TRANSFORMING THE CHEMICAL

INDUSTRY:
Safer Substitutes and Solutions for a
Non-Toxic Economy

POLICY PAPER # 3
Authored by Beverley Thorpe
Clean Production Action for the LOUISVILLE CHARTER

July, 2022
ACKNOWLEDGMENTS

Thank you to the many reviewers and contributors who took the time and effort to provide valuable insights,
comments and suggestions for this paper, including: Lena Brook, Senior Advocate & Director, Food Campaigns,
Natural Resources Defense Council; Eboni Cochran, Rubbertown Emergency Action (REACT); Margaret
Reeves, Ph.D., Senior Scientist, Pesticide Action Network North America; Judith Robinson, Executive Director,
Coming Clean; Mark S Rossi, Ph.D., Executive Director, Clean Production Action; Hanna Schuler, Food Justice
Organizer, Coming Clean; Veena Singla, PhD, Senior Scientist, Natural Resources Defense Council; Joel Tickner,
Lowell Center for Sustainable Production; Monica E. Unseld, Ph.D, MPH, Executive Director, Until Justice Data
Partners.

2
SUMMARY

The urgent transformation of the chemical sector is closely linked to a transition to a fossil fuel free, renewable
energy future. We need to set carbon and chemical footprint reduction goals together in all regulatory, company
and financial policies. Just as we are at ‘code red’ for climate change mitigation, we are at ‘code red’ for halting
the ongoing toxic assault on all life from plastic proliferation and hazardous chemicals released from production
through disposal. The use of toxic chemicals has now crossed the point at which human-made changes to the
Earth push it outside the stable environment of the last 10,000 years.

Eliminating hazardous petrochemicals and plastics and replacing them with demonstrably safer
alternatives requires:

• immediately eliminating toxic emissions to workers and communities from current chemical and plas-
tics manufacturing and prohibiting the planned expansion of the petrochemicals and plastics sectors;

• redesigning chemical products and systems to reduce both carbon and chemical footprints;

• altering production processes and substituting with safer alternatives;

• eliminating non-essential uses of chemicals and using chemicals that are shown to be safe throughout
their lifecycle; and

• rewarding innovation that benefits local communities and is safe and sustainable for future generations.

All twelve Principles of Green Chemistry and Green Engineering Principles (see Appendix 1 and 2) need to
shape innovation in a transformed chemical sector that transitions from fossil-fuel based chemical feedstock
production to biobased, and other alternative forms of material synthesis, with low hazard platform chemi-
cals. Key characteristics of green chemistry continue to be developed that emphasize precaution and reduced
consumption. Reducing the complexity and overall production of chemicals is key. New chemical synthesis
designed with the above principles and key criteria will fundamentally change the chemical sector and allow
innovation in locally sourced and new chemicals with lower hazards and less resource consumption. Achieving
a non-toxic economy requires political will and a shift in power that puts the health of people and the planet
above the profits of industry.

3
The petrochemical sector’s reliance on fossil-fuel feedstocks and manufacturing processes that have evolved
little in a hundred years is a massive barrier for change – but the Louisville Charter for Safer Chemicals is a clear
roadmap for this necessary transformation. The 10 planks of the Louisville Charter provide a roadmap for the
innovation that is required to reverse the ongoing assault from hazardous chemicals and their use.

This paper outlines one important piece of the roadmap– the need for safer substitutes and solutions focusing
on the chemical sector - beginning with the seven basic building block chemicals that are used to produce the
vast majority of chemicals on the market today. It summarizes the extent of the global problem and offers policy
recommendations to help detoxify our future, reduce resource consumption, and reward innovation in safer
chemical production.

“ Achieving a non-toxic economy requires political will and a shift in power

that puts the health of people and the planet above the profits of industry.
”

4
TABLE of CONTENTS
Section 1 FOUR FUNDAMENTAL PROBLEMS WITH THE PRODUCTION AND USE OF ...5
CHEMICALS TODAY
...6
1.1 The chemical industry is not held to account for hazardous impacts.
...9
1.2 Chemicals proliferate on the market with little health data or regulation.

1.3 The number of chemicals in circulation is more than three times what has been assumed and is unsustain- ...11
ably expanding.

1.4 The planned expansion of chemicals and plastics production will increase greenhouse gas emissions, haz- ...11
ardous chemicals, plastic waste and safety risks to communities.
...14
Section 2 CHEMICAL SECTOR TRANSFORMATION
...16
2.1 Replace the current seven hazardous petrochemical building block chemicals with safer alternatives.
...21
2.2 Redesign products and systems to reduce both carbon and chemical footprints.

2.3 Prioritize a ‘hazard-first’ approach to reduce risk in chemicals management and set chemical footprint ...24
reduction goals while transitioning to inherently safer substitutes with lower hazards.

2.4 Require full material disclosure across supply chains. ...26

2.5 Bend the curve down for all chemical use and especially toxic chemicals through functional substitutions, ...27
class based restrictions, and safer substitutions with a lifecycle perspective.
...29
2.6 Prioritize hazard reduction, full material disclosure, and reduced consumption in the circular economy.

2.7 Reward innovation in safer chemicals production by removing subsidies on fossil fuel developments, tax-
ing the use of hazardous chemicals and integrating chemical footprint reduction goals and investment in safer ...31
chemicals into all ESG reporting.

2.8 Scale benefits to local communities through smaller-scale, decentralized, and modular chemical and mate- ...33
rial manufacturing facilities. Halt all new facilities from being built in or near communities.

2.9 Produce food without petrochemicals. ...34

2.10 Train the next generation in chemical hazard literacy, green chemistry and green engineering principles ...35
and policies that advance a non-toxic future.
...35
Policy recommendations for achieving plank 3 of the Louisville Charter for Safer Chemicals

5
1. FOUR FUNDAMENTAL PROBLEMS WITH THE
PRODUCTION AND USE OF CHEMICALS TODAY

This section summarizes four reasons why the chemical sector needs urgent transformation if innovation for
safer chemicals is to succeed. This section is for companies, regulators, climate change solution providers, circu-
lar economy proponents, investors, students and the general public to understand the severity of the chemical
pollution crisis.

Four major problems are:

1. The chemical industry, and those who incorporate toxic chemicals into products, are not held to ac-
count for the hazardous chemical impacts to communities, workers, wildlife and planetary ecosystems;

2. Chemicals proliferate on the market with little to no health data and few regulatory requirements for
chemical producers or downstream users of chemicals to fill much needed data gaps and/or demon-
strate safety prior to market.

3. The number of chemicals in circulation is more than three times what has been assumed. The projected
increase in chemical production will generate even more unidentified chemical substances and associ-
ated exposures. No sustainability criteria is given to justify this planned expansion.

4. The planned expansion of chemicals and plastics production will increase greenhouse gas emissions,
hazardous chemicals, plastic waste and safety risks to communities.

6
1.1 The chemical industry, and those who incorporate toxic chemicals into products,
are not held to account for the hazardous chemical impacts to communities, workers,
wildlife and planetary ecosystems.

The projected expansion of the petrochemical sector in the United States and globally will intensify health im-
pacts from toxic chemicals in tandem with the climate crisis.

The 2019 United Nations Global Chemicals Outlook confirmed1 that:

• an enormous volume of chemicals is released to the environment every year, most of which is unregulated
and much of which is toxic and hazardous (see Figure 1);

• hazardous chemicals are ubiquitous in all media, in all regions of the planet and in all human bodies;

• for people living in fenceline communities this is an Environmental Justice issue; and

• in high consumer purchasing economies, products may be the largest source of hazardous chemical expo-
sures for some populations.

Figure 1:

Credit: UN Global Chemicals Outlook Report II, 2019.

Although the global chemical industry is one of the world’s largest manufacturing industries, representing US$4
trillion of sales in 2019, it is: slow to innovate; requires massive economies of scale to be profitable; has burden-
some capital investment; and has rigid production systems that are vulnerable to economic and supply chain dis-
ruptions. It mostly relies on fossil-fuel feedstocks and is the third largest industrial source of greenhouse gasses
with many of today’s top chemical corporations being the very same companies that produce oil and gas such as
ExxonMobil, Chevron, and Shell, among others.2

7
A 2022 scientific study concludes that chemical pollution has crossed a “planetary boundary,” the point at which
human-made changes to the Earth push it outside the stable environment of the last 10,000 years, which now
threatens Earth’s systems by damaging the biological and physical processes that underpin all life. The study’s
researchers advocate for a future fixed cap on chemical production and release, in the same way carbon targets
aim to end greenhouse gas emissions.3

The petrochemical sector externalizes its costs to human and planetary health. Proximity to chemical production
sites, waste dumps and high pesticide use4 results in acute and chronic health impacts and disease. A 2022 report
from the Human Rights Council of the United Nations highlights the ‘unconscionable environmental injustices
around sacrifice zones’ such as Mossville, St. Gabriel, St. James Parish and St. John the Baptist Parish, located in
Louisiana’s Cancer Alley where cancer rates are far higher than the United States average. These predominantly
Black communities are home to more than 150 refineries and petrochemical plants, including the world’s largest
producer of polystyrene.5

The proliferation of the petrochemical industry in the United States has resulted in almost 12,500 high-risk
chemical facilities putting 39% of the US population (124 million people) who live within three miles of these
facilities at constant risk of chemical disaster.6 Workers in these facilities face ongoing injury and death from
chemical accidents.7

Health costs from hazardous chemicals use are extensive, yet producer responsibility for remediation and health
impacts is absent. A recent analysis of health impacts from per- and polyfluoroalkyl substances (PFAS) in Europe
identified annual direct healthcare expenditures at 52–84 billion euros. Equivalent health-related costs for the
United States, accounting for population size and exchange rate differences, would be $37–59 billion annually. As
the authors note, “These costs are not paid by the polluter; they are borne by ordinary people, health care pro-
viders, and taxpayers.”8 Exposures to hazardous chemicals result in immediate costs that extend throughout the
lifetime of impacted communities. For example, the costs present themselves as children with asthma (missed
school days/not feeling well in school) and/or learning disabilities that can drastically affect educational attain-
ment, reducing future earning ability, in addition to the more immediate costs to parents who have to leave work
to take care of children who are ill.

Though settlements have been won in recent lawsuits against a few chemical producers, the amounts are dwarfed
by the profitability of these companies. For example, in January 2021, DuPont, Chemours and Corteva an-
nounced a cost-sharing agreement worth $4 billion to settle lawsuits involving the historic use of PFAS chemi-
cals9 and Bayer agreed in June 202010 to pay more than $10 billion to settle tens of thousands of claims for dam-
ages caused by the glyphosate herbicide, RoundUp, manufactured by Monsanto whom they acquired two years
previously. Legal settlements do not, however, result in a ban on these targeted chemicals, or an end to ongoing
exposure from the use of the chemical.

