Putting the Public into Alternatives Assessment

By Jennifer Sass, PhD

This essay is in response to: How can innovations in technology and research reduce exposures to toxic chemicals?

Progressive health experts, community leaders, and workplace safety specialists have long recognized the need to replace dangerous chemicals with safer ones in order to protect human health and the environment. Forward-thinking experts have advocated that many industrial and workplace hazards could be eliminated or reduced through the thoughtful incorporation of inherently safe (or safer) materials and technologies. Properly conducted, the alternative assessment framework offers a robust scientific approach to assessing the safety of alternative chemicals, materials, and products to replace harmful ones. Alternative assessment is necessary if we are to transition our economy away from its current over-reliance on hazardous and polluting materials. However, if such assessments are not conducted in a manner that is transparent, consistent, and inclusive then they will be subject to many of the same manipulations and suspicions that plague current risk assessment decisions.

Assessing alternatives can include replacing a hazardous chemical with a safer one, replacing a particular technology so that hazardous chemicals are no longer required, or redesigning a product so that the chemical is no longer needed. It doesn’t necessarily mean using completely benign chemicals. For example, a rocket fuel propellant may have to be combustible, but it doesn’t also need to impair hormone activity. The little batteries in children’s shoes that light them up don’t have to contain mercury to do the job. An alternative assessment can help identify safer replacement chemicals, or even non-chemical alternative processes or products. In all cases, care must be taken to make sure that the assessment of alternatives is thorough, so that risk-trading is at least downwards and not just from known to unknown risks.

Because alternative assessments can be extremely complex, the public must have timely, accurate, and accessible information about what goes into the assessment, including assumptions, extrapolations, uncertainties, and knowledge gaps. Risks are not just measured or calculated or estimated or modeled – they are also experienced, and not usually by the risk assessors, experts, or representatives of the polluting industry.

The corruption of information by regulated industries and their paid experts has led to the corruption of public knowledge about the risks that come with public exposure to toxic substances. There are many published accounts of chemical industry attempts to subvert regulations through interference with government risk assessments, withholding critical information, selective release of incomplete data, and endless efforts to delay a risk assessment by claiming that more data is coming. In addition, collaborations between industry and government have contributed to the imbalance of information and power.

With inaccurate information, regulators and the public are ignorant or misinformed about the risks associated with exposures to potentially hazardous materials, leading to ineffective evaluations of risks and alternatives.

Effective alternative assessments would drive the innovation of sustainable and socially-beneficial materials and safer technologies. Unfortunately, the Toxic Substances Control Act (TSCA), our nation’s failed law for regulating hazardous substances, needs to be rewritten to effectively apply alternatives assessments to prevent unnecessary exposure to harmful new and existing chemicals where safer alternatives are available. The Safe Chemicals Act of 2010, introduced by Senator Lautenberg in April, would require EPA to establish incentives for the development of safer alternatives, including market incentives for available alternatives and a research grant program to develop new ones for priority hazardous chemicals. The House bill, called the Toxic Chemicals Safety Act of 2010, introduced in July by Representatives Rush and Waxman, establishes a review process for safer alternatives to existing chemicals, and additionally requires new chemicals to be proven safe before they enter the market. If Congress passes strong chemical reform legislation then in addition to creating a market advantage for safer alternatives, it will create ‘green’ job opportunities conducting alternative assessments.

Additional reading:

For more on Alternatives Assessment Frameworks see: http://www.chemicalspolicy.org/alternativesassessment.lowellcenter.php

For more on TSCA reform policies see: http://www.chemicalspolicy.org/us.federal.tscareform.php

Meticulously documented examples of data manipulations by the chemical industry are reported in the following books and report:  Doubt Is Their Product: How industry’s assault on science threatens your health (Michaels, 2008); Deceit and Denial: The deadly politics of industrial pollution (Markowitz and Rosner, 2002); and, Rewriting the Rules: The Bush administration’s assault on the environment (NRDC, 2002).

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