Chapter 9. Conclusions and Recommendations
- 9.1.1 Conclusions regarding the specific chemicals
- 9.1.2 Conclusions regarding the alternatives assessment process
- 9.1.3 Conclusions regarding statewide economic impact
This report presents the results of alternatives assessments performed for several uses of each of five toxic chemicals. Through the preparation of this report, the Institute has learned both about the applicability of these specific alternatives and about the suitability of alternatives assessment as a methodology for informing toxic chemical use reduction.
9.1.1 Conclusions regarding the specific chemicals
The Institute performed alternatives assessments for 16 different use categories of the five chemicals. The Institute intentionally selected chemical uses for which some viable alternatives were expected to be available, and for which a detailed assessment of the technical, financial, and environmental health and safety characteristics of those alternatives was expected to be useful. In every case, at least one alternative was identified that was commercially available, was likely to meet the technical requirements of many users, and was likely to have reduced environmental and occupational health and safety impacts compared with the base chemical.
Many of the alternatives use chemicals that have been less thoroughly studied than the base chemicals, however, so their actual environmental and occupational health and safety impacts are less well understood. History presents many examples of chemicals that were thought to be relatively benign when first introduced but were later discovered to present significant problems (e.g. ozonedepleting chemicals, carbon tetrachloride as a degreaser).
The financial picture is mixed. Some alternatives clearly were cost-effective compared to the current process (e.g., salon drawer sanitizer elimination). Some involve significant capital costs for implementation but are likely to have positive net present values due to operating cost savings (e.g., high velocity oxy-fuel vapor deposition as a substitute for hard chromium electroplating). Some were clearly more expensive at this time (e.g., vapor degreasing solvent alternatives), and for many, particularly the emerging technologies, no cost conclusions could be reached due to a lack of information. There are also cases where the alternative is more expensive but the cost differential is unlikely to have a significant impact on consumers, businesses or industry. For example, the cost of medical device tubing is a minor part of the cost of neonatal surgery.
9.1.2 Conclusions regarding the alternatives assessment process
Alternatives assessment is at the heart of the planning process established under the Massachusetts Toxics Use Reduction Act (TURA). The success of Massachusetts companies in reducing their use of toxic chemicals provides strong evidence that alternatives assessment works. We now have both a more robust methodology for that type of assessment, and results for selected uses of the five chemicals that will provide a useful starting point for further user-specific investigation. The information contained in this report indicates that alternatives assessment is a useful approach to evaluating toxic chemical use.
The active involvement of all stakeholders was key to the success of this project. Their expertise, willingness to collaborate and share perspectives, and review of the report were invaluable. The involvement of a wide range of stakeholders throughout the project resulted in a more accurate assessment, more valuable results, and increased understanding of the issues, challenges and perspectives among stakeholders. In a broader sense, transparency was essential to the successful completion of this project, and is key to any successful alternatives assessment. This document can be used by others as a basis for their own work on alternatives, because the information we gathered is provided in the document.
Judgment was used in assigning comparison symbols (+, - ,=, and ?) in the summary tables; therefore readers should use these summary tables to get a quick overview of important issues, and then consult the text and supporting tables for a full discussion. The Institute clearly stated situations where we were not able to gather full information on a given parameter.
Alternatives assessment rests on a three-legged stool – the technical, financial, and environmental and occupational health and safety (EH&S) performance of each alternative. One key to the success of this project was the use of a set of consistent, objective criteria in each performance category. This approach helped to ensure consistency of results from one assessment to the next. Although the Institute is convinced of its utility, alternatives assessment is not without its difficulties. One significant difficulty is the selection of performance criteria for the EH&S evaluation. There are dozens of end points that could be considered (e.g., carcinogenicity, mutagenicity, LD50, flash point), and conflicting reasons to select many of them or just a few. Selection of a few criteria simplifies the analysis, but leaves the distinct possibility that a crucial category may be neglected. On the other hand, selecting a large set of criteria increases the analysis effort concomitantly, and introduces the new problem of aggregating and comparing the information across all of the categories.
In this study the Institute opted for a fairly large set of performance criteria, collecting data for the study chemical and its alternatives for 41 EH&S endpoints. Rather than attempting to combine these endpoints into one EH&S rating, this report presents the data for each alternative in tabular form, so that readers can make their own judgments about the environmental and occupational health and safety of the alternatives as compared to the study chemical.
Another difficulty with using alternatives assessment is the availability of full and objective information. Technical performance and cost data may be available for well-established technologies, but much less so for emerging ones. Similarly, the lack of EH&S information for newer chemicals reduces confidence in assessment results.
9.1.3 Conclusions regarding statewide economic impact
The panel of experts convened for this project were challenged with bringing their expertise to the complex topic of statewide economic impact from the adoption of alternatives. The framework created will assist users in analyzing likely economic impacts by clarifying the situational characteristics and factors that determine the outcome. Characteristics that may help to determine the economic implications of alternatives adoption include the size of the Massachusetts market in comparison with other markets, price sensitivity of consumers, nature of barriers to adoption, capacity of the workforce, and availability of useful and timely information.
The Institute’s experience in completing this project leads us to the following recommendations:
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Numerous promising alternatives were identified during this study. Many of these will require further work to determine their practicality and applicability for specific applications. Such work will speed up the adoption of these alternatives, and could include detailed discussions with vendors and users, independent laboratory testing of technologies, pilotscale industrial installations, supply chain workgroups and demonstration sites. The Institute has had success using these approaches for industrial toxics use reduction, and believes that there are many parallels for small businesses and consumer products. Examples of potential follow-up and additional research needs include:
- Automotive aerosol cleaners (obtain further technical performance and EH&S data on alternatives)
- Formaldehyde-free building materials (conduct basic research on new products and obtain associated EH&S data)
- Formaldehyde salon sanitary storage (work with salons, regulatory agencies and vocational schools)
- PVC in medical devices (conduct technical performance of the alternative plasticizers and alternative materials and obtain associated EH&S data)
- Lead-free fishing sinkers (work with supply chain, including manufacturers, distributors, retailers, state agencies and sport fishing associations)
- Alternatives to hexavalent chromium plating and passivation of zinc (conduct independent technical evaluations of the many emerging technologies)
- Both the TURA program experience and the Institute’s experience in performing this project illuminate the positive gains that can be made if the Commonwealth, industry, and the public work together in a proactive fashion to identify and solve problems. The Institute recommends that any further efforts to address alternatives assessment incorporate and encourage this cooperative approach.
- Alternatives assessment shows great value as a methodology, but its utility would be improved by the use of a consistent set of assessment criteria from one assessor to another. The Institute has been working with its sister institute, the Lowell Center for Sustainable Production, in the development of such a standardized methodology. Various other groups in the United States and other countries use similar but somewhat different methodologies. The Institute recommends that the Commonwealth take a leadership role in this area and that an international working group be convened to establish and publish an agreed-upon standard alternatives assessment methodology.
Finally, this study will have been a success if it spurs discussion and debate. It is our hope that the objective information in this report will serve as valuable source material for those discussions. Everyone can agree that the goal of reducing the use of toxic chemicals is admirable – it is the best path to that goal that is frequently hidden or disagreed upon. For several specific uses of five toxic chemicals, this report should point the reader to promising paths. Uncovering the best path will require the active and creative cooperation of government, industry, and the public.
This page updated Monday July 21 2008