8
In the case of glyphosate, despite the findings by the International Agency for Research on Cancer 2015 that gly-
phosate is a probable human carcinogen, the U.S. Environmental Protection Agency maintains that glyphosate is
not likely to be carcinogenic to humans, thereby allowing Roundup and other glyphosate-based herbicides to be
easily purchased throughout the country, unless a municipality has banned its use on city owned property. Fur-
thermore, Bayer’s announcement in 2021 that it will stop selling Roundup in the United States Lawn & Garden
residential market beginning in 2023, will not reduce exposure from its wider use in industrial agriculture.11

American workers in multiple industry sectors use tens of thousands of chemicals every day but only a small
number are regulated in the workplace. As a result, workers suffer more than 190,000 illnesses and 50,000 deaths
annually related to chemical exposures.12 Workplace chemical exposures have been linked to cancers, and lung,
kidney, skin, heart, stomach, brain, nerve, and reproductive diseases. In the agricultural sector, the pesticide poi-
soning incidence rate among U.S. farmworkers is 39 times higher than the incidence rate of pesticide poisoning
found in all other industries combined.13

Biodiversity is highly impacted by hazardous chemical and fertilizer use and releases to the environment. Re-
cently, researchers raised the alarm that 40 percent of all insect species are in decline and could die out in the
coming decades.14 They conclude that “a rethinking of current agricultural practices, in particular a serious
reduction in pesticide usage and its substitution with more sustainable, ecologically-based practices, is urgently
needed to slow or reverse current trends, allow the recovery of declining insect populations and safeguard the
vital ecosystem services they provide.”

Pesticides and fertilizers are an integral part of chemical production and use. Each year, an estimated one billion
pounds of pesticides are applied to U.S. farms, forests, lawns and golf courses. More than 17,000 pesticide prod-
ucts are currently on the market — with many of them approved through “conditional registration,” a regulatory
loophole that allows products on the market quickly without thorough review.15 Many of the most commonly
used pesticides are linked to a range of health impacts, including increased risk of cancer, Parkinson’s disease and
neurodevelopmental effects such as autism and ADHD.16

9
1.2 Chemicals proliferate on the market with little to no health data, and few regulatory
requirements for chemical producers or downstream users of chemicals to fill much
needed data gaps and/or demonstrate safety prior to market.

Chemicals of High Concern, are defined by international bodies as those that are Persistent, Bioaccumulative
and Toxic (PBTs); Carcinogens, Mutagens and Reprotoxic (CMR)s, Endocrine Disruptors, Neurotoxins, and
Persistent and Mobile (PM). Other chemicals of concern include those with high flammability and explosive
potential.

Although the criteria for highly hazardous chemicals are clear, the quantity of chemicals that meet this criteria is
far from clear. The vast majority of chemicals in consumer products and packaging, pesticides, and manufactur-
ing have no or only incomplete chemical hazard information.

A lack of chemical hazard data means scientists are unable to estimate the true toxic impacts to health and
biodiversity. In the US, it has been estimated that 85,000 chemicals have been used in industrial, commercial
and consumer product applications. But the global inventory analysis reveals that about one-quarter of the
CAS-numbered chemicals are not included in the North American and European inventories commonly used to
evaluate chemical exposure and impact. Researchers note that countries are making, using, or importing some
60,000 chemicals that are not well understood and regulated.17

The PFAS class of chemicals underscores how we are flying blind with unknown and untested chemical use.
PFAS have been produced and used since the 1960s. PFAS are highly persistent and will remain in the environ-
ment for thousands of years making these “forever chemicals” an urgent priority for class based restriction in
the US and globally. Biomonitoring studies by the federal Centers for Disease Control and Prevention show that
the blood of nearly all Americans is contaminated with PFAS. Additionally, water supplies for about 110 million
Americans are contaminated with PFAS – though this may be an underestimate.18 PFAS is used in common
household products for stain and grease resistance in food packaging, cookware, carpets and furniture; for water
repellency in clothing, in cosmetics and other products -- but there is no consumer labeling and few regulatory
restrictions - nor was the necessity of these chemicals ever discussed. They have been used for decades in fire-
fighting foam resulting in widespread water pollution and impact to firefighters’ health. A legal battle to uncover
data DuPont hid for decades,19 along with independent scientific data, reveals PFAS is linked to cancer, develop-
mental impacts in children and a range of other diseases. Recently PFAS has been correlated with a reduction in
the effectiveness of vaccines20 but, production of this chemical class is allowed to continue with little or no toxic-
ity information for most of the approximate 5,000 chemicals in this class and few, if any, restrictions. The result
is ongoing pollution which is perfectly legal, plus a growing legacy of costly cleanup efforts in farmers’ fields,21
drinking water supplies and toxic waste dumps22.

10
Cancer and other disease prevention efforts will fail unless chemical ingredient and hazard information is dis-
closed for all products and industrial sectors. For example, many chemicals of high concern are known to be
carcinogens and cancer is now the largest cause of death from disease in American children. In 2019, more
than 16,000 children in the United States were diagnosed with cancer, including leukemia, brain cancer, kidney
cancer, and bone cancer, with the number of new cases of cancer per 100,000 children increasing. From 1975
to 2017, leukemia incidence rates in children increased by roughly 34%, and incidence rates of brain and other
central nervous system cancers increased 40%-- and the science is clear that harmful environmental exposures
contribute significantly to these trends. However, because we lack a comprehensive list of chemicals that may
cause cancer in children, “we are essentially flying blind with no instruments,” observed Dr Philip J. Landrigan,
Professor Emeritus of Pediatrics and Preventive Medicine, Icahn School of Medicine at Mount Sinai Hospital.23

Confidential business information and lack of chemical information throughout the supply chain remain bar-
riers to innovation and obstacles in protecting community and global population health. Chemical ingredient
information for polymers is next to impossible to obtain. Researchers tested 34 products made from seven plas-
tics with the biggest market and detected more than 1,000 chemicals in these plastics, 80 percent of which were
unknown.24

This lack of chemical hazard information is tied directly to lax regulatory requirements that have not substantial-
ly changed. The growth of the petrochemical sector, particularly since the 1940s, allowed the production and use
of chemicals with no requirement for data on toxicological impact to human health and the environment. In the
United States the Toxic Substances Control Act (TSCA) passed in 1976, resulted in 62,000 industrial chemicals
remaining in commercial use, and deemed to be safe unless the Environmental Protection Agency (EPA) could
demonstrate unreasonable risk of harm. However, because the burden was on regulators to demonstrate harm,
rather than on the producer to demonstrate safety, only 5 chemicals were restricted prior to 2016. A revised Tox-
ic Substances Control Act in 2016 entrenched EPA’s requirement to demonstrate unreasonable risk, and although
several more substances have been added to the restriction list, the Act failed to require chemical producers to
demonstrate safety prior to market. This has resulted in a predicted “regulatory paralysis, especially in the face of
a well-framed opposition and critical courts.”25 In 2020 the EPA was sued by a coalition of health and environ-
mental justice organizations for failing to inform the public upon receipt of an application to manufacture a new
chemical and disclose all non-confidential information, particularly information about the health effects of and
exposures to the new chemical.26

Chemical regulation in the European Union (EU) requires comparatively more hazard data from producers
under the Regulation on the Registration, Authorisation, Evaluation and Restriction of Chemicals (REACH) but
since the regulation was passed fifteen years ago, less than 100 substances have been restricted.27 Recognizing the
need for quicker assessment of chemical hazards and restrictions of chemicals of high concern, the EU published
its Chemical Strategy for Sustainability in 2020 with the objective of better protecting citizens and the environ-
ment and boosting innovation for safe and sustainable chemicals.28 On April 26, 2022 it adopted a roadmap that
could see up to 7,000 chemicals restricted by 2030.29 This may hopefully set the template for other countries to
follow - however this will depend on the reality of political decision making in other parts of the world.

11
1.3 The number of chemicals in circulation is more than three times what has been as-
sumed. The projected increase in chemical production will generate even more uniden-
tified chemical substances and associated exposures.

A recent global inventory lists more than 350,000 chemicals and mixtures of chemicals registered for commercial
production and use worldwide, which is more than three times as many as is commonly estimated.30 In spite of
this, global chemical production continues to increase in terms of quantity, turnover and diversity.31 In recent de-
cades, production has roughly doubled every twelve years with a corresponding further increase predicted. But
this increase in chemical production lacks any justification for necessity or integration of any sustainability crite-
ria. There is no acknowledgment of producer responsibility for the life cycle impacts of these chemicals, little or
no integration of green chemistry and green engineering principles into molecular design, and no description or
any discussion as to whether these chemicals are necessary.

1.4 The planned expansion of chemicals and plastics production will increase green-
house gas emissions, hazardous chemicals, safety risks to community, and plastic
waste.

The role of petrochemicals is one of the key “blind spots” in the global energy debate, according to the Interna-
tional Energy Agency (IEA).32 The chemical industry’s contribution to climate change is detailed in the Plank 1
policy paper of the Louisville Charter for Safer Chemicals.

Petrochemicals which now account for 14 percent of oil use, are expected to drive half of global oil demand
growth between now and 2050, according to the IEA. Much of this projected increase is based on a doubling of
plastic production in the next 20 years with the U.S. seen as a growth area enabled by cheap fracked gas.

Since 2010, companies have invested more than $200 billion in 333 plastic and other chemical projects in the
U.S. and many of these facilities are in the permitting process.33 Drivers of this growth are the natural gas liq-
uids produced from US fracking sites and subsidies to the fossil fuel sector, along with corporate marketing that
natural gas is a bridging fuel to a renewable energy future. Exxon promotes natural gas as a cleaner fuel than
coal, stating that it will emit ‘significantly fewer pollutants such as NOx, SOx, particulates, mercury, and up to 60
percent fewer GHGs.34 However methane, the primary component of natural gas, is a stronger greenhouse gas
than carbon dioxide and on a weight basis has 21 times the global warming potential of carbon dioxide. Methane
leaks are common around fracking sites and satellite data reveals the fracking heartland of the US is leaking 3.7
percent of that gas into the atmosphere.35 This is worse for climate change than coal.36 Planned plastics produc-
tion will generate greenhouse gas emissions (GHG) over and above the U.S. Nationally Determined Contribu-
tions commitments to decrease GHG emissions by 50 to 52 percent by 2030.37

12
Increased chemical and plastic production will directly impact fenceline communities who are already exposed
to hazardous chemical releases and face disproportionate risk from climate change. Extreme weather events
exacerbated by climate change already demonstrate what is in store. After the landfall of Hurricane Harvey in
Houston, Texas, in 2017, oil refineries and chemical plants across the Texas Gulf Coast released more than 1
million pounds of dangerous air pollutants in the week following. Floating rooftops sank on oil storage tanks,
chemical storage tanks overflowed with rainwater, and broken valves and shutdown procedures triggered flaring
at refineries. This resulted in large releases of highly hazardous chemicals including benzene, 1,3-butadiene, hex-
ane, hydrogen sulfide, sulfur dioxide, toluene and xylene a week after the hurricane struck.38 Communities are
left with very few options in the event of an explosion or major leak. Transportation to evacuate is non-existent
for some, sheltering in place is not fully understood and may not even be an option and the purchase of masks
and other equipment that could save lives is unattainable for many.

Expansion of plastics production will generate even more single use plastic and waste, and as plastic degrades
into microplastics and nanoplastics it releases these particles and their chemical additives - many of which are
endocrine disrupting chemicals - into water, soils, air, wildlife and humans, including human placenta.39 The
entire lifecycle of plastics releases hazardous chemicals as shown in Figure 2. Plastic additives, such as phthalates,
bisphenol A and other endocrine active additives, are now reported amongst the most commonly found anthro-
pogenic substances in environmental samples.40 In 2016, the United States generated the largest amount of plastic
waste of any country in the world.41 Currently over 40% of plastics production is used in single use packaging – a
growing focus of restrictions. But although reducing the use of single use plastic packaging and passing plastic
bag bans are necessary it will not be sufficient in itself to solve the global problem created by expanded plastics
production and the increased use, and release, of highly hazardous chemicals. On March 2, 2022 heads of state,
ministers of environment and other representatives from 175 nations endorsed an historic resolution at the UN
Environment Assembly in Nairobi to address the full lifecycle of plastic, including its production, design and
disposal with a goal to achieve an international legally binding agreement by 2024.42 However implementation
of a concrete plan is still to be agreed and will be years in the making. That is why an immediate ban on planned
expansion of this sector is so urgent.

