Require Safer Substitutes and Solutions: Making the Substitution Principle the Cornerstone of Sustainable Chemical Policies

Currently, chemical regulations in the United States do not prioritize the production and use of inherently safe chemicals. At present, when regulations get passed to target a chemical for control, safer substitutes are not the goal nor are there specific guidelines or tools used to achieve Green Chemistry, Clean Production, or sustainable product design. In most cases, the replacement is often just as hazardous or simply a reduction of the quantity or concentration of the toxic substance that has been targeted. In contrast, by placing the Substitution Principle at the heart of new chemical policies and regulations, hazardous chemicals would be replaced with less hazardous alternatives or preferably alternatives for which no hazards can be identified. This would hasten the uptake of Green Chemistry, or environmentally benign chemical synthesis. Substituting hazardous chemicals goes beyond finding a drop-in chemical alternative and can include systems, materials or process changes. Regulatory drivers include a clear timeline for phase out of priority chemicals based on their inherent hazard, mandatory substitution planning for hazardous chemicals, financial and technical support for companies to find safer materials, and increased funding for green chemistry development and uptake by companies.