EPA updates Alternatives Assessment for flame retardants in printed circuit boards.

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Today, EPA’s Design for the Environment (DfE) program released an updated draft Alternatives Assessment of flame retardants in printed circuit boards (PCBs) in electronics. The report [PDF] revises a draft released in 2008; according to the agency, the new report “is being released for a second public comment period because of the large amount of information added describing the combustion testing conducted between 2008 and 2012,” and to update hazard profiles to align with the 2011 DfE Hazard Assessment Criteria [PDF]. In addition, the new draft addresses comments made on the 2008 draft.

This report is the result of a partnership convened in 2006 by EPA and members of the electronics industry and other sectors to develop information to better understand materials used to provide fire safety for PCBs in electronic equipment like computers and cell phones. The report’s purpose is to provide objective information to help electronics-makers “more efficiently factor human health and environmental considerations into decision-making when selecting flame retardants for PCB applications.”

The new draft assessment provides health and environmental information on flame retardant alternatives to tetrabromobisphenol-A (TBBPA), one of the most commonly used flame retardants for printed circuit boards. Hazard profiles vary across the three categories studied: reactive flame retardant alternatives (TBBPA, DOPO, and Fyrol PMP), reactive flame retardant resins (TBBPA-based resin and DOPO-based resin), and additive flame retardant alternatives (aluminum diethylphosphinate, aluminum hydroxide, magnesium hydroxide, melamine polyphosphate, and silicon dioxide). Human health effects for all of the assessed substances varied, with a range of toxicity endpoints. In terms of environmental fate, the reactive flame retardant alternatives and reactive flame retardant resins were all rated High or Very High for persistence, although TBBPA and DOPO were rated Moderate and Low for bioaccumulation, respectively. All five of the additive flame retardant alternatives are expected to have High persistence and Low bioaccumulation potential.

The report applies “life-cycle thinking” to explore factors affecting exposure, including occupational best practices, raw material extraction, and manufacturing. Results of combustion testing experiments simulating end-of-life disposal processes are also described.

Comments will be accepted on the draft report through February 15, 2015, under docket number EPA-HQ-OPPT-2014-0893.

New chemical footprint tool released.

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Clean Production Action, an environmental nonprofit, and the Lowell Center for Sustainable Production at the University of Massachusetts Lowell yesterday announced the launch of a new tool for companies and investment firms to measure suppliers’ use of safer chemicals and evaluate their own progress towards sustainability. The Chemical Footprint Project (CFP) is a third-party benchmark facilitating the comparison of corporate chemical use practices, conceptually similar to carbon footprint metrics.

The CFP defines “chemical footprint” as “the total mass of chemicals of high concern (CoHCs) in products sold by a company and used in its manufacturing operations.” The CFP identifies chemicals of high concern as all chemicals on California’s Safer Consumer Products list of Candidate Chemicals.

The CFP’s Steering Committee and Technical Committee members are drawn from several major corporate and nonprofit stakeholders, including Target, Staples, Kaiser Permanente, Hewlett-Packard, Seagate Technology, ChemSec, Environmental Defense Fund, and the U.S. Green Building Council.

According to the Project’s press release, the CFP is “the first initiative to publicly measure overall corporate chemicals management performance by evaluating:

  • Management Strategy
  • Chemical Inventory
  • Progress Measurement
  • Public Disclosure.”

The Project is expected to be fully operational in early 2015. The CFP is only the latest initiative to measure and manage the environmental and health impacts of products based on chemicals in supply chains. In October, the World Business Council for Sustainable Development released a guidance document on life cycle assessment (LCA) methods for chemical products. Last year, retailers Target and Walmart both announced sustainable chemical products programs which were both based on private standards.

EPA invites submissions to add ingredients to Design for Environment Safer Chemical Ingredients List.

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Today, the EPA’s Office of Chemical Safety and Pollution Prevention announced a new initiative to expand the number of chemicals and functional use categories on its Design for Environment (DfE) Safer Chemical Ingredients List (SCIL). Under the new initiative, EPA is inviting manufacturers to voluntarily submit chemicals/ingredients for review and inclusion on the SCIL. Submitters must “fully disclose” the chemicals to the agency’s DfE program as well as to one of EPA’s authorized third-party profilers, who will compile a hazard profile for each chemical. After receiving the submission from the profiler, DfE will review the chemical profile to determine whether it meets DfE criteria for inclusion on the SCIL.