13
Credit: CIEL, Earthworks, GAIA, Healthy Babies Bright Futures, IPEN, Texas Environmental Justice Advocacy Services
(t.e.j.a.s.), University of Exeter, and UPSTREAM. Plastic & Health: The Hidden Costs of a Plastic Planet. Feb 2019.

14
SECTION 2: CHEMICAL SECTOR
TRANSFORMATION

A transition to a more sustainable chemicals sector must begin now and will require:

• immediately eliminating emissions to workers and communities from current chemical and plastics
manufacturing and prohibiting the planned expansion of the petrochemicals and plastics sectors;

• redesigning chemical products and systems to reduce both carbon and chemical footprints;

• altering production processes and substituting with safer, low hazard alternatives;

• eliminating non-essential uses of chemicals and using chemicals that are shown to be safe through-
out their lifecycle; and

• rewarding innovation that benefits local communities and is safe and sustainable for future genera-
tions and our environment.

All twelve Principles of Green Chemistry and Green Engineering Principles (see Appendix 1 and 2) need to
shape innovation in a revamped chemical sector that transitions from petroleum based chemical feedstock pro-
duction to biobased, and other alternative forms of material synthesis, with low hazard platform chemicals. Key
characteristics of green chemistry continue to be developed that emphasize precaution and sufficiency. Reduc-
ing the complexity and overall production of chemicals is key. New chemical synthesis must not put workers,
local communities or environments at risk and must be designed with the full lifecycle in mind. To this end, the
Louisville Charter for Safer Chemicals sets out ten planks to ensure any proposed roadmap to chemical sector
reform will not put disproportionate exposure and hazards on environmental justice communities.

15
Section 2 presents ten recommendations for safer substitutes and solutions. Each subsection 1-10 outlines chal-
lenges and opportunities for implementing these recommendations:

1. Replace the current seven hazardous petrochemical building block chemicals with safer alternatives.

2. Redesign products and systems to reduce both carbon and chemical footprints.

3. Prioritize a “hazard-first” approach to reduce risk in chemicals management and set chemical footprint re-
duction goals while transitioning to inherently safer substitutes with lower hazards.

4. Require full material disclosure across supply chains.

5. Bend the curve down for all chemical use and especially toxic chemicals through functional substitutions,
class based restrictions, and safer substitutions with a lifecycle perspective.

6. Prioritize hazard reduction, full material disclosure, and reduced consumption in the circular economy.

7. Reward innovation in safer chemicals production by financially penalizing petrochemicals through removing
subsidies on fossil fuel developments, taxing the use of hazardous chemicals and integrating chemical foot-
print reduction goals and investment in safer chemicals into all Environment Social and Governance report-
ing.

8. Scale benefits to local communities through smaller-scale, decentralized, and modular chemical and material
manufacturing facilities. Halt all new facilities from being built in or near communities.

9. Produce food without petrochemicals.

10. Train the next generation in chemical hazard literacy, green chemistry and green engineering principles and
policies that advance a non-toxic future.

16
2.1 A reformed chemical sector will require replacing the current seven high hazard
petrochemical building block chemicals with safer alternatives.

Currently, just seven petrochemicals are the building blocks for more than 90% of downstream organic chem-
ical production, including tens of thousands of chemical products.43 Called “platform chemicals,” these seven
chemicals are: methanol; olefins—ethylene, propylene, and butadiene; and aromatics—benzene, toluene, and
xylene. Most of these platform chemicals have high intrinsic hazards and perpetuate these hazards throughout
the value chain. For example, the benzene chain is demonstrated in Figure 3 below.
Figure 3: The Benzene Chain

Credit: American Chemistry Council Guide to the Business of Chemistry. 2020. p.8.

17
Chemical sector reform is urgent – beginning with a transition from high hazard platform chemicals to low
hazard alternatives that are designed using the 12 Principles of Green Chemistry and Green Engineering Prin-
ciples. Currently, many of the green chemistries on the market are made from fossil fuel-based building block
chemicals with high or relatively high hazards. New platform chemicals with lower intrinsic hazard are needed
and research shows these can be made from sugars, biobased feedstocks, synthetic biology techniques or other
material design options.

“ Currently, just seven petrochemicals are the building blocks for more than
90% of downstream organic chemical production, including tens of thousands
”
of chemical products... Most of these platform chemicals have high intrinsic
hazards.

To illustrate the inherent hazards of these seven petrochemical building block chemicals, GreenScreen chem-
ical hazard assessments were done for the primary chemicals, intermediate chemicals and monomers used in
nine common plastics ( Figure 4).44 GreenScreen® for Safer Chemicals45 is a globally recognized and widely
used chemical hazard assessment method that groups chemicals into four Benchmarks ranging from Bench-
mark-1 ‘chemical of high concern’ to Benchmark-4 ‘preferred chemical’ as shown in Figure 4.
Figure 4

Credit: Coming Clean, Adapted from Clean Production Action.

The Benchmark criteria were developed to reflect hazard concerns that have been established by governments
nationally and internationally. An important value of GreenScreen is that Benchmark-1, “Avoid - Chemical
of High Concern”, clearly defines the criteria for chemicals of high concern to human health and the environ-
ment consistent with global regulations like the European Union’s REACH regulation. Benchmark-1 chemicals
include: carcinogens, reproductive, developmental and neurodevelopmental toxicants, mutagens, persistent,
bioaccumulative and toxic chemicals (PBTs), very persistent and very bioaccumulative chemicals (vPvBs), and
endocrine disruptors.46

18
Figure 5:

Credit: Clean Production Action.

19
As seen in Figure 5, methanol, benzene, and xylene are all classified as GreenScreen Benchmark 1 chemicals
–”Chemical of High Concern.” Toluene and 1,3, butadiene have also been assessed as GreenScreen Benchmark-1
chemicals.47 These chemicals are not just building blocks for thousands of substances but can also be found in
consumer products including gasoline, detergents, air fresheners, toys, playground equipment, polystyrene,
polyester textiles and other common products. For example, independent testing has found hundreds of popular
personal care items in the US to be contaminated with benzene, prompting several big brands to voluntarily re-
call dozens of products.48 Ethylene and propylene, two of the seven platform chemicals, were assessed as Green-
Screen Benchmark-2, “Use but search for safer substitutes.”

Substituting these building block chemicals with lower hazard alternatives requires new molecular design that
is based on environmental and human health, as well as needed function. The 12 Principles of Green Chemistry
and associated 12 Green Engineering Principles ensure sustainability criteria are built throughout the lifecycle of
chemicals, including design, manufacture, use, and ultimate disposal (Appendix 1 and 2).
Green chemistry is the design of chemical products and processes that reduce or eliminate the use or generation
of hazardous substances.49 Green chemistry focuses on designing inherently safer chemicals and products that
are fully effective yet have little or no toxicity. The principles emphasize the need for chemicals and products to
break down to innocuous substances after use so that they do not accumulate in the environment and minimize
the potential for accidents including explosions, fires, and releases to the environment. Using renewable feed-
stocks is one of the twelve principles (see Appendix 1).

These principles are informing new developments such as safer substitutes for phthalates and halogenated flame
retardants.50 However these greener chemicals on the market are probably often sourced from the seven petro-
chemical building block chemicals discussed above with their high or relatively high hazards. To truly encom-
pass green chemistry principles, platform chemicals, as well as chemical synthesis downstream, must be designed
with renewable feedstocks and low hazards. This is fundamental to chemical sector reform. Researchers note that
designing new feedstocks with low intrinsic hazard can be facilitated by new computing tools, data from molec-
ular reference libraries and lessons learned from medicinal chemistry where human safety is paramount. Green
chemistry and engineering inspired research provide opportunities to create new building block chemicals and
novel chemistries with less energy-intensive syntheses, higher efficiency, and lower toxicity and persistence in the
environment.51 Financial incentives and supportive regulations must now reward front runners in safer chemical
synthesis that are based on low hazard platform chemicals.

The Principles of Green Engineering52 are an important complement to the Principles of Green Chemistry be-
cause they apply to the process stage of chemical production. These principles emphasize that all materials and
energy inputs and outputs are as inherently non-hazardous as possible; that waste prevention is better than treat-
ment; materials are designed for reuse and recycling; and all materials and energy should be renewable rather
than depleting (see Appendix 2).

20
Another set of green engineering principles - The Sandestin principles of Green Engineering53 - were developed
by chemists and engineers from industry, academia, and government and also include important social dimen-
sions. Principle 9 of these principles, “actively engage communities and stakeholders in development of engi-
neering solutions,” is particularly important when considering the siting of new chemical production facilities.
Local communities need to be at the table from the beginning of any proposal for new chemical production
facilities. Community participation could address criteria about the ownership of the facility; benefits to the
local economy; impacts to health and the environment; the design and necessity of these new chemicals; possible
trade offs; and more.

The Sandestin Declaration: 9 Principles of Green Engineering

• Engineer processes and products holistically, use systems analysis, and integrate environmental im-
pact assessment tools.
• Conserve and improve natural ecosystems while protecting human health and well-being.
• Use life-cycle thinking in all engineering activities.
• Ensure that all material and energy inputs and outputs are as inherently safe and benign as possible.
• Minimize depletion of natural resources.
• Strive to prevent waste.
• Develop and apply engineering solutions, while being cognizant of local geography, aspirations, and
cultures.
• Create engineering solutions beyond current or dominant technologies; improve, innovate, and invent
(technologies) to achieve sustainability.
• Actively engage communities and stakeholders in development of engineering solutions.

Green chemistry and green engineering principles together with a goal of decreased consumption need to be
central to any new material design, including nanotechnology and synthetic biology, so that innovation is by de-
sign and not by accident. But such criteria needs to be implemented before widespread commercial application
of new materials - if we are to learn anything from past mistakes.54

21
2.2 Redesigning products and systems requires a reduction in both carbon and
chemical footprints. A transition to biobased or other building block chemicals
with no consideration of hazard will only perpetuate hazardous chemical pro-
duction and use throughout the supply chain.

Carbon footprint reduction is a large focus in current sustainability metrics. A carbon footprint can be de-
fined as the total greenhouse gas emissions caused directly and indirectly by a person, organization, event
or product.55 Various forms of non fossil-based carbon exist as alternative renewable feedstocks for chemical
production to reduce the carbon footprint of facilities and thereby meet Green Chemistry Principle #7. Cur-
rent research into non arable biomass, lignocellulose, algae, chitin and biocrude from sewage and food waste is
being explored.56 Other research is investigating the use of renewable energy to convert water and CO2 from the
air into fuels and other molecules, with no need for oil.57

However, reducing carbon footprints while neglecting to reduce chemical footprints will perpetuate the toxic
chemical economy. Green chemistry principles of low inherent hazard and renewable feedstocks are equally
needed to achieve true innovation in the design of safer products and a revamped chemical sector.
A chemical footprint is a hazard based metric that identifies and measures the amount of chemicals of high
concern used by an event, organization, service, building, or product. For example the chemical footprint of an
organization would include the total mass of chemicals of high concern in products sold by a company; used in
its manufacturing operations, facilities, and by its suppliers; and contained in packaging.

