Alternatives Assessment Guide
Public Comment Announcement
The Interstate Chemicals Alternatives Assessment Guide v1.2 public comment period has ended. The Interstate Chemicals Clearinghouse (IC2) has published a draft of the IC2 Alternatives Assessment (AA) Guide v1.2. IC2 is accepting public comment on the guide from Febuary 1 to March 15, 2024. The IC2 AA Guide was developed by IC2 member organizations to provide a flexible approach for governments and other organizations to identify and promote safer chemicals and products through alternatives assessments.
- Revisions to the list of available hazard assessment tools that meet IC2 criteria.
- Changes to performance, cost, availability and exposure approaches to better support the evaluation of non-chemical alternatives.
- The replacement of tiered practices for stakeholder involvement with a single set of flexible recommendations for stakeholder engagement.
- The incorporation throughout the IC2 AA Guide of optional practices and considerations to address equity and environmental justice in AAs.
The published draft and full list of revisions can be found in the link above. IC2 welcomes feedback from AA practitioners, organizations with an interest in safer chemicals and products, and any other interested parties. All feedback will be reviewed and may be used to change the guide prior to final publication.
Public comments can be submitted to Mikalah Bailey, IC2 Project Manager, at mbailey@newmoa.org. The comment period will end on March 15, 2024.
Alternatives Assessment Guide
An alternatives assessment is a set of tools that manufacturers, product designers, businesses, governments, and other interested parties can use to make better, more informed decisions about the use of toxic chemicals in their products or processes. The IC2 published the first version (v1.0) of the IC2 Alternatives Assessment Guide (Guide), a comprehensive look at the developing science of alternatives assessments, in January 2014. It was the product of 20 months of effort by the IC2’s members, who collaborated with businesses and non-governmental organizations on the development of the Guide. The Guide provides assessors with three potential frameworks and sufficient flexibility to allow a wide range of users to conduct an alternatives assessment to replace toxic chemicals in products or processes with safer alternatives. The IC2 released an updated version (v1.1) in January 2017, with substantive changes to the Exposure Module that bring the Guide into closer agreement with the National Academy of Sciences’ A Framework to Guide Selection of Chemical Alternatives.
The National Academy of Sciences (NAS) used v1.0 of the Guide as a source document during formalization of its alternatives assessment method, documented in A Framework to Guide Selection of Chemical Alternatives. The NAS placed an increased emphasis on comparative exposure assessment, which is used to determine “… if the alternatives would be expected to result in substantially equivalent exposures…”. The NAS committee indicated that “… simplified exposure estimates without elaborate exposure modeling can meet the needs of many alternatives assessments”.
The first version of the Guide incorporated many of the principles of comparative exposure assessment, and the IC2’s recent update to v1.1 clarifies how comparative exposure can be used within the Guide’s frameworks to conduct an alternatives assessment.
In addition to the Guide, the IC2 prepared two Response-to-Comment (RTC) documents. The summary RTC document groups comments received and documents how the Guide was either updated or not altered based upon input received. The detailed RTC document contains a response to each individual comment.
The responses in both RTC documents are identical; the full comments are available only in the detailed document. Comments on all of the documents created during the development of the Guide are available for review. The comments received to date have been grouped into the following categories:
The IC2 understands the benefits of consistency in alternatives assessments but recognizes that one approach will not work in all situations. The Guide was designed to be very comprehensive and includes three ways in which an alternatives assessment can be conducted.
The Guide was created with an extensive stakeholder involvement process, including:
- Initial scoping of the project
- Release of the modules as they were completed for review and comment
- Three industry workshops
- Two free webinars
- A 60-day comment period
All comments were summarized in the RTC documents.
For questions concerning the Guide, contact Melissa Lavoie, 617-367-8558.
Evaluation of the IC2 Alternatives Assessment Guide
As part of its continuing effort to provide good alternatives assessment guidance, the IC2 initiated a review of the Guide. A team led by ToxServices created a uniform data set based upon work on alternatives to copper anti-fouling paint conducted by the U.S. and California EPAs. The ToxServices team expanded this work to include chemical hazard assessments of components in several alternatives and split into three independent assessment groups to conduct alternatives assessments as described within the Guide. The intent of this work, however, was not to evaluate alternatives to copper anti-fouling paint but to provide input on how the Guide could be improved. The result of this work, Assessing Alternatives to Copper Antifouling Paint: Piloting the Interstate Chemicals Clearinghouse (IC2) Alternatives Assessment Guide, has been released. A number of GreenScreens® produced in the course of this project are available through the IC2 Chemical Hazard Assessment Database.
