Regulatory Review: An Introduction to Alternatives Assessment
A basic understanding of AA may be useful to those in the adhesives and sealants industry.
Over the past couple of years, the concept of alternative assessment (AA) has become much more common in the regulatory environment. First, the Department of Toxic Substances Control (DTSC) within the California Environmental Protection Agency (Cal-EPA) brought this to the forefront in its so-called “Green Chemistry Rule.” More recently, the U.S. Green Building Council (USGBC) has introduced AA in recent drafts of LEED v.4 within materials and resources credits designed to promote greener products. It also exists in regulations in several other states and countries.
However, to the average person in the adhesives and sealants industry in North America—save for those in EH&S, regulatory affairs or maybe sustainability functions—AA is a relatively new concept. A basic understanding of the various components of AA may be useful to those in the business.
What is AA?
AA involves evaluating and quantifying the risk from exposure and hazards of chemical ingredients in a product. It is a toxicology-based assessment and does not involve efficacy or economics. Those factors become important in determining what to do with an AA.
What attributes are considered within AA?
AA considers 18 different attributes. Generally, these are broken into three major categories: human toxicity, ecological toxicity, and fate and physical hazards. Specific attributes include endocrine disruption, carcinogenicity, reproductive effects, developmental effects, reactivity, persistence and bioaccumulation.
Does AA include all aspects that may be considered in a life cycle assessment (LCA)?
No. Only toxicology is generally considered, and that primarily deals with the raw ingredients and end-of-life chemistries. Carbon footprint and other attributes seen in LCA are not considered. However, AA is a key partner to LCA in determining the complete sustainability profile of a chemical or product.
What tools or methods are available for performing an alternative assessment?
Many approaches are possible, but the most common are those based on the design for the environment model. Of these, the one gaining the most acceptance among early adopters and forward thinkers is GreenScreen™, created by Clean Production Action (CPA), a non-profit aimed at promoting healthier products in commerce. (More information on GreenScreen and alternatives assessment is available at www.cleanproduction.org/Greenscreen.v1-2.php.)
Will regulations require certified, verified or audited AAs?
While this is still uncertain, it is likely that AAs performed or verified via third parties will carry more weight with regulators than self-declared AAs. In the de factomarket, regulations seen in green building systems such as LEED, or voluntary programs such as Healthy Products Declarations, third-party analysis will probably be required and rewarded somewhat better in terms of value.
What does it take in terms of time and money to do an AA?
Expert AA practitioners have been quoted as saying three working days per chemical in a product. For example, if a formulation has 10 ingredients, one could assume 30 working days. This includes data mining, scoring, report preparing, etc. While prices vary widely, manufacturers can expect to spend $1,000-2,000 per chemical analysis.
How often would an AA need to be redone?
A general rule of thumb is every three years. As the data used to determine chemical hazards improves in quality and quantity, and chemicals are added to lists of deselected or banned substances, analyses need updated.
What can AA be used for other than meeting regulatory needs?
While many uses and benefits exist, perhaps one of the best is that AA is a great tool to use in the product development process to promote the removal of chemicals of concern from the product line. This promotes a systematic “greening” of the portfolio and reduces the need to reformulate in the future.
Moving forward, AA will become a bigger part of the lexicon in adhesives and sealants regulation. For now, being aware of this assessment and what it may mean for our industry and individual businesses is an important first step in preparing for what is likely coming.