“ Simply replacing fossil fuel based carbon with biobased carbon to produce
hazardous chemicals and materials is a false solution. It is essential that
”
the goals of low chemical hazard and renewable feedstocks are equally
prioritized when designing safer solutions.

Various platform chemicals can and are being produced in biorefineries and several value-added chemical
products and polymers produced in a biorefinery have been commercialized.58 In 2020, the International Energy
Agency assessed the revenue from biobased products that included platform chemicals, solvents, polymers for
plastics, paints, coatings, inks and dyes, surfactants, cosmetics and personal care products, adhesives, lubricants,
plasticisers and fibers. They estimated that the production of biobased chemicals could generate over US$10
billion of revenue for the global chemical industry.59

Biobased chemistries can be significantly less hazardous than fossil fuel chemicals, but the hazard assessment
needs to show this is indeed the case. For example, the assessment of polylactic acid (PLA) in Figure 4 shows that
the building block of this polymer is glucose, which is assessed as a GreenScreen Benchmark-3 chemical - “Use -
but still opportunity for Improvement.” Products made from platform chemicals with lower hazards and that use
additives with lower hazards are being commercialized. For example, food service ware made from PLA by Na-
tureworks has achieved a GreenScreen Certified platinum designation for achieving Benchmark-3 assessments
for all ingredients in the product.60

22
Ensuring all ingredients in a biobased product are made with lower hazard chemicals is unfortunately far from
mainstream; and producers and certifications often focus solely on reducing carbon footprints. Two examples
that neglect chemical hazard reduction in the pursuit of biobased feedstocks are given below.

SPOTTING FALSE SOLUTIONS

False Solution: Benzene, toluene and xylene made from biobased carbon sourced from forest residues,
agricultural residues and perennial crops. Chemical engineers have found a framework that determines the
most profitable processes to produce benzene, toluene, and/or xylenes from biomass via methanol.”61 How-
ever these biobased chemicals will still exert the same hazardous properties as their fossil-based counter-
parts throughout their lifecycle. As Figure 6 illustrates, there is no such thing as “green benzene.”

Figure 6:

Credit: Coming Clean, 2022.

23
 False Solution: Biobased feedstock used to produce polyvinyl chloride polymer (PVC) with inherently high
hazards. Ineos, one of the largest producers of PVC polymers, has sourced biobased carbon as their stated
contribution to a circular and sustainable economy.62 As shown in Figure 5, the company Inovyn uses renew-
able residue of wood pulp processing to produce bio-attributed PVC ‘Biovyn’. The Roundtable on Sustainable
Biomaterials (RSB) has certified each step in the process, starting from UPM Biofuels converting the wood-
based residue (crude tall oil) into hydrocarbons, through to the final polymer. Bio-naphtha is mixed with
virgin fossil naphtha from UPM when it enters the INEOS supply chain in Germany. Inovyn produces the
chlorinated chemicals (VCM) that go into PVC. Tarkett then produces PVC floor rolls and tiles which carry
the RSB certification.

The certification is promoted as a sustainable contribution to the circular economy but unfortunately, omits
any consideration of the inherent hazards in the final product or the high chemical hazards perpetuated
throughout the value chain. PVC production involves the use of vinyl chloride monomer and other chemi-
cals of high concern (Figure 4), the use of hazardous chemical additives and the generation of toxic emissions
throughout the entire product lifecycle, including at the disposal stage.63

Figure 6: Biobased feedstock is used to produce polyvinyl chloride polymer (PVC) with inherently high hazards

Credit: Roundtable on Sustainable Biomaterials (RSB) www.rsb.org.

In summary, false solutions include using biobased carbon sources (e.g., forest residues, agricultural residues or
perennial crops) to make toxic chemicals (e.g., benzene, toluene, and xylene) and materials (e.g., PVC).

24
2.3 During this transition to chemical sector reform, chemical producers must priori-
tize a “hazard-first” approach to reduce risk in chemical management and set chemical
footprint reduction goals while transitioning to inherently safer substitutes with lower
hazards. Retailers and brands, further down the supply chain, can reduce their chemi-
cal footprints even more quickly.

As green chemistry innovations are rolled out by some chemical producers and formulators in the supply chain,
the chemical footprint of the alternatives should be transparent. Chemical footprinting is the process of bench-
marking progress away from hazardous chemicals and towards safer alternatives. Measuring a chemical foot-
print allows a company to quantify their use of chemicals of high concern, and set goals to reduce their chemical
footprint over time.

Chemical hazard assessment tools and databases now exist to help companies identify chemicals of high con-
cern and choose safer alternatives with lower intrinsic hazards.64 The GreenScreen® for Safer Chemicals bench-
marking tool and other chemical hazard assessment methods are used by leading corporations, governments
and standard setting bodies to make informed decisions about their chemical choice. Identifying chemicals of
high concern based on their intrinsic hazards and choosing substitutes with lower hazards fulfills many green
chemistry principles. Hewlett Packard, an early adopter of the GreenScreen method, emphasized in 2013 why a
hazard-first approach is best:

“A basic premise of Green Chemistry is that chemical risk is most effectively managed by reducing hazards
because exposure controls can and do fail, products are used in unintended ways and end of life management of
obsolete equipment is often problematic. Therefore, a dedicated hazard screening step in the alternatives assess-
ment process to identify lower hazard options is consistent with the principles of Green Chemistry.”65

One attempt to measure the chemical footprint of chemical producers is ChemScore, which ranks the world’s top
50 chemical producers on their production of hazardous chemicals. It was developed in order to provide inves-
tors with better information to assess which companies have strong chemicals management strategies, and which
do not.66 Each company’s total production of hazardous chemicals in the European Union and the USA, is set in
relation to the company’s total revenue. The scope of hazardous chemicals includes substances on Chemsec’s SIN
List, the EU’s REACH candidate list and authorization list, a list of persistent chemicals, the Stockholm Con-
vention Persistent Organic Pollutant List, the Rotterdam Convention’s Prior Informed Consent List anda list of
Highly Hazardous Pesticides.67

Each company is scored based on their product portfolio, development of safer chemicals, management and
transparency, and lack of controversies.

ChemScore is a useful resource to contextualize the progress made by chemical producers on green chemistry
research and adoption. For example, the listing of three green chemistry achievements by Dow Inc for non-ep-
oxy can linings, safer surfactants and non solvent binders68 is an important achievement, but this is juxtaposed
by the ChemScore ranking of a D+ grade for Dow Inc in ChemScore’s 2021 report. In this case, it would be
helpful for the corporation to outline its overall plan and timeline to reduce the production of chemicals of high
concern with safer substitutes based on green chemistry and green engineering principles. Such information will
increasingly be scrutinized by investors in the near future.

25
For retailers and brands downstream from chemical producers, a reduction of their chemical footprint can be
done even quicker, notwithstanding the challenge of getting full ingredient disclosure from their suppliers. Third
party certifications for formulated products and products in other sectors such as US Safer Choice, GreenScreen
Certified™ or Cradle to Cradle Certified® allow purchasers to know a chemical hazard screen has been applied.
But such certifications cover only a minority of products being produced. That is why some retailers and brands
are calculating their chemical footprint for certain product categories and setting chemical footprint reduction
goals.

The Chemical Footprint Project (CFP) offers a way for companies to both calculate chemical footprints and
set up a best in class chemicals management system to do so. The CFP defines a chemical of high concern as a
GreenScreen Benchmark-1 chemical (“Avoid - chemical of high concern”) which is consistent with international
precedent such as the European Union’s definition of substances of very high concern. The CFP provides an open
source list of over 2,000 Chemicals of High Concern based on GreenScreen Benchmark-1 criteria to enable com-
panies to get started in identifying known chemicals of high concern and pursue comprehensive chemical hazard
information from their suppliers. Company front runners in the CFP disclose their chemical footprint reduction
goals and their progress in eliminating chemicals of high concern.69 For example, GOJO was the first company
to announce in 2015 the goal to reduce their chemical footprint by 50% by the end of 2020. The company ex-
ceeded that goal, reducing it by 64%.70 By 2022, Walmart aims to reduce its consumables chemical footprint for
applicable products in Walmart stores and Sam’s Clubs in the U.S. by 10 percent.71

It is imperative that dollar stores set chemical footprint reduction goals for the products and food they sell be-
cause consumers in these communities face cumulative impacts from hazardous chemicals.. Almont one-half
(about 13,000) of the almost 27,000 dollar stores owned by the largest US chains are located within three miles
of a hazardous facility. Residents in such communities can also experience lower rates of food access and higher
rates for cancer and risk of non-cancer respiratory disease, as compared to the rest of the country.72

26
2.4 Informed substitution requires full material disclosure throughout supply
chains.

The intention of informed substitution is to reduce or eliminate chemicals of high concern with a functional
match that is safer for humans and the environment. This is accomplished via one-to-one chemical replacement,
a change in product design, or change in manufacturing process. An evaluation of chemical function is the start-
ing point for informed substitution. In a given application, it is the function of the chemical that is important,
not the chemical itself.73 For example, the use of toxic flame retardant chemicals in electronics can sometimes be
replaced by product redesign, rather than using alternative flame retardant chemicals with lower hazards.

For brands and retailers downstream in the supply chain, choosing safer chemicals in products and manufactur-
ing processes is essential to reduce business risk, avoid regrettable substitutes, and protect human and environ-
mental health. A regrettable substitution is the replacement of a known toxic chemical with another that proves
to be equally or more harmful to human health or the environment, such as the replacement of BPA in plastics
and cash receipts with BPS - which has equal hazards.74 Regrettable substitutions often disproportionately affect
vulnerable populations that are harmed first by the original toxic chemical and then by its substitute.

A fundamental barrier to choosing safer substitutes is lack of chemical ingredient information through the
supply chain. The BizNGO Principles for Safer Chemicals75 underscore the need for manufacturers to disclose
chemical constituents in their products, particularly chemicals of high concern. Companies are endorsing The
Principles for Chemical Ingredient Disclosure to better promote transparency.76 State legislation requiring disclo-
sure of chemical ingredients is increasing77 while purchasers are demanding full material disclosure from suppli-
ers to reduce their business risk. It is essential that regulatory agencies remove barriers to full chemical ingredi-
ent disclosure.

27
2.5 Functional Substitution can reduce chemical consumption. A class based restric-
tion for many hazardous chemicals will lower consumption of chemicals and speed
adoption of safer substitutes. Safer substitutes take a lifecycle perspective, includ-
ing what platform chemicals were used at the source of production. Informed substi-
tution does not shift hazards to other communities.

Functional substitution can reduce chemical consumption. The “service” provided by a chemical could be
functionally substituted by a less hazardous chemical or through product, process, or systems-level changes.
Functional substitution also questions if the chemical is actually necessary. For example, to meet GreenScreen
certification for PFAS-free textiles, a leading textile design firm discovered that ‘often a finish is not needed at all
and that textiles without a finish, or with a PFAS-free finish, clean just as well (and sometimes better) than those
with a PFAS-based finish. Years ago it was assumed that the more layers of chemical finishing, the better, but
this thinking is outdated and we know more about the environmental impact of these chemicals now.’78 A recent
study of 35 international apparel manufacturers found that 22 had already phased out PFAS or were planning to
do so by 2030.79

A class-based approach to hazardous chemical restrictions will speed innovation in necessary and safer substi-
tutes. In October 2020, the European Union declared a goal to phase out all uses of PFAS unless a specific use
could be shown to be essential.80 This concept of “essentiality” questions the need for the production and use
of toxic chemicals and the idea that such chemicals have benefits for society.81 Chemicals are assessed as either
Non-essential; Substitutable, or Essential – with the latter requiring research and development for eventual safer
substitution. A non-essential use is defined as uses that are not necessary ‘for the betterment of society in terms
of health, safety and functioning’, such as PFAS in dental floss, cookware coatings or ski waxes. In these cases
the use of PFAS may be “nice to have” (e.g. non-stick frying pans) but it is not essential. In many cases the “nice
to have” function can be fulfilled through substitution with fluorine-free alternatives. As researchers point out,
even where there are no alternatives to PFAS for providing the “nice to have” function, the use can be banned or
phased out because it is not essential. However if the chemical’s function can be shown to be beneficial in some
cases, then the Substitution Principle82 is used to find safer alternatives within a specified time frame.