Interested manufacturers are instructed to contact one of the two authorized third-party profilers, NSF or ToxServices. For chemicals that would be the first ingredient in a component class, EPA also recommends requesting a consultation with the DfE program to discuss broader context implications before the SCIL evaluation takes place.

In addition, EPA encourages cleaning product formulators to participate in the independent CleanGredients program, noting that profiles prepared for SCIL screening may also be used to qualify for CleanGredients.

EPA's ChemView database updated with new chemical SNURs and consent orders.

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Yesterday, EPA announced updates to ChemView, its public online tool for accessing information about chemicals regulated under the Toxic Substances Control Act (TSCA). The updates include enhanced data functions as well as updated, more comprehensive information.

The improved data functions include:

  • Improving the display and content for the Chemical Data Reporting information;
  • Adding a new link that displays the pollution prevention information generated as part of the Toxics Release Inventory program; and
  • Launching an administrative tool that will save EPA resources by streamlining the loading of future information.

ChemView’s databases were updated with the following new information:

  • 244 consent orders;
  • An additional 1,205 Significant New Use Rules (SNURs) for new and existing chemicals;
  • 16 additional chemicals with test rule data, and
  • Updates to the Safer Chemicals Ingredient List (part of the agency’s Design for Environment program).

In EPA’s press release, Assistant Administrator for the Office of Chemical Safety and Pollution Prevention Jim Jones explained that the agency was acting since Congress’ attempts to reform TSCA have so far been unsuccessful: “In the absence of TSCA reform, EPA is moving ahead to improve access to chemical health and safety information, and increase the dialogue to help the public choose safer ingredients used in everyday products.”

With the updates, ChemView now covers 10,000 chemicals and includes for the first time consent orders and new chemical SNURs. ChemView was first launched in 2013 to improve the availability of information on existing chemicals by displaying “key health and safety information and uses data in a format that allows quick understanding.”

Global chemical industry publishes guidance on environmental footprints for products.

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Ten global chemical companies and stakeholders have released guidance for the chemical sector on communicating a product’s environmental footprint using life cycle assessment (LCA) methods. Collaborating as a working group of the World Business Council for Sustainable Development (WBCSD), the members developed the guidance document – titled Life Cycle Metrics for Chemical Products – with the objective of facilitating “improved sustainability across value chains” by communicating reliable information using a “common language.” The guidance is based on ISO 14040:2006 and 14044:2006 and sets out requirements covering topics including:

  • Footprint system boundaries: Product footprint studies should be cradle-to-grave, except for business-to-business products, which may use cradle-to-gate studies. Cradle-to-gate studies must include end-of-life impacts for all waste generated in production.
  • Defining the functional unit and reference flow: The functional unit must be consistent with the goal and scope of the study, and the duration of the functional unit must be specified for cradle-to-grave studies. Compared solutions shall be assessed on main functionality, technical quality (stability, durability, ease of maintenance), and additional functions rendered during use and disposal.
  • Impact categories, energy, and other flows: The guidance names certain models to use in characterizing impacts ranging from global warming to marine eutrophication to human toxicity and ecotoxicity. Energy flows, including cumulative energy demand, renewable energy consumption, and non-renewable energy consumption, must also be assessed and reported.
  • Data source requirements and quality management: Primary data (from specific operations in the studied product’s life cycle) should be “the most accurate available data,” including on-site measurements of aggregated consumed water, energy, and raw material, as well as continual air and water emissions.
  • Main methodological choices: The guidance provides a decision tree for choosing how to allocate environmental impacts for multiple products with different functions coming from the same system. Other methodological choices addressed include: attribution of recycling benefits; avoided emissions; bio-based carbon storage; carbon storage and delayed emissions; and land-use change.
  • Uncertainties of results: At a minimum, studies should include a qualitative description of uncertainties. Quantitative assessments of uncertainty based on Monte Carle simulations are optional.
  • Critical/peer review: Chemical product footprint studies must undergo peer review to assess consistency with the guidance. Externally published comparative claims must undergo “an external critical review by a panel of LCA experts.” All studies must include a statement specifying that the study was critically or peer reviewed and summarizing the review’s conclusions.

This guide is the third release from the WBCSD Chemical Sector’s “Reaching Full Potential” project, which previously released guidance for the chemical industry on accounting and reporting corporate greenhouse gas emissions and avoided emissions. Together, the Project’s publications seek to provide for “consistent and credible communication on how the value chains of chemicals impact on and contribute to sustainability.”

