and TURI is encouraging more dry cleaners to switch to wet cleaning with demonstrations and the provision of information. In a second case study, Harriman spoke about hexavalent chromium. It is used in defense and aerospace applications, mainly in sealants, primers, and conversion coatings. Hex chrome is known to be carcinogenic in humans and a mutagen and developmental toxicant. Long-term inhalation can lead to lung cancer, perforation of the nasal septum, and asthma. TURI got involved in the search for alternatives in part because in 2011 the Defense Federal Acquisition Regulation Supplement called for industry to come up with alternatives and to get those through the approval process. In one typical use of hex chrome, a conversion coating containing the material is applied to an aluminum substrate; then a sealant containing hex chrome is used to fill gaps and recesses around the fasteners and joints; a primer containing hex chrome is applied on top of the sealant; and a topcoat is applied on top of that. The initial goal would be to replace the primer and sealant with versions that do not contain hex chrome, with the eventual goal being to find an alternative to the hex chrome conversion coating as well, so that the hex chrome can be done away with altogether. 

CURRENT EFFORTS TO REDUCE THE RISK OF CHEMICALS 123 A number of different companies are involved in the alternatives assessment and performance testing. “We could not do it without all those resources,” Harriman said. “The companies end up putting in millions of dollars worth of time in terms of fabricating and testing.” Lockheed Martin, for example, is carrying out accelerated corrosion testing, while NASA is doing long-term corrosion testing. TURI does the statistical analysis and writes papers reporting the results. Part of the project involves bringing the different components of the supply chain together so that people can communicate and understand the needs and constraints of others. The supply chain includes the U.S. Department of Defense, the original equipment manufacturers, the component and material suppliers, and the metal finishers. “The metal finishers, which are sort of at the bottom of that supply chain, have a much harder time meeting some of these requirements, and they do not necessarily get a lot of assistance,” Harriman said. “Their customer will say, ‘I want a hex-chrome-free finish on that,’ but they do not necessarily give them all the technical assistance they need to provide that.” Much of the resistance to the process is coming from the metal finishers, she said. “These products have worked well for them for a long time and they are very resistant to change.” Much still remains to be done, even after appropriate alternatives are found. In many cases changes in the military specifications are required. And changing a sealant may require, for example, a change in the sealant remover. It is important to make sure that the new sealant remover is not something toxic. “In summary,” she said, “our objective is to eliminate the hazard, to adopt safer alternatives where they are available, to do alternatives assessments to avoid regrettable substitutions, and to form these collaborations and partnerships with companies so that the supply chains can benefit from that assistance.” CASE STUDY: BULLITT CENTER The session’s last presenter was Joseph David, Sustainability Program Manager at Point32, a real estate company in Seattle, Washington, focusing on land use development and construction. David is in charge of Point32’s effort to secure the Living Building Challenge certification for the Bullitt Center, and he spoke of his experiences as a consumer trying to navigate the world of selecting toxic-free materials. 

124 ENVIRONMENTAL HEALTH RISKS OF CHEMICALS The Bullitt Center, completed in April 2013, is a 52,000-square-foot office building in the Central District area of the Capitol Hill neighborhood of Seattle. It was designed to be green in a number of ways. It generates all of its own electricity on site through a 14,000- square-foot solar array on its roof. It is also designed to be a net zero user of water, with much of its water supplied by capturing the rainwater that falls on its roof in a 56,000-gallon cistern in the basement. The water is filtered and treated on site for potable and nonpotable uses in the building. The goal is also to produce zero net waste. The building uses composting toilets and creates field-ready compost in the basement. David summarized the goals of the Bullitt Center project with a quote from Denis Hayes, the director of the Bullitt Foundation: “Our desire is to open a wedge into the future so that we can see what is possible in a contemporary office building.” The project needs to be profitable, David said, as it is owned by a small philanthropy as part of its investment portfolio, but it also aims to be a game changer. Hayes had also said that if the building turns out to be a unique project in 5 years, then the foundation will have missed its goal entirely. “We want to uncover successes, failures, and share that with the green building community throughout the world,” David said. In building the Bullitt Center, David said, another goal was to minimize the use of toxic materials. One motivation was the presence of a variety of toxic chemicals in Puget Sound, many of which were deposited there because of runoff from the roofs of buildings, the city streets, and other sources. The developers of the center did not want to contribute to that problem. To that end, the developers decided to adhere to an environmental building standard called the Living Building Challenge, using various issues in green construction such as responsible site selection, water management, energy conservation, and the use of green materials. It was the materials part of the standard that was most unfamiliar, David said. “We talk about green materials in the context of recycled content or where the product is sourced, but the issue of toxicity had not really come up.” To adhere to the Living Building Challenge standard it was necessary to avoid using any materials from a list of 362 prohibited chemicals, including asbestos, chlorofluorocarbons, formaldehyde, halogenated flame retardants, lead, petrochemical fertilizers and pesticides, phthalates, and PVC. “We have to prove to an auditor that, with a whole bunch of documentation, we have done our very best to avoid these chemicals.” 