Defining the “essential uses” of hazardous chemicals will be contentious but researchers point out that there is
an established policy precedent for applying this type of framework to phase out harmful substances –the elim-
ination of ozone depleting substances within the international Montreal Protocol. How decisions will be made
about the essential use concept is yet to be clarified. But equally important will be the process to identify func-
tional substitutes for any current ‘essential’ use of a hazardous chemical and a rapid timeline to implement these
safer solutions.

28
The Montreal Protocol’s goal to remove chemicals with ozone depleting potential dealt with the immediate threat
to the ozone layer. However a comprehensive understanding of a chemical’s hazard and its breakdown products
is needed, if we are to avoid unintended consequences and prevent exposure to toxic emissions from production
sites. For example, the community in Louisville, Kentucky is experiencing the direct impacts of the production
of hydrochlorofluorocarbon-22 (HCFC-22) - which, although banned under the Montreal Protocol as an ozone
depletion chemical, received a permit for ongoing production because it is used as a feedstock chemical in other
uses. In addition to the hazardous releases from the production facility, an unwanted byproduct of HCFC-22 is
hydrofluorocarbon-23 (HFC-23), a potent greenhouse gas. The Chemours Louisville Works facility is the largest
emitter of HFC-23 in the United States.83 The local community continues to be impacted by toxic emissions from
the plant including chlorine, hydrogen chloride, chloroform and hydrogen fluoride.84

In addition to PFAS, the class based approach for elimination should be applied as a priority to organohalogens,
bisphenols, phthalates, heavy metals, and antimicrobials.85 The announcement by the European Commision on
April 26, 2022 that it has adopted a roadmap to eliminate whole chemical classes by 2030 is an important and
proactive step forward.86 In the United States, many states are now taking action on PFAS disclosure and elimina-
tion.87

The purpose of informed substitution is to prevent the use of a “regrettable substitute’’ or an alternative
with equal or higher hazards. This requires full chemical ingredient disclosure and chemical hazard in-
formation. But such transparency should also extend to how the chemical was sourced. Safer substitutes
should ultimately be made from lower hazard platform chemicals in order to be truly considered ‘safer’. To
date, there is no requirement to disclose what platform chemicals were used in the design of chemicals on
the market . Yet, transparency about the hazards of the building block chemicals used in the creation of
chemicals on the market is essential for a non-toxic future that is rooted in environmental justice, human
rights and protection of biodiversity.

29
2.6 The promotion of a Circular Economy must prioritize hazard reduction and full ma-
terial disclosure together with a decrease in consumption. Chemical recycling of plas-
tics for fuel will perpetuate toxic emissions and does not address the need to reduce
plastic production.

The promotion of a circular economy aims to move away from the linear “take-make-use-dispose” model and
transition to a regenerative growth model in order to keep resource consumption within planetary boundaries.
In a circular economy, the value of products, materials and resources is maintained in the economy for as long as
possible, and the generation of waste is minimized.88

However, reducing waste- but not addressing hazards of chemicals and materials- will only perpetuate toxic
emissions along the product chain, putting workers, communities near recycling plants and consumers of recy-
cled products at risk.

Researchers examined 540 small plastic consumer products including children’s toys, purchased in 18 countries
between 2015 and 2019. Almost ten percent of the total, mainly those made of black-colored plastic, contained
hazardous phased-out and banned polybrominated diphenyl ether (PBDE) flame retardant chemicals which
probably originated from electronic waste.89 Studies conducted by the International Pollutants Elimination
Network found that toxic chemicals that have been banned under international chemicals conventions, such
as PBDEs, are being recycled from old waste into new consumer products, such as restricted brominated flame
retardant chemicals found in recycled plastic products from China, Indonesia and Russia.90

Company leaders who promote the circular economy and who recognize the need for chemical hazard infor-
mation are advocating for stricter chemical regulations. H&M Group and Inter IKEA Group have committed to
only use 100 percent renewable, recycled or other sustainably sourced materials by 2030. They and other brands
conducted a collaborative study to examine chemicals in recycled textiles in order to identify which chemicals
might be found in waste streams containing cotton, wool and polyester. Although the majority of recovered
textiles by weight did not have hazardous substances above regulatory requirements, at least ten percent of textile
waste did contain substances of high concern. The companies concluded that chemicals hampering recycling
and material recovery should be restricted as a class to avoid regrettable substitutions and avoid legacy waste
problems.91 A focus on fast-fashion and the need to cut consumption in the apparel sector overall is a necessary
corollary to reducing the sector’s use of hazardous chemicals.

Substituting single-use plastics with reusable alternatives helps to reduce plastics use and is an urgent priority in
procurement specifications and legislation. The National Reuse Network is a movement of activists and inno-
vators creating a world without toxic, single-use food and beverage packaging. The network supports leaders
working across the U.S. to catalyze and pass policies that promote reuse and reduce single-use food and beverage
packaging and ensure that reducing toxic chemicals in packaging is integrated in the policy work.92

30
The disproportionate impact on environmental justice communities living at the fenceline of plastic and chem-
ical production is well documented but needs much higher awareness and action. The Environmental Justice
Health Alliance for Chemical Policy Reform is a national network of grassroots Environmental and Economic
Justice organizations and advocates in communities that are disproportionately impacted by toxic chemicals
from legacy contamination, ongoing exposure to polluting facilities and health-harming chemicals in household
products.93 Their submitted comment letter to the White House Office of Science and Technology Policy on June
8, 2022, emphasized the need to inclusively engage and address the harms faced by communities disproportion-
ately affected by current practices of chemical use, production and disposal as the federal government develops a
consensus definition of “sustainable chemistry.”94 The comment also calls for a “focus on equity and justice at all
stages of the chemical lifecycle,” particularly during oil and gas extraction, chemical production, product manu-
facturing and use, and disposal and end of life.

Replacing fossil fuel feedstocks with chemical recycling of plastics is contentious. Chemical recycling technol-
ogies use heat, chemical reactions, or both, to break down used plastics into raw materials for new plastic, fuel,
or other chemicals. The US Government Accountability Office is researching chemical recycling as one way to
reduce the amount of plastic that ends up in landfills and is asking policymakers what steps could be taken to
further incentivize chemical recycling rather than disposal.95 However this does not address the inherent toxicity
of plastics throughout the lifecycle of these materials and it perpetuates the use of fossil fuel feedstocks. It is also
an unproven technology and could release hazardous emissions into communities already exposed to dispro-
portionate and cumulative emissions. While the viability and impacts of plastic repolymerization remain highly
uncertain, industry uses the term “chemical recycling” to greenwash plastic-to-fuel technologies, seeking public
approval for the continued use and disposal of plastic.96

According to the NGO Chemsec, a leading advocate for strong European chemical policy, chemical recycling
could have a role to play in reducing resources, if certain conditions are met97 and the content of the materi-
al poised for recycling is known and safe. This is a subject under intense scrutiny and needs to be positioned
within the larger criteria of essentiality, low hazard chemicals and materials and functional substitution to reduce
consumption. To date this has not happened. In the meantime the planned expansion of increased plastic pro-
duction will increase hazardous chemical use, toxic releases and waste into communities and the global environ-
ment.

31
2.7 Reward and incentivize innovation in safer chemicals production through financial
incentives including removing subsidies on fossil fuel developments, taxing the use
of hazardous chemicals and integrating chemical footprint reduction goals and invest-
ment in safer chemicals into all Environment Social and Governance reporting.

Our society wants healthy products and food. Regulators need to support research and development that will ad-
vance low hazard chemicals and materials. This requires ending perverse subsidies and tax breaks for oil and gas
production.98 Current government subsidies to the oil and gas sector —upward of $20 billion/year in the United
States—should be reallocated to support renewable energy and green chemistry development - with a focus on
local community supported enterprises. Doing so would raise the price of fossil fuels, making sustainable feed-
stocks more competitive, and provide the market signals that would drive new private-sector investments.99

New chemical manufacturing can involve a diversity of smaller-scale producers employing a range of feedstocks
and production processes. It is anticipated that a more networked and collaborative chemical industry and
matching supply chains will be more agile and better prepared for faster adoption of innovations and reaction to
disruptions, changing market conditions, and new knowledge of unintended negative impacts.100

A widely cited 2004 U.S. Department of Energy study, summarizes the opportunity of biomass-derived basic
chemicals – some of which are already in use.101 But this study, almost twenty years old, needs updating to reflect
the opportunities in new biobased and molecular opportunities that are sustainable with low hazards throughout
their lifecycle.

Regulations should not stifle innovation in safer substitutes but hazardous materials and plastics are often cheap-
er than lower hazard substitutes. Without parallel fiscal incentives, companies may try to avoid substitution for
as long as possible. An assessment of fiscal policies that could help companies adopt safer chemicals includes a
tax on hazardous chemical use, subsidies and grants to cover part of the increased investment and operational
costs associated with the switch to alternatives. Researchers found that giving companies economic incentives
for moving away from hazardous chemicals can unlock a multi-billion market for safer alternatives.102

The financial sector will have an essential role in transforming the chemical sector but it must set roadmaps that
advance a non-toxic future. A report entitled, The Invisible Wave - Getting to Zero Chemical Pollution in the
Ocean, published by Economist Impact103 summarizes the various ways that investors could take action.

32
Three recommendations from this report are given below - with modifications to further advance overall chemi-
cal sector reform:

1. To date most of the reporting on Environment, Social and Governance (ESG) measures under ESG reporting
has focused on persuading companies to reduce their climate emissions—hence the global wave of corpo-
rate pledges to reach a net zero carbon impact. While the focus on climate will remain, momentum is also
growing for investments that are net zero, nature-positive and socially just. For example, Shareholder activist
group ShareAction launched a campaign in September 2021 targeting the chemicals industry over its carbon
emissions from the seven building block chemicals (referred to in 2.1). ShareAction argued that phasing out
these seven platform chemicals would provide the sector with a credible decarbonisation pathway.104 This
example offers creative opportunities to put the focus on both the chemical footprint and carbon footprint
of these chemicals, and together plan a fundamental shift to renewable platform chemicals with low chemical
hazards.

2. The report recommends that reporting to clear principles is needed. For example the Ocean Business Action
Platform has developed a set of Sustainable Ocean Principles. Major investment funds are working with the
UN Global Compact to support companies using the principles as a reporting mechanism. In this case, the
Louisville Charter for Safer Chemicals could be used to define clear principles for investors and financial
bodies who are keen to support protection of biodiversity and environmental justice.

