In Pursuit of Safer Alternatives Using California’s SCP Alternatives Analysis – With Kelly Grant
Hosted by Jenny Shaw, SETAC; Transcript by Donna Frankel, SETAC
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JENNY SHAW: Hello and welcome to the podcast for the journal Integrated Environmental Assessment and Management, better known as IEAM. I’m Jenny Shaw. Every day, we encounter chemicals just by going about our lives. From the beauty products in your morning routine, to the packaging in your take-out meal, to the furniture that you’re sitting on, chemicals are found in just about everything we touch or consume, and not all of them are completely benign. The identification and substitution of safer chemicals is an ongoing work in progress for regulatory bodies and manufacturers alike.
The July 2022 issue contains an article that discusses California’s Safer Consumer Products regulation, a program committed to identifying safer alternatives to chemicals of concern through a process that goes beyond traditional alternatives assessment. Today we’re speaking with lead author Kelly Grant. She’s a senior environmental scientist at Safer Consumer Products at the California Department of Toxic Substances Control.
JENNY SHAW: Hi Kelly. Thanks for joining us today.
KELLY GRANT: Hi Jenny. Thanks for having me.
JENNY SHAW: So, your paper discusses alternatives analysis, which is different from alternatives assessment, which might be a term that is more familiar to our listeners. Can you tell us about alternatives analysis?
KELLY GRANT: So, alternatives analysis is California’s brand name for alternatives assessment, except that our process is defined by regulations. It has very specific requirements, and it’s quite comprehensive compared to alternatives assessment. Whereas alternatives assessment tends to be a more generic term, and the approach really varies depending on the framework that’s used, who does the assessment and who the audience is. Some of the AAs are geared towards manufacturers trying to find safer ingredients, and some are geared towards purchasers, like those who might be trying to decide what type of athletic field to install in their schools or parks. SCPs, or Safer Consumer Products, alternatives analysis is a comprehensive process that is completed by the manufacturer with the goal of them finding a safer alternative for their products.
JENNY SHAW: So, it sounds like alternatives analysis is a much more comprehensive process, as you said, and it’s going to entail a lot more work for manufacturers. Why is it needed?
KELLY GRANT: Let me start first by [explaining] why alternatives assessments are needed. There are tens of thousands of chemicals in commerce, and most of these are really poorly characterized with regard to toxicity, but also, when thinking about their exposure potential characteristics like persistence or mobility. So, in the Safer Consumer Products AA, or alternatives analysis, process, the manufacturer has to look at a wide range of hazard endpoints that range from various human and wildlife toxicities to global warming potential or eutrophication. And the manufacturers have to look at those concerns over the entire life cycle of the product, so, from extraction of the natural resources all the way down to the end of life and disposal of that product. It’s a really comprehensive process that also includes the exposure potential at each one of those steps. And beyond that, the SCP AA process also asks manufacturers to consider a broad range of alternatives. The manufacturers have to look at the removal of the chemical of concern. Can it be removed from the product, which really gets to this idea of: Is the chemical necessary for the function of the product at all? It can also look at reformulation of the product, which would involve, you know, a replacement chemical. They can also include looking at redesigning the product to reduce either exposure or the adverse impact from that product. The goal of the AA is to really broadly consider different ways to get to a safer product.
JENNY SHAW: Can you give us an example of a poor choice substitution for a chemical that could have been avoided had alternatives analysis been used?
KELLY GRANT: Yeah, so one example is bisphenol A, or BPA, in water bottles and baby bottles. Manufacturers were so eager to put that BPA-free sticker on their bottles. Unfortunately, many of the manufacturers continued to use nearly the same bisphenol chemistry. They just shifted from BPA to BPS, without really addressing the underlying safety concern. Another example that’s happening now really has elements of both regrettable and safer substitutions. Manufacturers of carpets, clothing, food packaging, etcetera, are starting to use safer alternatives now that they’re phasing out these short-chain PFAS. They had previously used long-chain PFAS, and, as the toxicity of those became public, they made the regrettable shift to these short-chain ones. So, early on, the toxicity of those short-chain PFAS was less well characterized, and when they switched, I don’t think they really appreciated that there was this tradeoff between the bioaccumulation of the long-chain PFAS and the mobility of the shorter-chain ones.