CURRENT EFFORTS TO REDUCE THE RISK OF CHEMICALS 125 To do that it was necessary to check out the material safety data sheet for each potential building material. These data sheets list every component of a material, and these components can be checked against the list of prohibited chemicals. At first it seemed overwhelming, David said. “We are architects, engineers, builders, and contractors. We are not chemists or toxicologists.” If they saw formaldehyde on the data sheet, it was easy enough to cross that building material off the list and look for an alternative. But what to do about a chemical like decabromodiphenyl oxide? “We do not know if this is good or bad. What do we do?” Pretty quickly, he said, they realized that they should not be working with the names of chemicals but rather with the Chemical Abstract Service Registry numbers (CAS numbers). “Using available databases such as the Pharos Project database, we were able to take these CAS numbers and quickly vet them against known red list or avoided chemical lists, including the Living Building Challenge red list.” The vetting process they developed grouped the building materials into three major categories. There were materials, which were things like paint or sealant or adhesives. “It typically comes in a five-gallon pail and we typically use a brush or a gun to install it,” he said. There are material safety data sheets available for such materials, which can be tested against the red list. A second category consists of things they referred to as “articles”— small components such as a ball valve for a plumbing joint. Such articles do not come with a material safety data sheet. The third category is assemblies, things that have more than 10 parts. An example would be a water pump, which might contain hundreds of distinct components—the wiring, the circuitry, and so on. Again there is no material safety data sheet provided. “That is a pretty daunting task to figure out what red list chemicals might be present in something like that,” David said. Thus, the vetting process was simplest for materials: Get the material safety data sheet, extract the CAS numbers, and run the numbers through the Pharos Project database. However, they discovered that the data sheets generally disclosed only 15 to 20 percent of the chemicals used in the product. Sometimes the materials on the data sheet would be stamped as a trade secret or proprietary. “We essentially began a campaign to cold call the manufacturers of every product in the building and ask for cooperation in confirming that none of our red-listed chemicals were used in their products,” David said. That took a huge amount of time and energy for both the project team and the manufacturer. 

126 ENVIRONMENTAL HEALTH RISKS OF CHEMICALS The process was more difficult for articles. They could ask a manufacturer for a data sheet for each of the materials that made up an article, or they could have the manufacturer sign a letter confirming that none of the red-listed materials were in any of the materials that made up the article. Assemblies were an even bigger challenge. “It is a really difficult conversation to have with a manufacturer,” David said. “It is hard to know where all the distinct parts and pieces come from that make up that pump. . . . Sometimes we were able to get a blanket statement saying, Yes, we can confirm that 10 percent by weight or volume of this product does not contain red list chemicals, but beyond that, it was difficult.” This process was carried out for more than 1,000 products over the 3 years it took to design and construct the Bullitt Center. “We quickly realized we needed to standardize this process,” David said, so they developed a building material information request form that asked a manufacturer to answer basic questions about a product: Where is the product manufactured? Where are the source materials coming from? Did they contain the red list chemicals? What is the content of volatile organic compounds? What is the recycled content? And so on. “We sent that out to all the manufacturers. In most cases we got some level of participation and got these forms back and made the best decision we could about which products to use for our building.” From the manufacturer’s point of view, it was equally burdensome, as the Bullitt Center was not the only project with such questions. “The manufacturers are receiving these questions from dozens, hundreds, maybe even thousands of projects,” he said. “All the forms look slightly different. The questions are very similar . . . but it is a tremendous burden on the manufacturers to field all these questions.” The construction industry is struggling with the issue of how much chemical disclosure is appropriate. At this point, David said, there is a spectrum of disclosure. At one end is the material safety data sheet that virtually every product has. The problem with it is that it is difficult to extract all the information you need to make an informed decision about the constituent chemicals in that product. On the other end of the spectrum is a new label that has recently come into use. The Declare label requires manufacturers to publicly disclose 99 percent of the constituents in their products. That is convenient for consumers, but it presents some serious difficulties related to proprietary formulations and trade secrets. In the middle of the spectrum is a form called the Health Product Declaration. It is a reporting protocol that many manufacturers 