3. The report’s roadmap for investor-led action on marine chemical pollution could be modified for wider
chemical sector reform as summarized below. For example the roadmap could:

• Develop improved ESG guidance, particularly around emerging nature-related frameworks such as the new
Taskforce on Nature Related Financial Disclosures to include social justice and chemical footprint audits.
Aligning to a widely agreed list of chemicals of high concern such as GreenScreen Benchmark-1 chemicals
and chemical classes such as PFAS, will help measure chemical footprints and support the ESG community
in driving corporations to reduce their use of toxic chemicals.
• Publish more and better data, that is free, accessible and open access, particularly around companies’ chemi-
cal hazard impacts and plans to reduce their chemical footprint while investing in research and development
of green chemistry innovations.
• Provide a template for setting out the risks that investors may face during the transition to a more sustainable
and socially just chemical sector.
• Provide collaborative ways for industry and investors to work together to uncover opportunities for transi-
tion financing and align the supply of, and demand for, large-scale deals.
• Outline how private equity and Mergers & Acquisitions activity can help drive innovation in the burgeoning
green chemistry startup scene.
• Outline a just transition plan for impacted workers and communities during the transition.
• Establish a clear mechanism for early and active participation by impacted communities in any financial or
investment planning.

33
2.8. New innovations in chemical processes could benefit local communities through
smaller-scale decentralized, or modular facilities - but regardless of the type of man-
ufacturing facility, appropriate zoning laws should apply and prohibit construction in
close proximity to homes or schools. Community participation in decision making will
be key.

Designing safer chemicals and materials will involve a variety of new technologies such as bioprocessing, elec-
trochemistry, and new synthetic molecular processes. It will also involve a complete change in infrastructure
and scale of production. According to researchers, the potential for these forms of production to benefit local
communities through smaller-scale decentralized, or modular facilities could enable regional manufacturing and
differentiation in chemical production based on local feedstocks and help protect against the impacts of global
supply chain disruptions.105

The environmental justice considerations and impact on communities from the location of biorefineries and the
chemicals and products being produced needs to be prioritized. The IEA notes that: “Biorefinery development
… requires a social contract from the communities and countries in which they plan to operate. This can include
issues of direct and indirect employment, new skills development, health, noise and nuisance factors, ownership
and consultative decision-making.”

As new forms of production are proposed, it is important that local communities who will be most impacted by
innovations are participants in decision making with full information disclosure from the beginning to the end.
The history of petrochemical expansion has resulted in the unjust and disproportionate exposure to fenceline
communities. The planned expansion of chemical and plastic production facilities will further increase this toxic
assault on communities. That is why innovation in the production of safer chemicals must prioritize community
engagement. Community residents, not just local businesses, must be consulted at the beginning of any proposal
- and not as an add on once decisions are made. The expertise of community members is based on actual lived
experience - which is often not understood by companies and regulators. Leaders working at the intersection of
environmental justice and chemical policy recommend106 that regulators and companies engage vulnerable pop-
ulations to participate in deliberations and decisions about:

• the uses and exposures at each lifecycle phase of proposed alternatives to avoid shifting the burden of hazard-
ous exposure to another community;
• trade-offs in decision making;
• the social, economic and job implications of switching to an alternative;
• how to regularly evaluate progress and implement further changes as needed.

As renewable feedstocks are increasingly promoted, information about the health and environmental impact
from the sourcing of feedstocks will also be important. Are chemicals of high concern used in the production of
these feedstocks? What are the environmental justice impacts from the sourcing of these feedstocks? What are
the health impacts to workers, communities and the environment? These considerations need to be foundational
in the transition to a biobased chemical economy. Otherwise we will simply replicate the mistakes created by the
petrochemical sector, as set out in Section 1.

34
2.9 Promoting what is known to be safer - food and fiber production without petro-
chemicals.
Crucial to reversing the climate crisis along with the loss of biodiversity, food insecurity and water crisis is an
overhaul of food and fiber production. Chemical hazard reduction is a key reason to transition from intensive
industrial agriculture to sustainable and more local food production. There is limited justification or need for
petrochemical use in agriculture and farmers have shown non toxic alternatives are effective. The simplest and
most direct indicator that synthetic pesticides and fertilizers are unnecessary for economically viable production
of virtually every crop in the U.S. market is the continuing positive growth of the certified organic industry that
disallows use of virtually all petroleum-derived synthetic pesticides and all fertilizers. The organic sector has
relied primarily on market forces alone to grow and thrive. In order to realize the full health, environmental and
economic benefits of organic farming systems, we need to ramp up governmental support for organic-specific
technical assistance and research programs. Farmers and ranchers would also benefit from incentive programs
that help offset the risk of adopting new practices during the three year organic transition process. The 2019
USDA Organic Survey showed that sales of certified organic crops increased by 31% from the previous survey in
2016. The number of operations producing certified organic commodities was up 17%, and land used for certi-
fied organic production was up 9%. This represents 16,585 farms, 5.5 million acres, and $9.9 billion in sales.107
However financial support for organic farming needs to be reflected in a reduced price for organic food sold in
stores. The cost of organic produce is too costly for most people, which further increases cumulative impacts to
communities already highly impacted by toxic chemical exposure. Lowering the cost of organic food will ex-
pand the market and bring multiple health benefits from a reduction in pesticide exposure to farmworkers and
consumers.

Certified organic farming can be considered a first step in a transition to a safer, more agroecological food
system.108 Agroecology is a scientific discipline, a set of practices and a social movement. As a set of practices, it
seeks sustainable farming systems that optimize and stabilize yields. An agroecological transition can be pro-
posed at several levels, usually starting with resource use efficiency, followed by the substitution of convention-
al inputs. The ultimate goal is not only to promote substitutions that reduce the reliance on external synthetic
inputs, but also a redesign of the system to one that embraces complexity in order to enhance diversification and
recycling, gain nutritional quality and promote farmer and community autonomy. As with green chemistry inno-
vation, fiscal and regulatory policies are urgently needed to scale sustainable food production.

35
2.10 Train the next generation in chemical hazard literacy, green chemistry and green
engineering principles and policies that advance a non- toxic future

Understanding the human and environmental health impacts from hazardous chemicals – and the opportunities
for safer solutions – should be integrated into a wide range of educational curricula, including medical, biolo-
gy, economic, and engineering departments. Few doctors understand the link between chemical exposure and
impacts to human health. For most people, the word ‘chemicals’ sounds complicated and overwhelming. Most
science, engineering or business degrees do not integrate an understanding of hazardous chemicals impact into
biology, chemistry, engineering or business administration curricula.

To teach the next generation, we need to increase literacy about chemical impacts across the entire education
system, and as an immediate measure prohibit the use of harmful chemicals in schools. Some efforts are now
being made. For example, Beyond Benign provides educators with the tools, training and support to make green
chemistry an integral part of chemistry education. Set to launch in 2023, the Green Chemistry Teaching and
Learning Community (GCTLC) is a new online community resource sharing and network co-developed by Be-
yond Benign and the ACS Green Chemistry Institute.109 Incentives and rewards are needed at collegiate level to
encourage students to pursue a future in safer chemical design. This is a start, but we need to also massively scale
awareness about the tools, databases and networks that are available to help companies, regulators and the public
promote a non-toxic future.

POLICY RECOMMENDATIONS FOR PLANK 3

1. A transition to a more sustainable chemicals sector must begin by prohibiting the planned expansion of both
petrochemicals and plastics production and engaging in mandatory emissions reductions of toxic output
from this sector. This involves:

• A halt to permitting process for new petrochemical and plastics production facilities.
• No decades-long ‘transition’ fuels such as natural gas as a bridging technology.
• Immediate removal of all fossil fuel subsidies, financial support, tax relief, and grants for current petrochem-
ical production.
• Urgent, mandatory chemical emissions reduction that are real, permanent and verifiable by impacted com-
munities. This must be accompanied by the adoption of policies and practices that remedy the dispropor-
tionate chemical hazards and exposures faced by environmental justice communities - communities of color,
Tribes and Native/Indigenous communities, and low-income communities. See Louisville Charter Plank 2:
Prevent Disproportionate Exposures and Hazards, and Reduce Cumulative Impacts on Environmental Jus-
tice Communities.
• Transition planning for workers.

36
2. A transition to a more sustainable chemicals sector prioritizes a ‘hazard first’ approach to risk reduction guid-
ed by all 12 Green Chemistry Principles and green engineering principles. Priority is given to a clear implemen-
tation plan to transition away from current petrochemical building block chemicals to renewable feedstocks and
platform chemicals with lower hazards.

3. New chemical production facilities produce materials with clearly stated functionality, and created from lower
hazard platform chemicals and renewable feedstocks. Producers supply full disclosure of chemical ingredients
and an assessment of their chemical hazards. Communities are fully informed and participate as priority stake-
holders in decisions concerning the permitting and ownership of new chemical production plants.

4. During this transition phase, current chemical producers adopt a ‘hazard-first’ approach for risk reduction in
their chemical portfolio and set chemical footprint reduction goals. Chemical classes with high hazards are a pri-
ority for elimination with a clear timeline. Functional substitutes are prioritized for research and development
and an implementation plan.

5. Regulations require full material disclosure from chemical producers and reverse the onus of proof onto pro-
ducers to transparently demonstrate safety of chemical products and assume the otherwise externalized costs on
society.

6. Promoters of a circular economy prioritize chemical hazard reduction and full material disclosure into all
circular economy implementation plans. Chemical recycling of plastics is prohibited for polymers containing
chemicals of high concern. Full disclosure of chemical constituents and their hazard assessments is mandated
for all polymers. Chemical recycling under the guise of ‘plastic waste to fuel’ otherwise known as incineration, is
prohibited.

7. A comprehensive plan for financial support and investor strategy for green chemistry startups that benefits
local communities and involves community participation is established. Policy rewards and incentivizes inno-
vation in safer chemicals production and use throughout the supply chain. Incentives for purchasing low hazard
products are created that are comparable to financial incentives for low energy use, such as Energy Star. Finan-
cial and regulatory support for organic food production and agroecology is prioritized. Financial incentives in-
clude, but are not limited to, removing subsidies on fossil fuel developments, taxing the use of hazardous chem-
icals and integrating chemical footprint reduction goals and investment support for safer chemicals innovation
into all Environment Social and Governance reporting.

8. Chemical impact literacy is integrated across the education system at all levels. Knowledge of human health
impacts from hazardous chemicals is integrated into biology, chemistry, engineering and business administra-
tion curricula. Course curricula for sustainable design in any application integrate green chemistry and green
engineering principles.

37
Appendix 1: The 12 Principles of Green Chemistry

1. Prevent waste: Design chemical syntheses to prevent waste. Leave no waste to treat or clean up.

2. Maximize atom economy: Design syntheses so that the final product contains the maximum proportion
of the starting materials. Waste few or no atoms.

3. Design less hazardous chemical syntheses: Design syntheses to use and generate substances with little
or no toxicity to either humans or the environment.

4. Design safer chemicals and products: Design chemical products that are fully effective yet have little or
no toxicity.

5. Use safer solvents and reaction conditions: Avoid using solvents, separation agents, or other auxiliary
chemicals. If you must use these chemicals, use safer ones.

6. Increase energy efficiency: Run chemical reactions at room temperature and pressure whenever possible.

7. Use renewable feedstocks: Use starting materials (also known as feedstocks) that are renewable rather
than depletable.

8. Avoid chemical derivatives: Avoid using blocking or protecting groups or any temporary modifications if
possible. Derivatives use additional reagents and generate waste.