JENNY SHAW: Are there any success stories of chemical substitutions that have come as a result of alternatives analysis?
KELLY GRANT: So, I’m going to talk about alternatives assessments in general, and I’m going to talk about an example that a lot of people might not think of as an alternatives assessment. This was work done by the Green Science Policy Institute. Arlene Blum and her colleagues asked the question whether flame retardants were required in furniture. Did they actually help reduce the severity of fires or prevent fires? And the answer they found was no. And, so, their work really helped repeal this California standard that was putting all sorts of these flame retardants in our furniture. Because of that example, that’s one of the reasons that the SCP AA’s office starts by asking the manufacturer to reflect on whether the chemical is necessary in the product. If the chemical adds no value or no function, then it’s really simple to remove it. That’s the easiest path in terms of chemical safety. Now, we know things are rarely that simple, but, you know, it’s a really good place to start.
JENNY SHAW: Right. It’s an easy first filter.
KELLY GRANT: Yeah.
JENNY SHAW: So, how does California’s Safety Consumer Products regulation compare to regulations in other states, or even countries?
KELLY GRANT: Until a couple of years ago, regulatory AA programs were quite rare. The Safer Consumer Products program developed the first regulatory AA process in the United States. And, as I’ve mentioned before, our AA process is the most comprehensive that I’m aware of. In our case, the manufacturers conduct the alternatives analysis, or AA, and the philosophy behind that is that they have the technical knowledge to know what’s feasible in their products. A couple of years ago, Washington State passed their safer products law, and in that instance the state completes the AA using a really well-established chemical hazard assessment, and like SCP, they analyze a wide array of alternatives, not just drop-in chemical replacements. And one of the things that I think is really cool about their approach is that they’ve elected to work on large classes of chemicals to further reduce the chance of regrettable substitutes. Oregon has the Toxic-Free Kids Act, and that primarily focuses on other regulatory approaches to achieve safer children’s products, but it also incorporates alternatives assessment. In the EU, REACH was really the premier use of regulatory AAs. And it’s had some really wonderful successes, and has also provided a number of learning opportunities about AAs.
JENNY SHAW: Sounds like California comes out among the most stringent in the states. Are there any aspects of the California approach that you would like to see improve?
KELLY GRANT: Well, and again here, I think I’m going to talk generally about alternatives analyses and alternatives assessments. One of the biggest issues is there are just so many data gaps, especially when it comes to chemical hazards. You know, the whole point is to be built to compare the safety of chemicals, and that’s really hard to do when there’s data missing. One of the things I’d really like to see is continued development and deployment of new approach methodologies so that we can have better predictions of toxicity or other health and environmental endpoints that are of concern.
JENNY SHAW: So are all these different government entities working off similar or the same databases?
KELLY GRANT: You know, there’s no central repository of what chemicals are in products. I would say that is another one of the big challenges with AAs. There’s not a lot of consolidated databases with that sort of information.
JENNY SHAW: The process must be so much more difficult if there’s no cross-communication between any of these regulatory bodies.
KELLY GRANT: Well, and just the number of chemicals in products. You know, it’s not always the predominant chemical that’s of concern. Sometimes it’s even getting at these chemicals that might not even be disclosed or are in there at small percentages that are really driving the toxic concerns with some of these products.
JENNY SHAW: Right, because I think everyone’s first thought as a consumer is what’s the primary chemical, right? We look at the first five ingredients on the label.
KELLY GRANT: Yeah, whereas the concern might be in the fragrance, or preservatives, which is way down on that list.
JENNY SHAW: Kelly, we so appreciate you taking the time to talk to us today.
KELLY GRANT: Well, Jenny, thank you so much. I really appreciate the opportunity to talk about the Safer Consumer Products AA process.
JENNY SHAW: You’ve been listening to Kelly Grant discuss her article, “Informed substitution of hazardous chemicals through the lens of California’s Safer Consumer Products Alternatives Analysis: Best practices, challenges, and opportunities.” Access the article in the July 2022 issue of IEAM. Just go to setacjournals.org. I’m Jenny Shaw, and thank you for listening to the IEAM podcast.
(End of recording)
* Transcription was generated from audio files and may contain minor errors due to sound quality.
Author’s contact: [email protected]