CURRENT EFFORTS TO REDUCE THE RISK OF CHEMICALS 127 and consumers have agreed on as a good way to standardize information about chemical constituents. It provides more useful information than the material safety data sheets but offers less of a threat to a business’s proprietary information. In closing, David described a particular episode during the construction of the Bullitt Center. A product called Fastflash from a company called Prosoco was being considered for use in the building’s liquid applied air barrier. “This is arguably one of the most important layers in the building,” he said. “It keeps the rain out. It keeps the warm conditioned air in.” They got the material safety data sheet for Fastflash and discovered there were a number of proprietary chemicals, so they called up Prosoco and asked if any red list chemicals were in it. Yes, it contained a type of phthalate which is what allowed it to stretch and flex. “I said thanks for working with us. We cannot use your product on this building.” One week later, however, the company called back to say that their engineers had been working on a reformulation of the product that could get rid of the phthalates. If they could have 6 months for research and development they should be able to help. Then, 5 months after that, the company called to say that it had succeeded. “Come on down to our lab. We just ran this reformulated product through 500 hours of hurricane testing in our test chamber. It is performing quite well.” And that material is what is now installed in the Bullitt Center—a reformulated, phthalate- free version of the original material. Seeing the success of that product, the manufacturer decided on a wholesale elimination of phthalates from its entire product line, and now all its products are phthalate-free and compliant with the Living Building Challenge red list, David said. “I think this is really a testament to the benefit of entering dialogue between consumer and manufacturer.” DISCUSSION In the discussion following the presentation, the first question concerned the attitudes toward green chemistry that are generally found within companies, laboratories, and other organizations. Trisha Castranio of NIEHS said that while laboratory employees generally do not want to have to worry about green programs, they do not want to be around toxic materials either, so they are willing to participate in programs to reduce them. Nonetheless, she said, the major push for green materials will need 

128 ENVIRONMENTAL HEALTH RISKS OF CHEMICALS to come from consumers. They will be the ones driving the movement toward for green chemistry. Zephanie Jordan of Johnson & Johnson said that attitudes within her company differ from department to department. For example, public affairs people believe it is important to the company’s leadership position that it continue to move forward on sustainability, but those in the supply chain and research and development are very sensitive to the disruptions that the move to green chemistry can cause. It is a real tension, she said. Connie Deford of Dow echoed Jordan’s observation. Many new graduates coming into the company are drawn by its sustainability programs and are very supportive of the move to green chemistry, while the employees who have been there for a while recognize how very challenging and expensive it can be for the company to make the major changes in the materials that they produce and use. David Constable of the ACS Green Chemistry Institute observed that most companies have people who are working to institute green chemistry, but there are many competing demands, and many people worry that the move to green chemistry may affect the quality of their products or something else in a negative way. Beverley Thorpe of Clean Production Action commented that one of the major obstacles to the movement to green chemistry is disclosure. Without disclosure, it is impossible to make informed decisions, but many companies resist making such disclosures out of fears of losing a competitive advantage. A follow-up question concerned how best to share the necessary information about products while still protecting necessary confidentiality. Jordan answered that her company, Johnson & Johnson, struggles with that issue, particularly as it relates to how much information it provides to consumers. One approach, she suggested, is to provide the information to regulators. There are also some voluntary systems that Johnson & Johnson participates in and to which the company provides information about its formulations. Deford of Dow agreed that it is a challenging issue. One approach is to use nondisclosure agreements. Also, she said, another option is to provide information on the product family rather than the specific chemical as the health and environmental profiles are very similar, or another option is to provide the requested information to a third party. Constable suggested that third-party certification can solve some of the problem. Having a material being certified as not containing any of a list of chemicals can be enough for certain customers. 

CURRENT EFFORTS TO REDUCE THE RISK OF CHEMICALS 129 Liz Harriman suggested that the confidentiality issues may not be as serious as some have suggested because of the increasing ability to analyze products and determine exactly what materials they contain. “I am not sure that there is really as much proprietary information as business would like to think there is,” she said. Joseph David of Point32 said that while some consumers are pushing for full disclosure of materials in order to make informed assessments, having a third-party verifier do independent assessments of products is also workable. Either model works pretty well, he said. Castranio pointed out, however, that there are a large number of different groups offering different sorts of seals of approval, and it is very difficult for consumers to learn enough about them to know which to trust. David agreed and suggested it would be useful to get industry agreement on a gold standard in certification in each sector. An audience member asked how information is collected about chemicals from other countries. David said that in building the Bullitt Center almost all of the products were produced within 1,000 kilometers of Seattle and there were very few instances where they had to go to an international source for a material in the building. In those cases there was a partner in the United States that was able to convey the questions and get information and whatever disclosure material was available from the suppliers. Constable said that there are not really any good mechanisms to get good information about what is in the chemical formulations that come from places like China or India. Thorpe suggested that, given the growing push for green products, the difficulty of proving that materials from other countries do not contain any hazardous chemicals might lead to a certain amount of relocation of the supply chain back to the United States. REFERENCE IC2 Safer Alternatives Assessments. 2011. IC2 safer alternatives assessments. Available at http://www.ic2saferalternatives.org (accessed January 28, 2014).