9. Use catalysts, not stoichiometric reagents: Minimize waste by using catalytic reactions.

10. Design chemicals and products to degrade after use: Design chemical products to break down to in-
nocuous substances after use so that they do not accumulate in the environment.

11. Analyze in real time to prevent pollution: Include in-process, real-time monitoring and control during
syntheses to minimize or eliminate the formation of byproducts.

12. Minimize the potential for accidents: Design chemicals and their physical forms (solid, liquid, or gas)
to minimize the potential for chemical accidents including explosions, fires, and releases to the environ-
ment.

38
Appendix 2: Principles of Green Engineering

1. Designers need to strive to ensure that all materials and energy inputs and outputs are as inherently
non-hazardous as possible.

2. Prevention Instead of Treatment. It is better to prevent waste than to treat or clean up waste after it is
formed.

3. Design for Separation. Separation and purification operations should be designed to minimize energy
consumption and materials use.

4. Maximize Efficiency. Products, processes and systems should be designed to maximize mass, energy,
space, and time efficiency. Simplicity is key.

5. Products, processes, and systems should be “output pulled” rather than “input pushed” through the use
of energy and materials.

6. Conserve Complexity when making design choices on recycle, reuse, or beneficial disposition.

7. Targeted durability, not immortality, should be a design goal.

8. Meet Need, Minimize Excess. Designing for unnecessary use or “one size fits all” solutions should be
considered a design flaw.

9. Minimize Material Diversity to promote disassembly and value retention.

10. Integrate Material and Energy Flows in the design of products, processes, and systems with available
energy and materials flows.

11. Design for Commercial “Afterlife.”

12. Material and energy inputs should be renewable rather than depleting.

39
Endnotes

1 United Nations Environment Programme. Global Chemicals Outlook II: From Legacies to Innovative Solutions 11 March 2019
Global Chemicals Outlook II: From Legacies to Innovative Solutions | UNEP - UN Environment Programme

2 Joel Tickner, Ken Geiser & Stephanie Baima (2021) Transitioning the Chemical Industry: The Case for Addressing the
Climate, Toxics, and Plastics Crises, Environment: Science and Policy for Sustainable Development, 63:6, 4-15, DOI:
10.1080/00139157.2021.1979857

3 Linn Persson, et al. Outside the Safe Operating Space of the Planetary Boundary for Novel Entities. Environ. Sci. Technol. 2022, 56,
3, 1510–1521. Publication Date:January 18, 2022. https://doi.org/10.1021/acs.est.1c04158

4 US Geological Survey Maps. Pesticide Info. Pesticide Action Network. https://www.pesticideinfo.org/pesticide-maps/usgs

5 United Nations. Human Rights Council. Forty-ninth session. The right to a clean, healthy and sustainable environment: non-tox-
ic environment. Report of the Special Rapporteur on the issue of human rights obligations relating to the enjoyment of a safe,
clean, healthy and sustainable environment. Feb 28, 2022 https://www.ohchr.org/EN/NewsEvents/Pages/DisplayNews.aspx?News-
ID=28254&LangID=E

6 Coming Clean Inc. LIFE AT THE FENCELINE: UNDERSTANDING CUMULATIVE HEALTH HAZARDS IN ENVIRON-
MENTAL JUSTICE COMMUNITIES. Environmental Justice Health Alliance. September 2018. https://ej4all.org/life-at-the-fence-
line
7 Chemical Safety Board https://www.csb.gov/

8 The True Cost of PFAS and the Benefits of Acting Now. https://pubs.acs.org/doi/10.1021/acs.est.1c03565 quoted in The True Cost of
Toxic Materials Rebecca Stamm, Dec 22, 2021 https://www.greenbiz.com/article/true-costs-toxic-materials

9 DuPont, Chemours and Corteva Reach $4 Billion Settlement on ‘Forever Chemicals’ Lawsuits. Jan 22, 2021. Environmental Work-
ing Group. https://www.ewg.org/news-insights/news-release/dupont-chemours-and-corteva-reach-4-billion-settlement-forever-chem-
icals

10 Roundup Maker to Pay $10 Billion to Settle Cancer Suits. New York Times. June 24, 2020. https://www.nytimes.com/2020/06/24/
business/roundup-settlement-lawsuits.html

11 Where is Glyphosate Banned? Baum Hedlund. March 2022. https://www.baumhedlundlaw.com/toxic-tort-law/monsanto-round-

up-lawsuit/where-is-glyphosate-banned-/

12 U.S. Occupational Safety & Health Administration (OSHA). Transitioning to Safer Chemicals. https://www.osha.gov/safer-chemi-
cals

13 Calvert, GM, J Karnik, L Mehler, J Beckman, B Morrissey, J Sievert, R Barrett, M Lackovic, L Mabee, A Schwartz, Y Mitchell, and
S Moraga-McHaley. 2008. Acute Pesticide Poisoning Among Agricultural Workers in the United States, 1998–2005. Am J Indust Med
51:883-898.

14 Francisco Sanchez-Bayo. Worldwide decline of the entomofauna: A review of its drivers. Biological Conservation
Volume 232, April 2019, Pages 8-27. 2019. https://doi.org/10.1016/j.biocon.2019.01.020

15 Pesticide Action Network. Pesticides 101. https://www.panna.org/pesticides-big-picture/pesticides-101

16 Collaborative on Health and the Environment https://www.healthandenvironment.org/our-work/toxicant-and-disease-database/?-

showcontaminant=2380

40
17 Chemical & Engineering News. Number of chemicals in commerce has been vastly underestimated. 12 February 2020. https://cen.
acs.org/policy/chemical-regulation/Number-chemicals-commerce-vastly-underestimated/98/i7

18 PFAS Contamination of Drinking Water Far More Prevalent Than Previously Reported
New Detections of ‘Forever Chemicals’ in New York, D.C., Other Major Cities. Environmental Working Group. Jan 2020. https://www.
ewg.org/research/national-pfas-testing/

19 The Lawyer Who Became DuPont’s Worst Nightmare. New York Times. Jan 6, 2016. https://www.nytimes.com/2016/01/10/maga-
zine/the-lawyer-who-became-duponts-worst-nightmare.html

20 PFAS Exposure in Infancy Linked to Reduced Vaccine Response. Grandjean, P. National Institute of Environmental Health Scienc-
es. https://www.niehs.nih.gov/research/supported/sep/2017/pfas-exposure/index.cfm

21 America’s Dairyland May Have a PFAS Problem. NRDC. October 2019. https://www.nrdc.org/stories/americas-dairyland-may-
have-pfas-problem

22 Costs of PFAS Contamination. Safer States. 2019. https://saferchemicals.org/wp-content/uploads/2019/02/safer_states_costs_of_

pfas_contamination.pdf

23 Childhood Cancer: Cross-Sector Strategies for Prevention. Cancer Free Economy. 2020. https://www.cancerfreeeconomy.org/
childhood_cancer_prevention/

24 Consumer Reports. Most Plastic Products Contain Potentially Toxic Chemicals, Study Reveals. Oct 2, 2019. https://www.consumer-
reports.org/toxic-chemicals-substances/most-plastic-products-contain-potentially-toxic-chemicals/

25 Sheldon Krimsky. The unsteady state and inertia of chemical regulation under the US Toxic Substances Control Act. PLOS Biology.
2017 https://journals.plos.org/plosbiology/article?id=10.1371/journal.pbio.2002404

26 Earthjustice. Report: Trump’s EPA sued for concealing health studies, violating its chemical laws
Agency breaks Toxic Substances Control Act rules constantly. 18 March 2020. https://earthjustice.org/news/press/2020/report-trumps-
epa-sued-for-concealing-health-studies-violating-its-chemical-laws

27 ECHA and Restriction. accessed 27 April 2022. https://echa.europa.eu/substances-restricted-under-reach

28 European Commission. Chemicals Strategy. 2020 https://ec.europa.eu/environment/strategy/chemicals-strategy_en

29 European Commission. Restrictions Roadmap under the Chemicals Strategy for Sustainability. https://ec.europa.eu/docsroom/doc-
uments/49734

30 Environ. Sci. Technol. 2020, DOI: 10.1021/acs.est.9b06379

31 UNEP. Global Chemicals Outlook, GCO II Synthesis report, https://www.unep.org/resources/report/global-chemicals-out-

look-ii-legacies-innovative-solutions

32 The Future of Petrochemicals. Oct 2018. International Energy Agency. https://www.iea.org/reports/the-future-of-petrochemicals

33 The Plastics Pipeline: A Surge of New Production Is on the Way. Dec 2019. Yale School of the Environment. https://e360.yale.edu/
features/the-plastics-pipeline-a-surge-of-new-production-is-on-the-way

34 ExxonMobil. Natural Gas. https://corporate.exxonmobil.com/Operations/Natural-gas Accessed March 20, 2022

41
35 New Scientist. Fracking wells in the US are leaking loads of planet-warming methane. 22 April 2020.
https://www.newscientist.com/article/2241347-fracking-wells-in-the-us-are-leaking-loads-of-planet-warming-methane

36 Bill McKibben. Yale Environment. How Climate Activists Failed to Make Clear the Problem with Natural Gas. March 13, 2018.
https://e360.yale.edu/features/how-climate-activists-failed-to-make-clear-the-problem-with-natural-gas-mckibben

37 Coming Clean. The Chemical Industry: An Overlooked Driver of Climate Change. Authored by Darya Minovi. https://comingclean-
inc.org/assets/media/images/Louisville%20Charter%20content/plank%201%20policy%20paper.pdf

38 The Washington Post. Harvey causes chemical companies to release 1 million pounds of extra air pollutants. September 4, 2017.
https://www.texastribune.org/2017/09/04/harvey-causes-chemical-companies-release-1-million-pounds-extra-air-po/

39 Antonio Ragusa, et al. Plasticenta: First evidence of microplastics in human placenta, Environment International,
Volume 146, 2021, https://doi.org/10.1016/j.envint.2020.106274

40 Anderson Abel de Souza Machado, et al. Microplastics as an emerging threat to terrestrial ecosystems.
Global Change Biology. 15 December 2017, https://doi.org/10.1111/gcb.14020

41 Kara Lavender Law, et al. The United States’ contribution of plastic waste to land and ocean. Science Advances. 30 Oct 2020, Vol 6,
Issue 44. DOI: 10.1126/sciadv.abd0288

42 UN Environment Program. Historic day in the campaign to beat plastic pollution: Nations commit to develop a legally binding
agreement. March 2, 2022. https://www.unep.org/news-and-stories/press-release/historic-day-campaign-beat-plastic-pollution-na-
tions-commit-develop

43 2020 Guide to the Business of Chemistry (Washington, DC: American Chemistry Council, 2020), cited in Joel Tickner, Ken Geiser
& Stephanie Baima (2021) Transitioning the Chemical Industry: The Case for Addressing the Climate, Toxics, and Plastics Crises, Envi-
ronment: Science and Policy for Sustainable Development, 63:6, 4-15, DOI: 10.1080/00139157.2021.1979857

44 Clean Production Action. Plastics Scorecard. Appendix 3. 2014. https://www.cleanproduction.org/resources/entry/plastics-score-

card-resource

45 GreenScreen® for Safer Chemicals. Clean Production Action. https://www.greenscreenchemicals.org/learn

46 GreenScreen® for Safer Chemicals benchmarking method. Clean Production Action. https://www.greenscreenchemicals.org/learn/
full-greenscreen-method

47 Coming Clean. When the Wind Blows. 2015. See appendix 4. https://comingcleaninc.org/wind-blows

48 The Guardian. Carcinogenic chemical benzene found in hundreds of US personal care products. 18 March 2022. https://www.
theguardian.com/us-news/2022/mar/18/benzene-carcinogenic-chemical-personal-care-products-us

49 US Environmental Protection Agency https://www.epa.gov/greenchemistry/basics-green-chemistry

50 Plastic Additives and Green Chemistry. Pure and Applied Chemistry. 2013. https://www.degruyter.com/document/doi/10.1351/
PAC-CON-12-08-08/html

51 Joel A. Tickner, Ken Geiser & Stephanie Baima (2022) Transitioning the Chemical Industry: Elements of a Roadmap To-

42
ward Sustainable Chemicals and Materials, Environment: Science and Policy for Sustainable Development, 64:2, 22-36, DOI:
10.1080/00139157.2022.2021793. Page 28.

