Contributed by Richard Engler, Senior Policy Advisor with Bergeson & Campbell, P.C.
In 2014, the U.S. Environmental Protection Agency (EPA) and American Chemical Society Green Chemistry Institute® (ACS GCI) renewed their Memorandum of Understanding (MOU), continuing the partnership centered on the Presidential Green Chemistry Challenge Award. The award cycle returned to its original schedule with the 2015 ceremony set to coincide with the Green Chemistry & Engineering Conference, as it had until 2013. This year the conference will be held on July 14-16, 2015, in North Bethesda, Maryland. This recommitment between EPA and ACS GCI is an expression of the continued dedication each has to creating opportunities for the growth and development of green chemistry. 2015 is especially significant as it represents the 20th year for the Presidential Green Chemistry Challenge Award. The award ceremony and conference should highlight both the success of years past and the potential of years to come.
There are other positive indicators about the direction of green chemistry in the coming year as well. On January 5, 2015, Bergeson & Campbell, P.C. (B&C®) published “Predictions and Outlook for EPA’s Office of Chemical Safety and Pollution Prevention (OCSPP) 2015” (The Outlook). It covers the full range of OCSPP issues, including green chemistry and Design for the Environment (DfE).
In 2014, Jim Jones, OCSPP’s Assistant Administrator, continued his focus on green chemistry and DfE. Jones visited award winners to gain a deeper understanding of their technologies and businesses. Jones’s engagement in both programs should continue in 2015. DfE is undergoing revitalization in 2015.
EPA is expected to reveal the new Safer Product Labeling logo. DfE is also looking to expand its Safer Chemical Ingredients List (SCIL) and is providing new opportunities for DfE partners to be recognized for their efforts.
The New Year will also see more interactions between green chemistry and the Toxic Substances Control Act (TSCA). As you may know, manufacturers must submit “premanufacture notices” (PMN) to EPA prior to manufacturing or importing any substance not listed on the TSCA Inventory or otherwise exempt. TSCA allows EPA to review new substances for unreasonable risk to human health or the environment.
Most green chemistry technologies are classified as “new” under TSCA rules, so they must clear this hurdle. Some green chemistry technologies have drawbacks in one phase of their lifecycle and benefits in another. For example, a biobased substance may be less toxic to humans, but more toxic to fish relative to the petroleum-based incumbent. The challenge for EPA is how to consider these impacts, both positive and negative, especially relative to existing chemicals in commerce. Historically, EPA has only focused on the substance itself, its hazard, releases, and exposures, to determine “unreasonable risk.” Biobased chemicals, using waste as a feedstock, and greener production methods present new challenges to EPA as these benefits are upstream of the substance itself. As discussed in The Outlook, some green chemistry technologies have languished in the new chemicals review process or have been subject to requirements different from those imposed on nearly identical, existing chemicals. To avoid undue delays, some submitters have taken advantage of voluntary pollution prevention (P2) statements in PMNs to clarify the benefits of the novel technology to aid EPA in its decision-making. Even with this additional information, it is not a trivial task for EPA to compare and evaluate the relative risks and benefits at different stages of a chemical’s lifecycle. Novel biobased feedstocks, intermediates, and products will challenge both EPA and industry in 2015.
While some aspects of TSCA may be a barrier to new green chemistry technologies, TSCA can also be a driver for change. EPA regulatory action on existing chemicals will provide new drivers for companies to develop and deploy green chemistry. Near the end of 2014, EPA published its update on Work Plan and Action Plan chemicals. In particular, decisions on trichloroethylene, dichloromethane, benzedine dyes, short-chain chlorinated paraffins, phthalates, and long-chain perfluoroalkyl carbonates all present increasingly important targets for green chemistry innovations. Similarly, the California Department of Toxic Substances Control (DTSC) is moving ahead with its actions on priorit... and, of course, implementing the Safer Consumer Products Regulations.
Information about chemical design may get a boost from the maturation of EPA’s Computation Toxicology tools that allow rapid screening for endocrine disruption. The coming year is likely to also see progress on TSCA reform, which may include provisions relating to green chemistry.
While EPA struggles with diminished funding and diminished numbers of senior scientists (mostly through retirement), the fundamental prospects for green chemistry remain sound: There are many problems to solve and many scientists and engineers working to find sustainable ways to solve them. EPA and ACS GCI will continue to be central to supporting and nurturing green chemistry.
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