The working group is comprised of major companies like BASF, Eastman Chemical, Evonik, and Solvay, as well as Cefic, the European Chemical Industry Council. The next step for the Reaching Full Potential project is to develop a guide for companies to assess social impacts and benefits of chemical products. Development of that guide is already under way, with release expected in late 2015.

National Research Council advises EPA on sustainability-based decision-making.

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A new report advises the U.S. Environmental Protection Agency (EPA) to consider incorporating sustainability concepts used in the agency’s Design for Environment (DfE) program in its new chemicals screening process as it evolves, suggesting a new direction for Toxic Substances Control Act (TSCA) reform. The National Research Council (NRC) says that EPA should incorporate into its decision-making process an integrated strategy for evaluating effects on the three dimensions of sustainability – environmental, social, and economic – across all the agency’s activities.

This week, the NRC, the principal operating agency of the National Academies, released its report, Sustainability Concepts in Decision-Making: Tools and Approaches for the US Environmental Protection Agency. The NRC found that a wide variety of tools are available for the agency to use in integrating sustainability concepts into its decision-making, while declining to give “prescriptive advice” on “the use of specific tools and specific decisions” and recognizing that incorporating sustainability into EPA decision-making will be an “evolutionary process.”

The NRC’s report elaborates on issues left unresolved in the NRC’s 2011 report, Sustainability and the U.S. EPA (also known as the Green Book); this new report was commissioned by EPA “to examine applications of scientific tools and approaches for incorporating sustainability considerations into assessments that are used to support EPA decision-making.”

The report includes among five case studies examining how EPA could incorporate sustainability tools into its decision-making the agency’s DfE program. The NRC recommends that EPA use a “systems-thinking approach,” in contrast to the agency’s traditional focus on reducing releases from specific source categories. Likewise, in regulating products, EPA is urged to consider potential life-cycle effects of business processes along the entire value chain. In particular, the report advises EPA to consider applying lessons learned from the DfE program to the new chemicals screening process under TSCA. The NRC highlights the following approaches from the DfE program:

  • Convening public-private partnerships;
  • Using a variety of screening-level and quantitative analytic tools (like life-cycle analysis and alternatives assessments) relevant to sustainability; and
  • Using a variety of indicators (ecotoxicity, human toxicity, bioaccumulation, and environmental persistence) relevant to sustainability.

EPA is also advised to look to the private sector’s sustainability expertise to learn about tools used outside the agency, and to convene the private sector and NGOs “to define and implement value-chain-wide goals and performance outcomes.” In addition, the NRC recommends that EPA work to share insights and best practices learned from leading companies with other businesses.

EPA seeking feedback on new logo for Design for Environment label.

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Yesterday, the EPA’s Design for the Environment (DfE) program announced two listening sessions to solicit public input as part of the process of redesigning the new logo for the voluntary product labeling program. Chemical-based products – like cleaning solutions and laundry detergents – bearing the DfE label must meet certain standards that exclude ingredients that have been identified as chemicals of concern. Four proposed design concepts for the new logo are posted online. EPA’s stated goals for the new logo are:

  • Better convey the scientific rigor of EPA’s product evaluation and the benefits to people and the environment with a label that is easier to display on products, materials, and in digital media;
  • Increase buyers’ recognition of products bearing EPA’s Safer Product Label; and
  • Encourage innovation and development of safer chemicals and chemical-based products.

E&E News reports that industry groups are concerned with the logo redesign, quoting American Chemistry Council president Cal Dooley at a conference earlier this year calling the DfE program “unprecedented” in terms of the label’s “potential for significant market implications.” Dooley also expressed doubt that DfE met the Federal Trade Commission’s Green Guides guidelines for private labeling programs.

EPA’s listening sessions will be held as webinars on August 4 and 5, 2014, from 1pm to 2pm Eastern Time; participants must register no later than August 1. Comments are also accepted on the DfE label website. According to the Federal Register announcement, although EPA “does not intend to formally respond to all comments that are submitted, EPA will consider the information gathered from this notice and other sources as it selects a new DfE logo.”

EPA recognizes industry leaders using safer chemicals, reiterates need for TSCA reform.

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Making products with safer chemicals meets consumer demand while improving companies’ bottom lines and benefiting human health and the environment at the same time, says EPA Assistant Administrator for Chemical Safety and Pollution Prevention Jim Jones. Today, Jones wrote on the agency’s “EPA Connect” blog to highlight several U.S. companies leading in the area of safer chemicals in consumer products, including as partners in EPA’s Design for Environment (DfE) program. Jones lauded these product makers and retailers for “advancing industry beyond the safety ‘floor’ set by the outdated Toxic Substances Control Act (TSCA).”