52 Anastas, P.T., and Zimmerman, J.B., “Design through the Twelve Principles of Green Engineering”, Env. Sci. and Tech., 37, 5,
94A-101A, 2003. available at https://www.acs.org/content/acs/en/greenchemistry/principles/12-design-principles-of-green-engineer-
ing.html

53 Abraham, M.; Nguyen, N. “Green engineering: Defining principles” – Results from the Sandestin conference. Environmental Prog-
ress 2004, 22, 233-236.DOI: 10.1002/ep.670220410 accessed at https://www.acs.org/content/acs/en/greenchemistry/principles/sandes-
tin-declaration-9-principles-of-green-engineering.html

54 Elizabeth Grossman. Chasing Molecules. Poisonous Products, Human Heath, and the Promise of Green Chemistry. See discussion
in Chapter 8. 2009.

55 Carbon Trust. What is a Carbon Footprint? 2018. https://www.carbontrust.com/resources/carbon-footprinting-guide

56 The path to renewable fuel just got easier. Science News. Feb 2, 2022. https://www.sciencedaily.com/releases/2022/02/220202091930.
htm

57 Can the world make the chemicals it needs without oil? Robert F. Service. AAAS. September 2019. https://www.sciencemag.org/
news/2019/09/can-world-make-chemicals-it-needs-without-oil

58 The Chemical Footprint Project. Measuring a chemical footprint. Clean Production Action. https://www.chemicalfootprint.org/
learn/measuring-a-chemical-footprint

59 Sudhakar Takkellapati, et al. An Overview of Biorefinery Derived Platform Chemicals from a Cellulose and Hemicellulose Biorefin-
ery. Clean Technol Environ Policy. 2018 Sep; 20(7): 1615–1630.
doi: 10.1007/s10098-018-1568-5

60 Bio-based Chemicals. A 2020 update. IEA Bioenergy: Task 42: 2020: 01.

61 Energy Fuels 2016, 30, 6, 4970–4998 Publication Date: May 2, 2016 https://doi.org/10.1021/acs.energyfuels.6b00619

62 Energy Fuels 2016, 30, 6, 4970–4998 Publication Date: May 2, 2016 https://doi.org/10.1021/acs.energyfuels.6b00619

63 Roundtable on Sustainable Biomaterials. Chemicals & Polymers Booklet. https://rsb.org/chemicals-polymers/

64 See for example: Health Care Without Harm. Why PVC remains a problematic material. June 23. 2021. https://www.noharm-asia.
org/articles/news/europe/why-pvc-remains-problematic-material

65 OECD Substitution and Alternatives Assessment Tool Selector. http://www.oecdsaatoolbox.org/Home/Tools

66 Helen Holder et al. Hewlett-Packard’s Use of the GreenScreen for Safer Chemicals. Issues in Environmental Science and Technolo-
gy. Chemical Alternatives Assesments. RSC Publishing. 2013. Page 162.

67 International Chemical Secretariat (Chemsec). ChemScore Report 2021. https://chemscore.chemsec.org/about/

68 Chemsec. https://chemscore.chemsec.org/methodology/product-portfolio/

69 Dow https://corporate.dow.com/en-us/seek-together/green-chemistry-sustainable-world.html

43
70 Clean Production Action. Chemical Footprint Project Survey Guidance. See case studies of chemical footprint metrics and policies.
https://www.chemicalfootprint.org/assess/survey-guidance

71 GOJO Exceeds its Chemical Footprint Reduction Goal. Jan 18, 2022. https://www.gojo.com/en/Newsroom/Blog/2022/GOJO-Ex-
ceeds-its-Chemical-Footprint-Reduction-Goal

72 Walmart Sustainability Hub. Sustainable Chemistry Implementation Guide. https://www.walmartsustainabilityhub.com/sustain-

able-chemistry/implementation-guide/advancing-safer-formulation

73 Coming Clean. Life At the Fenceline, 2015.

74 Joel Tickner, et al. Alternatives assessment and informed substitution: A global landscape assessment of drivers, methods, policies
and needs. Sustainable Chemistry and Pharmacy Volume 13, September 2019, 100161. 2019 https://doi.org/10.1016/j.scp.2019.100161

75 Leo Trasande. Exploring regrettable substitution: replacements for bisphenol A. The Lancet. June, 2017 https://doi.org/10.1016/
S2542-5196(17)30046-3

76 Biz NGO https://www.bizngo.org/safer-chemicals/principles-for-safer-chemicals

77 Biz NGO https://www.bizngo.org/public-policies/principles-for-chemical-ingredient-disclosure

78 Safer States Bill Tracker. Chemical Prioritization / Disclosure / Phase-out. https://www.saferstates.org/bill-tracker/FilterBills

79 Bev Thorpe. Champions Designing PFAS-free and Healthier Furniture and Fabrics with GreenScreen Certified™. Clean Production
Action. Feb 23, 2022. https://www.greenscreenchemicals.org/resources/entry/champions-designing-pfas-free-and-healthier-furni-
ture-and-fabrics-with-greenscreen-certified

80 Joel Tickner. Op cit. 2022

81 European Union Chemicals Strategy for Sustainability. October 2020. https://ec.europa.eu/environment/strategy/chemicals-strate-

gy_en

82 The concept has its roots in the Montreal Protocol (1987) which phased out the use of ozone-depleting chlorofluorocarbons except
for certain ‘essential’ uses. See:- The concept of essential use for determining when
uses of PFASs can be phased out. : Environ. Sci.: Processes Impacts, 2019, 21, 1803.
https://pubs.rsc.org/en/content/articlepdf/2019/em/c9em00163h

83 Substitution Principle can be defined as the replacement or reduction of hazardous substances in products and processes by less
hazardous or non-hazardous substances, or by achieving an equivalent functionality via technological or organisational measures. -
Substitution of Hazardous Chemicals in Products and Processes. Oekopol. 2003.

84 Phil McKenna, Jame Bruggers. A Single Chemical Plant in Louisville Emits a Super-Pollutant That Does More Climate Damage
Than Every Car in the City. Inside Climate News. March 9, 2021. https://insideclimatenews.org/news/09032021/a-single-chemical-
plant-in-louisville-emits-a-super-pollutant-that-does-more-climate-damage-than-every-car-in-the-city/

85 James Bruggers, Phil McKenna. Chemours’ Process for Curtailing Greenhouse Gas Emissions Could Produce Hazardous Air Pollut-
ants in Louisville. Inside Climate News. November 19, 2021. https://insideclimatenews.org/news/19112021/chemours-process-for-cur-
tailing-greenhouse-gas-emissions-could-produce-hazardous-air-pollutants-in-louisville/

44
86 Green Science Policy Institute. Class Concept. https://greensciencepolicy.org/our-work/class-concept/

87 European Commission. Restrictions Roadmap under the Chemicals Strategy for Sustainability. https://ec.europa.eu/docsroom/doc-
uments/49734

88 Safer States. PFAS. https://www.saferstates.com/toxic-chemicals/pfas/

89 European Commission. Circular Economy. https://ec.europa.eu/environment/topics/circular-economy_en

90 Natsuko Kajiwara, et al. Recycling plastics containing decabromodiphenyl ether into new consumer products including children’s
toys purchased in Japan and seventeen other countries, Chemosphere, Volume 289, 2022
https://doi.org/10.1016/j.chemosphere.2021.133179

91 IPEN. Plastic Poisons the Circular Economy. 13 February 2022. https://ipen.org/tags/toxic-recycling

92 H & M Group. Large scale study from H&M Group and IKEA shows potential to transform the way we use recycled textiles. 5
October 2021. https://hmgroup.com/news/large-scale-study-from-hm-group-and-ikea-shows-potential-to-transform-the-way-we-use-
recycled-textiles/

93 Upstream. The Reuse Movement. https://upstreamsolutions.org/national-reuse-network

94 Environmental Justice Health Alliance. https://ej4all.org/about/environmental-justice-health-alliance

95 Green Chemistry Experts and Environmental Justice Advocates Call on OSTP to Center Environmental Justice and Fully Reflect Of-
fice’s Equity Action Plan in Efforts to Define and Advance Sustainable Chemistry. June 8, 2022. https://comingcleaninc.org/latest-news/
in-the-news/sustainable-chemistry

96 US. General Accounting Office. Can Chemical Recycling Reduce Plastic Pollution? Oct 5, 2021. https://www.gao.gov/blog/
can-chemical-recycling-reduce-plastic-pollution

97 Rollinson, A., Oladejo, J. (2020). Chemical Recycling: Status, Sustainability, and Environmental
Impacts. Global Alliance for Incinerator Alternatives. doi:10.46556/ONLS4535

98 Chemsec. 5 key points that must be met for chemical recycling to work. May 17, 2021. https://chemsec.org/5-key-points-that-must-
be-met-for-chemical-recycling-to-work/

99 EESI https://www.eesi.org/papers/view/fact-sheet-fossil-fuel-subsidies-a-closer-look-at-tax-breaks-and-societal-costs#1

100 Joel Tickner. Op cit. 2022

101 Joel Tickner. Op cit.

102 U.S. Department of Energy, Top Value Added Chemicals from Biomass: Volume 1: Results of Screening for Potential Candidates
from Sugars and Synthesis Gas (Washington, DC, 2004). Cited in Joel Tickner. Op cit

103 Chemsec. Unlock the market -- Economic incentives for alternatives to hazardous chemicals. Final report. January 2022. https://
chemsec.org/giving-companies-economic-incentives-for-moving-away-from-hazardous-chemicals-can-unlock-a-multi-billion-mar-
ket-for-safer-alternatives/

104 Back to Blue. The Invisible Wave - Getting to Zero Chemical Pollution in the Ocean.Chapter 7. Economist Impact. 2022. accessed
at https://backtoblueinitiative.com/the-invisible-wave-getting-to-zero-chemical-pollution/

45
105 Slow Reactions: Chemical companies must transform in a low-carbon world, ShareAction (September 2021). See:
https://api.shareaction.org/resources/reports/Slow-Reactions-Chemicals-and-Climate.pdf

106 Joel Tickner, et al. op cit 2022

107 NRDC. Selecting Safer Alternatives to Toxic Chemicals and Ensuring the Protection of the Most Vulnerable: A Discussion Draft.
2017.

108 USDA https://www.nass.usda.gov/Publications/Highlights/2020/census-organics.pdf

109 Wezel, A., Herren, B.G., Kerr, R.B. et al. Agroecological principles and elements and their implications for transitioning to sustain-
able food systems. A review. Agron. Sustain. Dev. 40, 40 (2020). https://doi.org/10.1007/s13593-020-00646-z

46