Optimizing Chemicals Management in the United States and Canada through the Essential-Use Approach

Abstract

Chemicals have improved the functionality and convenience of industrial and consumer products, but sometimes at the expense of human or ecological health. Existing regulatory systems have proven to be inadequate for assessing and managing the tens of thousands of chemicals in commerce. A different approach is urgently needed to minimize ongoing production, use, and exposures to hazardous chemicals. The premise of the essential-use approach is that chemicals of concern should be used only in cases in which their function in specific products is necessary for health, safety, or the functioning of society and when feasible alternatives are unavailable. To optimize the essential-use approach for broader implementation in the United States and Canada, we recommend that governments and businesses (1) identify chemicals of concern for essentiality assessments based on a broad range of hazard traits, going beyond toxicity; (2) expedite decision-making by avoiding unnecessary assessments and strategically asking up to three questions to determine whether the use of the chemical in the product is essential; (3) apply the essential-use approach as early as possible in the process of developing and assessing chemicals; and (4) engage diverse experts in identifying chemical uses and functions, assessing alternatives, and making essentiality determinations and share such information broadly. If optimized and expanded into regulatory systems in the United States and Canada, other policymaking bodies, and businesses, the essential-use approach can improve chemicals management and shift the market toward safer chemistries that benefit human and ecological health.

Quaternary Ammonium Compounds: A Chemical Class of Emerging Concern

“…This includes many QACs used in products listed in Table S1. Chemicals regulated under TSCA are subject to less rigorous risk assessment requirements than those managed under FIFRA. , Access to information about QACs also varies depending on how the QAC is used. While manufacturers who make pesticidal claims need to have their labeling information (i.e., active ingredient concentrations, consumer warnings, information about how to obtain directions on proper use) reviewed and approved by the EPA under FIFRA, many of the products listed in Table S1 (e.g., hair conditioners, fabric softeners) that utilize the same QACs for other purposes or without making pesticidal claims can be sold without providing the same type of information to the end user.…”

“…SCIL lists several QACs as ingredients of the lowest concern within the functional class of surfactants. 205 Unfortunately, while the SCIL criteria are publicly available, 206 the chemical-specific health and environmental hazard information is not, making it difficult to determine the degree to which these QACs have been assessed, particularly for hazard end points identified in this review.…”

“…The fact that there is already widespread exposure and growing evidence of adverse environmental and human health impacts of QACs suggests that source control to reduce exposure should be considered, for example, through the essential-use approach. 206 The essential-use approach states that chemicals of concern should only be used where their function is necessary for health and safety, or is critical for the functioning of society, and no safer alternatives exist. This approach has been used in various contexts beginning with the 1987 Montreal Protocol to phase out certain ozone-depleting substances (e.g., chlorofluorocarbons).…”

PFAS: forever chemicals—persistent, bioaccumulative and mobile. Reviewing the status and the need for their phase out and remediation of contaminated sites

“…in the semiconductor industry, often proved to be very complex and it was difficult to assess the substitutability of PFAS applications [40]. The concept of essential uses is currently also discussed in North America to be eventually implemented in chemicals management [41]. The EU Commission plans to include this concept in the upcoming revision of the REACH regulation [35].…”

Invited Perspective: Why Systematic Reviews, Scoping Reviews, and Evidence-to-Decision Frameworks Are Critical for Transparent, Consistent, Equitable, and Science-Based Decision-Making in Environmental Health

“…Potentially toxic chemicals that are used for non-essential items—such as Bisphenol A—should be banned immediately. 30 In addition, nonessential items that require the use of and release potentially toxic chemicals—such as polycarbonate water bottles 31 —also should be banned.…”