Acknowledging that the absence of a DfE label does not necessarily mean a product is unsafe, Jones points out that the DfE label promotes supply chain transparency: “With the DfE label, you know what is going into a product and that the formula is the safest for human health and the environment based on the best available science and protective criteria—above and beyond the minimum legal requirements set by existing TSCA.”

Jones’ focus on the need to update TSCA, which has been the subject of significant legislative activity this session, is consistent with his previous public statements. In today’s post, he pledged EPA’s continuing commitment to its DfE partners regardless of the outcome of the current TSCA reform effort.

EPA identifies safer alternatives for flame retardants.

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Yesterday, EPA’s Design for Environment (DfE) program released two reports on flame retardants and their safer alternatives. One report is a draft update of a 2005 Alternatives Assessment on the flame retardant pentabromodiphenyl ether (pentaBDE) in flexible polyurethane foam; the other is a final Alternatives Assessment on Hexabromocyclododecane (HBCD), a brominated flame retardant used in polystyrene building insulation. Both chemicals pose risks to human health and the environment, including “potential reproductive, developmental, and neurological effects and can be persistent, bioaccumulative, and toxic to aquatic organisms.”

PentaBDE has already been phased out of use in the U.S.; in 2004, industry voluntarily agreed to cease production and EPA issued a Significant New Use Rule (SNUR) aimed at ending the chemical’s domestic manufacture. EPA proposed another SNUR in 2012 to address imports of pentaBDE-containing furniture or other articles. EPA identified oligomeric phosphonate polyol as a safer alternative to pentaBDE. PentaBDE has also been subject to flammability standards recently proposed and finalized by the Consumer Product Safety Commission and the state of California, respectively. EPA’s updated alternatives assessment is “[complementary to] the CPSC and California actions by providing important information for informed selection of flame retardants in the manufacture of home and office furniture, as well as the many home products not covered by these standards.” The draft update provides a hazard assessment for flame retardant chemicals used in upholstered consumer products containing polyurethane foam, including updated health and environmental profiles previously profiled in 2005 and new products in the category.

EPA issued this report on HBCD as part of the agency’s action plan for HBCD under the Existing Chemicals Management Plan. Although HBCD is also used as a flame retardant in textile back coatings and high-impact polystyrene in electronics housings, the Alternatives Assessment only addresses its use in expanded polystyrene (EPS) and extruded polystyrene (XPS) foam insulation produced for the building and construction industry for fire safety. Butadiene styrene brominated copolymer was identified as a safer alternative to HBCD based on hazard considerations, with lower human health, ecotoxicity, and exposure potentials, although it is also inherently persistent due to its molecule size. Butadiene styrene brominated copolymer is regulated by its own SNUR and is commercially available from chemical suppliers, according to EPA.

Partnering with EPA's Design for Environment at Walmart Sustainable Products Expo.

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EPA is a significant partner to companies leading innovation efforts in the arena of safer consumer products, according to Assistant Administrator Jim Jones, of EPA’s Office of Chemical Safety and Pollution Prevention. In a blog post yesterday, Jones describes how EPA’s Design for Environment (DfE) program recently participated in a “Supplier Panel on Sustainable Chemistry” at Walmart’s first ever Sustainable Products Expo, which brought together leaders from EPA, NGOs, and product manufacturers.

As we have previously discussed, EPA’s DfE program – which establishes voluntary sustainability-related standards for consumer products like household cleaners – plays a major role in Walmart’s Sustainable Chemistry Initiative. Jones writes that EPA’s contribution is “providing scientific expertise and understanding of health and environmental impacts throughout the supply chain, educating consumers and companies alike, and bringing people to the table to stimulate dialogue and partnerships.” Jones notes that with “growing consumer recognition” and trust for the DfE’s “Safer Products” label and program criteria, EPA’s partnerships with companies like Walmart and its participating suppliers can promote sustainability, health, and the environment while meeting consumer demand and growing their business.

The Expo also featured announcements from Walmart and its suppliers of various new sustainability commitments and initiatives. One such initiative is the Closed Loop Fund, which will invest $100 million seeded from suppliers including Coca-Cola, Pepsico, and Johnson & Johnson in recycling infrastructure with the goal of “transforming the recycling system in the United States.” Cargill made commitments to increase supply chain transparency in beef and Procter & Gamble pledged to reduce water use for liquid laundry detergent. Together, the suppliers participating across all of these voluntary sustainability efforts account for over $100 billion in sales at Walmart.